Our submissions and applications

The Breast Cancer Aotearoa Coalition makes submissions and applications to Government, Te Whatu Ora, Pharmac and health organisations with the aim of improving the access to, and quality of, treatment for women with breast cancer. 

On this page you can view the recent submissions and applications we've made.

2023

• In October BCAC provided a comprehensive summary of the benefits of incorporating the measurement and reporting of breast density within breast screening programmes. This was provided in response to a request from BreastScreen Aotearoa (BSA) for views on breast density within the New Zealand breast cancer sector. Our submission makes the case for BSA to measure and inform women of their breast density as high density is both a risk factor for breast cancer and masks tumours in mammograms. We make the case that it is our right to be informed of this significant risk factor so we can understand whether we need additional screening and surveillance, to avoid late detection of breast cancer. We provide a summary of uptake of density reporting internationally and ask that Aotearoa NZ become an early adopter rather than a late follower of this global trend. Read our breast density submission here.
• In August medical writer Marion Barnett, BCAC Committee Member and Metavivor, summarised access to medicines for advanced breast cancer in Aotearoa NZ. Marion's paper lists medicines available by breast cancer sub-type and compares our access to that recommended in international guidelines and medicines funded in Australia. Read the paper here.
• In June BCAC wrote to Medsafe urging them to progress the registration of Enhertu (trastuzumab deruxtecan, T-DXd) with urgency. This vital medicine provides greater progression free and overall survival for those with advanced HER2 positive breast cancer and is the standard of care defined in NZ and international treatment guidelines. AstraZeneca applied for registration in January 2023 and Medsafe gave the applicg that ation priority status. However, after 6 months there appears to have been no progress. Patients need this medicine now. Read our letter to Medsafe here.
• In June BCAC responded to Manatū Hauora’s (the Ministry of Health’s) second consultation on its draft Long-Term Insights Briefing on Precision Health: Exploring opportunities and challenges to predict, prevent, diagnose, and treat disease more precisely in Aotearoa New Zealand. We outlined the wonderful opportunities to improve healthcare for the people of Aotearoa through commitment to the development and uptake of innovative technologies. Read our second Precision Health response here. 

• In June BCAC responded to a Pharmac consultation on whether to replace Herceptin (trastuzumab) with a biosimilar equivalent medicine, Herzuma. We stated we are supportive of the switch as Herzuma has been used safely and effectively since 2019 and the switch will free up funds for other therapies. We're pleased Pharmac will retain a stock of Herceptin in case anyone has problems with Herzuma and to see long-term patients can have a 'treatment holiday' and return to treatment later. We're deeply disappointed to see access has not been extended to allow retreatment following progression on trastuzumab in metastatic breast cancer, especially given the lack of other funded options. Later line retreatment is recommended in evidence-based guidelines compiled by experts around the world including ESMO, NCCN and New Zealand's ABC NZ2. We're also sad to see Pharmac has not funded a rapidly injectable form of trastuzumab as this would enable patients to receive treatment in a doctor's clinic in 10 minutes, providing easier, more equitable access and taking pressure off our cancer treatment centres. Read our full submission here.

• In March BCAC wrote a submission to the Ministry of Health on the new Women's Health Strategy, which is being drafted as required by the Pae Ora Act. BCAC stressed the importance of ensuring that breast cancer was explicitly covered in the strategy and suggested three key areas needing change and better resourcing. Read our full submission here.
• In March BCAC responded to Pharmac’s consultation on potential changes to Rule 8.1b of the Pharmaceutical Schedule that governs the way in which treatments for paediatric cancers are funded. Read our submission here.
• In March BCAC wrote a submission on the Therapeutic Products Bill, which is now being considered by the Health Select Committee before being passed into legislation. BCAC has grave concerns about this Bill, particularly the loss of any ability to import medicines not registered in New Zealand, the broad definition of 'advertising' that could effectively prevent any information on new medicines being made available to patients, and the potential to discourage clinical trials of new medicines in New Zealand.  Read our submission here. 
• In January BCAC responded to a call from Te Manatū Hauora (Ministry of Health) for input on the topic of Precision Health, which is being considered for inclusion in the next Long-term Insights Briefing to Government. BCAC’s Fay Sowerby wrote a comprehensive submission, in which she describes how both precision health and precision medicine present huge opportunities for improvements in breast cancer care. Fay says that we are on the cusp of seeing a growing range of new tools to predict breast cancer risk and to identify who needs greater surveillance using new technologies. This increased precision will direct tests and treatments to those that need them most, at the time they most need them, and result in significant improvements in both quality of life and survival. Read our submission here.

