Friday, 15 February 2019

Breaking the pharmacy cartel

I wish that government spent even half as much time looking at how its existing regulatory structures create cartels as it did in the rest of its antitrust enforcement.

The Herald reports that a new entrant has finally started shaking things up in pharmacy, reducing costs to consumers. They get the framing entirely backwards, focusing on reduced earnings among the Chemist Warehouse's nearby competitors.

I wish they'd open an outlet in Wellington so I could have a look. Here's a dumb small example of what things are like here. I occasionally have minor heartburn. In North America, I'd buy a big bottle of Tums antacid. It'd take me a year to go through the big bottle. Now they sell them there in even bigger bottles: 330 tablets for $13.44 - $0.04 per tablet. Add on exchange rates and GST and you're still under $0.07 per tablet. The things are also great as placebo when a child is malingering. 

Here's what you can buy in New Zealand. The cheapest per-unit is a tiny little pack of Quick-Eze. They taste rubbish. And they're $0.15 per tablet. 

Every single thing in NZ pharmacies feels like a giant rip-off. My wife and son are lactose intolerant. Here's what lactase should cost: 9 cents US per tablet (9000 lactase units per tablet) - about 15 cents NZD with GST. Here's what it does cost: 76.5 cents per tablet - five times what it should cost. If you need a couple of these things to eat an ice-cream cone, New Zealand adds about 40% to the cost of an ice cream cone for the lactose intolerant - at least for those who haven't worked out ways of getting them imported. 

It would have been nice if the reporter at the Herald had compared prices at the new discount pharmacy warehouse; I'm curious. 

Anyway, why has it been so hard to get decent prices on anything pharmacy in New Zealand? The government screwed up the whole industry, forcing everyone to pay too much for everything, by putting in a rule saying that every pharmacy must be 51% owned by a pharmacist. I don't know how Chemist Warehouse has solved this problem: it's not easy to find one person, who happens to be a chemist, who has the capital to put up to build something like that. Maybe there are interesting ways around it with a clever debt structure. 

The prior National government was looking to get rid of the rule in changes to the Therapeutic Products Regulatory Regime. The pharmacists didn't like it. 

The Bill as currently drafted, and currently under consultation, seems to leave the ownership question open. Or at least I can't find any requirement in it that pharmacies be owned by pharmacists, but I can find a requirement that the responsible persons for the licence have qualifications as determined by the rules - with the rules not specified. I think that's because Minister Clark has left it open. But he does provide some discussion in December's background paper:

The pharmacists' organisation raised a pile of concerns about market concentration in the absence of the rule, but remember that the point of competition law is to improve outcomes for consumers, not to prevent concentration per se. The current model delivers terrible prices for New Zealand consumers - and especially for those consumers least able to route around the current mess by importing the products they need.  

There is absolutely no good reason to require that the person owning a pharmacy be a pharmacist. There are good reasons to require that dispensing be done by a pharmacist. 

The government is taking submissions through 18 April. If you think submitting makes any difference, here's the link.

That the criminalisation provisions in current New Zealand competition policy do not apply to regulators who create cartels continues to frustrate me. New Zealand has a lot of small-market problems that make things a bit less competitive automatically. But everywhere people think they see cartels or anticompetitive activity - dig a little to find the regulatory apparatus blocking competitors' entry.

Tuesday, 12 February 2019

Reader mailbag - supermarket zoning edition

From today's reader mailbag:
Hi Eric,

Why not make supermarkets a permitted activity in any Rural zoned area?

Then another chain could be developed with a lower cost base as they wouldn't be paying retail zoned land prices. Large supermarkets could sit on the outskirts of most cities and towns in NZ with minimal effects. Huge dairy factories and timber mills are permitted activities - why not a supermarket?

There are Aussies chains avail - only Woolworths is here. Also Aldi and Lidl - though they only need quite small sites

One tiny change to the RMA and you could knock food prices down by 25% I reckon. Westfarmers would be here in a heartbeat - they own Bunnings.

Graeme Farr
I thought Aldi was starting to look at New Zealand. But in-town zoning does seem a substantial barrier to entry. In Christchurch, Raeward ran a very nice big supermarket just outside of town by the airport.

Are there currently barriers to putting up supermarkets on rural zoned land? I expect there would be transport infrastructure needed, but there's a lot of rural land on highways. 

Graeme notes the price difference between identical products in New Zealand and Australian supermarkets. A lot of that will be differences in warehousing and transport costs between the two countries, so I'd be surprised if prices came down by quite as much as advertised. But that's not a reason not to open things up. 

Let's make a polling deal

Inland Revenue has admitted it was wrong to ask for New Zealanders' political persuasions in a survey they are carrying out for the Government on the eve of the release of a crucial tax reform report.

The taxman is researching the public's views on globalisation and fairness in the tax system. Questions had included where respondents sit on the political spectrum, prompting questions of whether taxpayers are funding sensitive political polling.
It would be bad if IRD were doing this kind of polling to help its political masters to sell whatever tax changes might be coming, but that's not the only possible interpretation.

