15 February 2021: OIA response | Lamotrigine meetings records and communications

15 February 2021 

Dear [name and contact details withheld] 

REQUEST FOR INFORMATION 

Thank you for your request dated 11 January 2021 under the Official Information Act 1982 (OIA) for information relating to lamotrigine. You asked for:

  • All recorded minutes from each of the fortnightly Lamotrigine project team meetings held throughout the calendar year of 2020;
  • All recorded minutes from the Medicines Adverse Reactions Committee which mention the terms 'lamotrigine', 'Logem', and relate to the epilepsy funded brand switch for the calendar year of 2020;
  • Copies of all internal Pharmac correspondence which mentions the terms lamotrigine, Logem, or the epilepsy funded brand switch between January 1, 2019 and December 31, 2020;
  • Copies of all external media correspondence Pharmac received and responded to - including the internal chains of communication related to each such request - which mentions the terms lamotrigine, Logem or the epilepsy funded brand switch. 

Your request has been considered under the OIA and part of the information you have requested is included with this response (below and/or attached).

Please note that PHARMAC approaches its assessment of requests for information under the OIA on the basis that, once released, the information becomes publicly available - in other words once we release the information to you it becomes available to any other party in that exact form (whether by you distributing it to others or by virtue of us receiving the same request from a different third party).

We have redacted a small amount of information from the information released as we consider this is necessary to:

  • protect the privacy of natural persons (section 9(2)(a))
  • maintain the effective conduct of public affairs through the free and frank expression of opinions by or between officers and employees of PHARMAC in the course of their duty (section 9(2)(g)(i)), and
  • maintain legal professional privilege (section 9(2)(h)).

As required by the OIA, we considered whether, in the circumstances, the withholding of this information was outweighed by other considerations which render it desirable, in the public interest, to make this information available. In this case we did not consider that the public interest outweighed the reasons for withholding the information.

Minutes from the Lamotrigine Implementation Project Team meetings for the calendar year of 2020

Please find a copy of the minutes from each of the fortnightly Lamotrigine Implementation Project Team meetings held throughout the calendar year of 2020 attached with this response (Appendix 1).

Minutes from the Medicines Adverse Reactions Committee for the calendar year of 2020

As noted in our email to you on 11 January 2021, minutes from the Medicines Adverse Reactions Committee (MARC) can be found on the Medsafe website:

www.medsafe.govt.nz > Committees > Medicines Adverse Reactions Committee > Minutes(external link)

Internal correspondence between 1 January 2019 and 31 December 2020

Per our emails to you on 14 and 19 January 2021, we attempted to refine the scope of this request in order to assist us to provide relevant information for your request. We also provided references to previous OIA responses published by PHARMAC with regards to the lamotrigine brand change. 

Your response, received 27 January 2021, advised you would like copies of all internal emails, reports, memos and advice which mention the terms lamotrigine, Logem, or the epilepsy funded brand switch. 

Some information relevant to your request is already publicly available; PHARMAC provided a memo to the Neurological and Mental Health Subcommittees of the Pharmacology and Therapeutics Advisory Committee (PTAC) in January 2019. A copy of this memo, as previously released under OIA, is available from page 21-44 of the document released on 1 October 2019 in response to an OIA request regarding lamotrigine safety [PDF, 4.1 MB]. PHARMAC also provided a memo to the PHARMAC Board for the meeting held in March 2019. The PHARMAC Board memo is also included from page 95-120 of the above document. 

Record of the Neurological and Mental Health Joint Subcommittee meeting held 7 February 2019 regarding lamotrigine can be found on our website:

www.pharmac.govt.nz > About > How we get expert advice > PTAC Subcommittees > Mental Health Subcommittee or Neurological Subcommittee.

Record of the PHARMAC Board meeting held in March 2019 [PDF, 212 KB] can be found on our website: 

www.pharmac.govt.nz > About > Who we are > Our Board.

Following a search of our records, we found 22,000+ items that included the keywords noted in your request for correspondence between 1 January 2019 to 31 December 2020. Due to the large volume of data that is applicable to this request, we advise that we have decided to refuse your request for copies of all internal emails, reports, memos and advice which mention the terms specified on the grounds that the information requested cannot be made available without substantial research or collation (section 18(f) of the OIA).

As required by the OIA, we have considered whether fixing a charge or extending the time limit of the request would assist us to research and collate the information requested however, given the large volume of information identified, we do not consider that this would assist us to fulfill your request.

We invite you to resubmit your request with a refined scope for consideration and also refer you to review content previously released in response to OIA requests related to the lamotrigine funded brand change

Previously published lamotrigine OIA responses:

External media correspondence and internal chains of communication related to each request

Please note that we need additional time for consultations necessary to make a decision for the release of information for this request. We advise that we have decided to extend the time limit for this decision by a further 15 working days. You should receive a response from us for this request no later than 8 March 2021. 

Please note you have the right, by way of complaint under section 28(3) of the OIA to an Ombudsman, to seek an investigation and review of our decision. 

We trust that this information answers your queries. We are making our information more freely available, so we will now publish selected OIA responses (excluding personal details) on our website. Please get in touch with us if you have any questions about this. 

Yours sincerely 

Rachel Read

Manager, Policy and Government Services