2022

• In December BCAC wrote to Pharmac requesting that the current funded form of goserelin be replaced with a different brand. The product in now use has a faulty applicator with a blunt needle that causes pain, bruising and bleeding and often fails to successfully deliver the capsule as required. Patients, breast care nurses and clinicians have all reported problems with the current brand. Some patients have stopped their treatment because of these issues. Goserelin plays an important role in ovarian function suppression and can improve long-term outcomes for pre-menopausal women with hormone receptor positive breast cancer, so it is vital that a better form be provided. Read our letter here.
• In November BCAC submitted a formal application to Pharmac to fund pembrolizumab (Keytruda) both for high-risk early-stage triple negative breast cancer (TNBC) and for advanced TNBC. Read our submission here and our summary of clinical data supporting our submission here.
• In November BCAC responded to a Pharmac consultation on the funding of oral vinorelbine. We strongly supported this proposal, noting the benefits for those living in remote and rural areas as well as Māori and Pacific women who tend to experience barriers to treatment access. An oral form will enable immunocompromised patients to avoid clinic visits where there may be risk of Covid exposure. Read our response here. 
• In October BCAC responded to a Pharmac consultation on the introduction of trastuzumab (Herceptin) biosimilars. Australia funded five different biosimilars between 2019 and 2020 and these have proven to be equivalent in efficacy, with no additional side effects. BCAC supports the introduction of biosimilars and asks that Pharmac work with patient groups and clinicians to ensure patients receive high quality information about any product switch. We asked that a sub-cutaneous (injectable) form be introduced, to increase the ability to treat close to home, broaden access and address current inequities, especially for Māori and Pacific people. This would take pressure off infusion services and improve access for those living at a distance from cancer treatment centres. We also asked that trastuzumab be made available for retreatment in advanced breast cancer after disease progression on trastuzumab. This is the international standard of care and the backbone on which new life-extending treatment regimens are built. Read our submission here.
• In August BCAC submitted a formal application to Pharmac seeking funding for eribulin (Halaven) to treat people whose breast cancer has progressed after two prior chemotherapy regimens for advanced disease. This would provide a much needed option after other treatments have failed. Read our summary of clinical trial data here and our description of clinical need here. Pharmac's Pharmacology and Therapeutics Advisory Committee (PTAC) will consider this application in November 2022.
• In June BCAC responded to Pharmac's consultation on their proposal to make trastuzumab emtansine (Kadcyla) available to people who have residual disease after neo-adjuvant HER-2-targeted therapy. BCAC supported the provision of this medicine for the specified group of patients who have early HER2 positive breast cancer and are at high risk of recurrence. However, BCAC was concerned that Pharmac proposed to limit access to a second treatment with trastuzumab emtansine for these women, should their cancer return as metastatic disease. At present, trastuzumab emtansine is an important medicine for those with metastatic HER2 positive breast cancer. BCAC's response can be found here.
• In March BCAC responded to a Pharmac consultation on whether to extend funded treatment with zoledronic acid to prevent bone loss in early breast cancer from 2 years to 3. We presented data showing that access should be extended to the full duration of treatment with aromatase inhibitors and suggested that restrictions on prescribing be removed to allow physicians to determine what would be best for their patients. This was subsequently implemented. Read our submission here.

