Kidney Health New Zealand (KHNZ) welcomes the opportunity to provide feedback on Pharmac’s proposal to widen access to empagliflozin, dulaglutide and liraglutide for people with type 2 diabetes.
KHNZ believes people living with chronic kidney disease should not miss out on funded access to empagliflozin solely because they do not have diabetes and/ or heart failure, where treatment is considered clinically appropriate by a renal specialist.
KHNZ strongly supports widening access to empagliflozin and acknowledges the significant benefits this medicine can provide in slowing progression of chronic kidney disease (CKD), reducing cardiovascular complications and reducing hospitalisations for many New Zealanders living with type 2 diabetes.
New Zealand urgently needs a stronger focus on kidney disease prevention, earlier detection and treatment. Medicines that can slow disease progression and delay or prevent dialysis should be considered an important part of that response.
However, we are concerned that the current proposal does not address access to empagliflozin for the substantial number of New Zealanders living with chronic kidney disease who do not have diabetes and/or heart failure.
Chronic kidney disease is a growing health challenge
Chronic kidney disease is one of New Zealand’s fastest-growing health challenges and affects at least one in 10 New Zealanders. Māori, Pacific, and Indo-Asian peoples are disproportionately affected and experience significantly higher rates of advanced kidney disease and dialysis.
CKD is often referred to as a “silent disease,” because many people experience no symptoms until kidney function is severely reduced.
As KHNZ has consistently highlighted through community engagement, advocacy and public education, earlier detection and treatment are critical to slowing progression of kidney disease and reducing pressure on patients, whānau and the health system.
Equitable access remains important
Māori and Pacific peoples experience significantly higher rates of chronic kidney disease, dialysis and kidney-related complications in New Zealand.
KHNZ acknowledges concerns raised regarding the proposed removal of the ethnicity-based access pathway for empagliflozin and notes emerging New Zealand evidence suggesting improved access to SGLT2 inhibitors may help reduce inequities in kidney and diabetes outcomes for Māori and Pacific peoples.
Recent Waikato and Auckland research found significantly greater mortality improvements associated with SGLT2 inhibitor use among Māori and Pacific peoples, with researchers concluding these medicines may help reduce longstanding health inequities.
KHNZ therefore supports ongoing monitoring of access and prescribing patterns to ensure any changes to funding criteria do not unintentionally worsen existing inequities in kidney health outcomes.
Evidence supports broader CKD access
Recent international evidence demonstrates that empagliflozin significantly slows progression of chronic kidney disease and reduces cardiovascular mortality regardless of whether a person has diabetes.
The EMPA-KIDNEY trial found empagliflozin reduced the risk of CKD progression by 29 percent, reduced hospitalisations by 14 percent and lowered cardiovascular-related mortality.
The Pharmacology and Therapeutics Advisory Committee (PTAC) has previously recommended empagliflozin for CKD with high priority (whether or not type 2 diabetes is the cause of CKD).
KHNZ is concerned that limiting funded access primarily to people with diabetes risks excluding a significant group of New Zealanders who could benefit from treatment that delays kidney decline, improves quality of life and reduces pressure on already overstretched renal services (In New Zealand, approximately 45% of patients on dialysis do not have diabetes as the cause of end stage renal failure. The total numbers of patients needing dialysis could be significantly reduced over time if access to empagliflozin was broadened to include non-diabetic CKD)
Currently, many people living with chronic kidney disease who may benefit from empagliflozin are unable to access the medicine because they cannot afford to self-fund it. For some patients this creates a barrier to earlier intervention that could delay progression to dialysis and other serious complications, therefore significant health inequities exist in regards to accessibility.
Reducing long-term pressure on the health system
The pressure currently facing renal services across New Zealand highlights why prevention and early intervention matter.
Demand for dialysis continues to grow, while many renal services are already operating under significant workforce and capacity pressures. A joint ANZDATA and ANZSN dialysis capacity survey released in May 2026 found that half of all renal services nationally were operating above capacity, with the Auckland renal service operating at approximately 150 percent capacity.
The 2025 “Can’t Afford Not To” report estimated that broader access to empagliflozin for people with CKD could:
- avoid more than 10,000 hospitalisations annually
- reduce dialysis demand
- reduce emergency department presentations
- improve workforce participation and productivity
- deliver an estimated $1.94 return for every dollar invested
The report also highlighted particularly strong projected benefits for Māori and Pacific communities, where the estimated return was $2.20 for every dollar invested.
As economist Shamubeel Eaqub noted at the launch of the report:
“There are still so many choices in front of us that are both cost saving and good for us. There are not many spaces where you get these unicorns.”
KHNZ believes earlier intervention in chronic kidney disease — including access to medicines that slow disease progression — is one of those opportunities.
Conclusion
KHNZ supports Pharmac’s proposal to widen access to these medicines for people with type 2 diabetes and supports efforts to improve equitable access.
However, we strongly encourage Pharmac to continue progressing broader funded access to empagliflozin for people living with chronic kidney disease, irrespective of diabetes status, where clinically appropriate.
KHNZ believes people living with chronic kidney disease should not be excluded from funded access to empagliflozin solely because they do not have diabetes and/or heart failure, where treatment is considered clinically appropriate by a renal specialist.
Ngā mihi,
Madi Keay
General Manager
Kidney Health New Zealand
REFERENCES
- ANZDATA & ANZSN SPECIAL REPORT: Haemodialysis Capacity Survey 2025
- HTAnalysts: Can't Afford Not To November 2025
- Chepulis L, Gan H, Simmons D, et al. SGLT2 inhibitor use and disparities in all-cause mortality in type 2 diabetes: insights from a multi-ethnic population. Diabetologia. 2026.
- Deloitte Access Economics. (2023). Changing the Chronic Kidney Landscape
- KHNZ + Health NZ (2023): Aotearoa New Zealand Haemodialysis Infrastructure Survey
- NZEIR (2021) Transforming Lives and Saving Money: The Impact of Early Detection in Kidney Health.
- International Society of Nephrology. (2025). WHO Global Kidney Health Resolution Adopted.
- Te Whatu Ora / Health NZ + KHNZ. (2023). Aotearoa Haemodialysis Infrastructure Survey.
- Te Whatu Ora / Health NZ. (2015). Managing Chronic Kidney Disease in Primary Care.
- Te Whatu Ora / Health NZ. (2021). Chronic Kidney Disease: Fact Sheet.
- World Health Organization. (2025). Global Kidney Health Resolution.
