Published on 4 Mar 2026

Navigating 16,000 submissions on complex health reform - Therapeutics Products Bill

Sean Stack Senior Consultant Contact me
Stuart Beresford Senior Consultant Contact me

The Ministry of Health needed a trusted partner to make sense of 16,586 public submissions on landmark health reform through the Therapeutics Product Bill. The Therapeutics Products Bill was technically complex, and politically sensitive as it touched on a range of important issues including Māori health sovereignty, consumer rights and industry viability. 

Allen + Clarke were engaged to provide the support the Ministry needed to prepare the Departmental Report, a crucial part of the Select Committee process. We triaged, coded and analysed nearly 6,000 substantive submissions.  We delivered a comprehensive report the Ministry could use as it mirrored the Bill's 11 part structure providing clear linkages between feedback and insights. Three senior team members were subsequently retained in-house at the Ministry to support further work, reflecting the confidence placed in our work.

 

Allen + Clarke delivered the full analysis within the Ministry's parliamentary deadline despite having to triage and analyse over 16,000 submissions. The clause-by-clause structure and recommendations tables let the Ministry use our report directly, reducing duplication and supporting a smooth legislative process.

Landmark health reform need a trusted analytical partner

Manatū Hauora - the Ministry of Health needed an expert partner to support analysis over submissions and preparation of the Departmental Report for the Therapeutics Products Bill. The Bill proposed replacing decades old legislation with a comprehensive framework that would cover medicines, medical devices, products with active pharmaceutical ingredients and natural health products, including rongoā (traditional Māori medicine). 

During 11 weeks of consultation the Health Select Committee received 16,586 submissions on the Bill which was large, complex and politically sensitive. A tight parliamentary deadline meant that submissions needed to be analysed quickly, but also comprehensively to reflect feedback on the technical subject and the 11 part legislation. Submissions on rongoā and Te Tiriti o Waitangi analysis also required culturally informed expertise. 

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Our three-phase methodology delivered technical rigour

To analyse the submissions our team used NVivo, a specialised software tool for organising and analysing large volumes of qualitative data. Our team needed deep proficiency with NVivo as well as the cultural competency to handle submissions on Māori health sovereignty with accuracy and respect and a strong understanding of the current sector context. 

Strong project management was also equally important. We needed to be flexible to refine the coding framework iteratively as new themes emerged but without disrupting or having to redo work that had already been completed. 


  • We co-designed a coding framework with the Ministry that reflected both the structure of the Bill (including clause by clause analysis) and key areas of focus for the Ministry. We then tested and refined the framework on a sample of submissions. 

  • We triaged and classified all submissions as substantive, support or opposition only or form submissions. This enabled us to give an early indication of sentiment for the Bill and identify 5,969 substantive submissions for further analysis. These substantive submissions were uploaded to NVivo, coded against the agreed framework, with quality checks throughout to ensure accuracy and consistency. 

  • In the final phase we produced a 230-page report structured across all 11 parts of the Bill, with recommendation tables for each part. This was written to serve directly as a working document for the Ministry's Departmental Report. 

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We provided a complete, trustworthy picture of the public feedback

Allen + Clarke delivered the complete analysis within the Ministry's parliamentary deadline. Our processes meant that the Ministry could be confident the submissions had been triaged and analysed appropriately and that the report was representative of submitters views. 


  • All 16,586 submissions were triaged and classified, with 5,969 coded in full, ensuring no perspectives were overlooked. 

  • Over 880 submissions touching on rongoā and Te Tiriti o Waitangi were analysed through a culturally informed lens, so the full weight of what submitters said on these issues was accurately captured and represented. 

  • Three senior Allen + Clarke team members were retained in-house at the Ministry post-delivery to support its Departmental Report - a clear measure of confidence in our work. 

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