2021

• In December BCAC submitted on the Government's Pae Ora Healthy Futures Bill. We asked that the new legislation await the final report of the Pharmac Review Panel and incorporate any changes recommended to Pharmac's operations. Sadly the Government chose to enshrine the original 1993 wording, meaning this timely opportunity for reform was lost and cost constraint remains Pharmac's driving purpose. Read our submission here.
• In November, BCAC wrote to Pharmac to inform them that many patients were experiencing pain, discomfort, difficulty and stress with the new brand of goserelin they had funded. The delivery mechanism was faulty and the needle blunt, so we requested they replace this brand of oestrogen-suppressing medicine urgently so patients weren't driven to cease treatment, potentially compromising their outcomes.
• In July BCAC made a comprehensive submission to the independent review panel set up by the Government to conduct a review of PHARMAC. You can read this submission here.
• PHARMAC recently proposed declining a number of inactive funding applications. This included first line fulvestrant for metastatic breast cancer, lapatinib later line for metastatic breast cancer and pertuzumab neo-adjuvant for early breast cancer. Following a review of the clinical trial evidence, we made a submission that these medicines are recommended in international guidelines and they will benefit some patients so we oppose the proposal to decline them. View the complete submission here.
• BCAC met with Minister of Health, Hon. Andrew Little in March 2021. The three key issues BCAC raised with the Minister were: risk management and targeted screening for early detection and prompt treatment; improving access to medicines; and introducing precision genetic testing. Read our briefing here.
• BCAC provided feedback to PHARMAC's proposed changes to how their advisory committees operate. In relation to the Consumer Advisory Committee (CAC) we suggested: refining the definition of a consumer for CAC so that members are people who can genuinely provide advice from the perspective of affected patients; that CAC members be drawn from people nominated by groups representing patients; and that CAC members be required to consult those needing a particular medicine or medical device under consideration, through recognised patient groups and individual patients.
• With respect to Clinical Advisory Committees in PHARMAC's proposed changes BCAC suggested: the inclusion of a consumer representative on both the Pharmacology and Therapeutics Advisory Committee (PTAC) and its Specialist Advisory Committees; experts in the disease area (such as clinicians who have been involved in clinical trials) and consumers in the disease area under discussion be brought in to provide their knowledge, experience and insights when particular treatments are under consideration; PTAC and its Specialist Advisory Committees to provide much more advice to PHARMAC, for example, providing advance knowledge across particular disease areas, to allow planning for future developments, rather than just reacting to submissions; more frequent meetings and timely provision of minutes to speed the provision of advice.
• Read BCAC's full response on these changes here.

2020

• BCAC has objected strongly to PHARMAC's proposal to decline funding of nab-paclitaxel. Read the consultation response submitted in October 2020.
• Fay Sowerby, BCAC Secretary, has written two papers discussing breast screening protocols in New Zealand and the need to improve them. Read Moving towards personalised breast screening in New Zealand. The second paper, Improving our breast screening protocols, can be read here.
• Members of BCAC's committee met with the newly established Cancer Control Agency in January 2020. Read a summary of our response to the recently published New Zealand Cancer Action Plan 2019-2029.
• BCAC made a submission in January 2020 to PHARMAC supporting their proposal to fund palbociclib (Ibrance) as a first-line and second-line treatment of HR-positive, HER2-negative locally advanced or metastatic breast cancer. Read the submission.

2019

• BCAC's AGM was held on the 3rd December. See a copy of Libby Burgess's, BCAC Chair, report here.
• BCAC and Breast Cancer Cure made a joint submission in response to the proposed Cancer Action Plan 2019-2029. Read our submission here.
• BCAC responded to a consultation from PHARMAC regarding the funding of breast cancer medicine trastuzumab emtansine (T-DM1 Kadcyla) for HER-2 positive metastatic breast cancer. We supported the proposal to provide access to this treatment and asked PHARMAC to widen the criteria further than initially proposed. Read our response.
• We also responded to a PHARMAC consultation to fund fulvestrant (Faslodex®) for post-menopausal (either naturally or induced) women with locally advanced or metastatic (advanced) oestrogen-receptor positive breast cancer whose disease has progressed following previous treatment with either an aromatase inhibitor (letrozole, anastrozole, exemestane) or tamoxifen. BCAC endorsed this proposal but also asked for access to be given with urgency. Read our response here.
• BCAC appeared before the Health Select Committee in early August to speak to their submission regarding the Petition of Emma Crowley for the Breast Cancer Aotearoa Coalition: Fund Breast Cancer Drugs. You can read a copy of our submission here.
• In May BCAC made a submission to the Health and Disability Review. Read a copy here.
• BCAC presented a petition to Parliament on 7th May along with a number of other disease groups who presented petitions at the same time all requesting the funding of various medicines. The BCAC petition Petition of Emma Crowley for the Breast Cancer Aotearoa Coalition: Fund Breast Cancer Drugs urged the Minister of Health to provide sufficient funding to PHARMAC to subsidise all of the drugs listed in the Euorpean ESMO guidelines for the treatment of advanced breast cancer. Read a copy of BCAC deputy chair Emma Crowley's speech at that presentation here.
• BCAC made a submission in March to the Health Select Committe in support of Terre Maize's petition for funding of Ibrance and Kadcyla - see a copy here. Also here a summary of that submission.
• BCAC met and worked with all Auckland District Health Boards (DHBs) to improve treatment options by improving local delivery of chemotherapy and targeted therapies in South Auckland. This work continues and BCAC wrote a detailed report for the Auckland DHB - How can ADHB achieve greater equity and improved outcomes for Maori and Pasifika breast cancer patients and how could BCAC assist?  View a copy here.

2018

• In November 2018, BCAC made an application for the funding of palbociclib (Ibrance) for those currently being treated for hormone receptor positive metastatic breast cancer. BCAC made the application because the recommendation for funding is only for those who haven't already received a hormonal treatment such as tamoxifen or an aromatase inhibitor. This means if this funding recommendation is appproved, funding will only be provided to those who are newly diagnosed and all those currently being treated will be excluded. See the application here.
• In August 2018, BCAC made a submission to the Health Select Committee in favour of the immediate introduction of intraoperative radiotherapy (IORT) by Intrabeam to the public health system in New Zealand. IORT is a highly effective treatment option for New Zealand women in selected cases of early-stage breast cancer. Read our submission.
• In July 2018, BCAC made a submission on PHARMAC's Consumer Voice consultation, where it sought input into how it could better incorporate the consumer voice into its work. In our submission we said PHARMAC must collaborate and partner with consumers/patients at every step of the decision making process, in place of the current very formal and closed PHARMAC structure. This would improve decisions leading to enhanced outcomes for all those involved including consumers, family, whānau, communities and PHARMAC. Read the submission here.
• In July 2018, BCAC and Breast Cancer Foundation NZ made a strongly worded and evidence-based joint submission to PHARMAC requesting that funding for Perjeta (pertuzumab) be extended to all people with HER2-positive advanced breast cancer. Read the submission here. Read the poster referred to in the letter: Final overall survival (OS) analysis of PHEREXA study.
• In July 2018, BCAC met with the Associate Minister of Health Hon. Julie Anne Genter, Labour’s Health and Wellbeing Caucus member Hon. Louisa Wall and National’s Health spokesperson Hon. Michael Woodhouse. The two key issues highlighted by BCAC in the talks were the need to improve access to medicines; and the need to address inequities for Māori and Pasifika women in breast cancer screening and treatment. Read the submission here.
• BCAC made an application for the medcine Afinitor (everolimus) to be funded. This is used for the treatment of women with hormone receptor positive HER-2 negative advanced breast cancer (ABC) – in combination with exemestane (or tamoxifen or fulvestrant) in post-menopausal women after recurrence or progression following a non-steroidal aromatase inhibitor. See the application here.
• BCAC has also made two further applications to PHARMAC in 2018 for other medicines to be funded. One for Abraxane (nab-paclitaxel) which is used to treat advanced breast cancer in people who have already received other medicines. See the application here. The other application is for Faslodex (fulvestrant) which is used to treat hormone-receptor-positive advanced breast cancer in postmenopausal women with disease progression following anti-oestrogen therapy. See the application here.

2017

• Following the funding of Perjeta by PHARMAC in late 2016, BCAC and the Breast Cancer Foundation NZ made a joint submission to PHARMAC early this year to request extending the funding of Perjeta to include all those being treated with Herceptin (trastuzumab) for metastatic HER2 positive breast cancer. This request was not declined outright but PHARMAC stated they require more clinical trial evidence before extending the funding. Read the submission here.

2016

• In December 2016, BCAC met with the Minister of Health and presented a briefing which made a case for increased medicines funding and outlined other areas of concern. Read the full briefing here.
• In November 2016, BCAC made a submission to PHARMAC applauding their decision to fund pertuzumab for HER2+ metastatic breast cancer patients. However, there are some aspects of the proposed Special Authority criteria for access to pertuzumab that we have serious concerns about. Read our submission here.
• In October 2016, BCAC provided feedback to PHARMAC’s consultation on the implementation of Trans Pacific Partnership (TPP) provisions and other amendments to application Processes. Read our feedback here.
• Early in 2016 BCAC made a joint submission with the Breast Cancer Network Australia (BCNA) to the Royal Australian and New Zealand College of Radiologists to suggest that the Faculty amend its position that Intra-Operative Radiation Therapy (IORT) is not supported by sufficient evidence to form a view. Read the full submission here.

2015

• In March 2015, BCAC met with Minister of Health Jonathan Coleman, Associate Minister of Health Peter Dunne and Labour Health spokesperson, Annette King. We highlighted the need for improved access to breast cancer medicines, ensuring the Breast Cancer Standards are implemented, better access to clinical trials, the ability to review the safety and ethical status of clinical trials and the timely introduction of intra-operative radiotherapy. Read the full briefing here.

2014

• In October 2014, BCAC made a submission to PHARMAC asking that funding of pertuzumab (Perjeta) for the treatment of metastatic HER2 positive patients be given a high priority following the outstanding results from the CLEOPATRA study showing its efficacy. Read our letter to PHARMAC here.

2013

• In October 2013, BCAC met with the Minister of Health Tony Ryall, the Associate Minister of Health Jo Goodhew and Labour Health spokesperson, Annette King.  We highlighted the need for progress in the following areas: an appropriate body to review the safety of clinical trials involving NZ patients; the need for improvements to lymphoedema care, psychosocial care, subsidised fertility treatment and delayed breast reconstruction; the need for changes to the free breast screening age bands; and funding issues in the public and private sectors.  Read our briefing to the Minister of Health here.
• In November 2013, BCAC wrote to the National Health Committee, asking it to recommend introducing intraoperative radiotherapy using Intrabeam for selected patients with breast cancer in the public health system.  Read out letter to the National Health Committee here.
• In August 2013, BCAC made a submission to PHARMAC regarding the decision criteria it uses for funding medicines. Read our response to PHARMAC's Decision Criteria Consultation here.
• In April, BCAC wrote in support of a PHARMAC proposal to consider funding Pegfilgrastim to prevent neutropenia in patients undergoing chemotherapy.

2012

• In October 2012, BCAC met the Minister of Health Tony Ryall, the Associate Minister of Health Jo Goodhew, Health Select Committee member Dr Jackie Blue, Labour Health spokesperson Maryan Street and Green Health Spokesperson Kevin Hague to deliver a strong message about the needs of New Zealanders with breast cancer. Read more about what we told the politicians here.  
   
• In August 2012, BCAC commented on a proposal by the Government's drug-buying agency, PHARMAC, to create a nationally consistent list of medicines which it would fund for all District Health Boards. Read more about what BCAC had to say on the suggested schedule of pharmaceuticals here. 
   
• In June 2012, BCAC commented on a proposal by the Government's drug buying agency, PHARMAC, to change it's operating policies and procedures. You can read  BCAC's submission on Pharmac's operating policies and procedures here.