We can also imagine scenarios where the political masters wanted changes that IRD knew to be a bad idea, that the politicians thought were popular, and that IRD wanted to be able to demonstrate were not only bad policy but also bad politics. "See? It isn't just rich pricks and right-wingers who hate this particular part of your tax package which we've also told you is a terrible implementation issue. Would you please now consider not doing this?"

I have zero inside line on this one, but it's not unimaginable.

Perhaps, as penance, IRD could just release the polling data for all of us to play with. It would be super awesome to have the full results. And then there'd be no worries about whether they were doing secret political polling for Labour - the results would be up for everyone to play with.
Around 1000 people are being asked questions about their views on Inland Revenue, whether they are generally trusting, believe what they read in the media, pay too much tax or whether public services should get more funding.

A question on where respondents sit on a left/right political spectrum threatens to skirt the department's legal obligation for political impartiality.

Polling experts said the results could give politicians valuable insight on how different demographics view the tax system
I for one would love... hmm. I'll try OIAing the full results.

Monday, 11 February 2019

Counting jobs

I really really hope that somebody in the bureaus is running proper probity over whatever Shane Jones is up to in the Provincial Growth Fund. Because every time we hear news on it, it's just a bit off. 

Here's Jason Walls in today's Herald:
Numbers published on the Ministry of Business, Innovation and Employment (MBIE)'s website show more than 10,000 jobs are expected to be created as a result of Provincial Growth Fund (PGF) announcements made last year.

Of that, 7000 – almost 70 per cent – are estimated to come from just one project: The East Bay of Plenty Regional Development Project Implementation.

This project was allocated just under $240,000 for "funding a position to manage and report on 65 key economic development projects".

That 7000 jobs estimate is based on a feasibility study provided to the Provincial Development Unit, which oversees the PGF, by the Ōpōtiki District Council.
It isn't nuts to run forecasts of expected employment from projects that haven't yet gotten started, but this kind of accounting doesn't seem right.

And this seems just a bit off as well, from the head of the Provincial Development Unit:
The day after Goldsmith said just 54 PGF jobs had been created, the Provincial Development Unit issued a press release which said "job creation does not happen overnight" and that more than 10,000 jobs may be created as a result of all the PGF investment approved to date.

Speaking to the Herald, the head of the Provincial Development Unit Robert Pigou said the statement was only released to provide "clarity" around how the PGF was structured.

He said he was not able to say how many jobs had been created because of the PGF last year, as he "did not have that detailed information yet" but said it would be higher than 54.

"We're working with the [PGF] applicants because many of them are just starting to get into that employment phase [of the projects]."

The 10,000 jobs expectation is based on the estimates of the PGF project applicants, a Provincial Development Unit spokesman said.

"When applicants outline their project, they include an estimate of the number of jobs to be created both directly through the project and indirectly, as a result of the investment."

For larger scale projects, such as the $40 million to expand the TranzAlpine service, financial modelling by an independent economic firm has been used.
I would expect Shane Jones to advertise numbers based on the job creation estimates provided by folks seeking grants from him; he is a retail politician.

I would expect a neutral and impartial public service to be a bit more sceptical about claims made in those applications and not use them to tally up big numbers to put on the Ministry's website. And that makes me a bit nervous about what the heck is going on over there more generally.

It’s always been a mistake to try and sell this stuff on short-term job creation numbers. The point of the fund, as I’d understood it, was to get infrastructure and other bits in place for longer term development in the regions. There are better and worse ways of trying to do that – a pile of loans to business that no commercial outfit would take a punt on isn’t a great idea, but getting better infrastructure in place so that regions that don’t have a strong enough economic base can have a fair go – that’s not crazy.

So I think it was silly to advertise this stuff as aiming at lots of jobs quickly.

That said, it is a bit odd to count as current benefits the estimated increase in jobs that might transpire if a bunch of other projects that haven’t yet been funded all panned out as well as expected by the folks pitching the projects. I haven’t seen the underlying studies, but if the Herald’s description is accurate – it’s an odd way to do things. It’s fine to base expected numbers on projections from studies, but we might have expected the basis to be a bit stronger than that.

I also really hope that there are sufficient checks in place in the bureaus vetting these projects and approving them, making sure that none of them would cause problems for any of our international agreements around subsidies, and making sure that there’s sufficient probity around the projects.

Thursday, 7 February 2019


Government should seek value for money in its procurement policies. Using procurement as a way of forcing or encouraging other ends is generally going to be a bad idea: You get a worse deal on what you're trying to purchase, and there are likely going to be more cost-effective ways of encouraging whatever goal you're after.

Or to put it another way, does it seem generally likely that the most cost-effective way of encouraging X is by paying more for goods and services produced by companies committing to X?

And so the cabinet paper on procurement is a bit of a worry. It's from October; I hadn't noticed it at the time. 

The paper starts off well, reminding us of the decent procurement framework we already have, and contrasting it with the messes elsewhere:
The government procurement policy framework in New Zealand consists of a combination of principles, rules and good practice guidance. It aims to support and encourage procurement practice that delivers good commercial outcomes. In contrast, some other international frameworks, such as in the European Union, have very prescriptive rules which result in procurement practices that are more compliance-driven.
...New Zealand is generally internationally perceived as having an exemplary government procurement framework and as being open, fair and transparent. In the World Bank’s Benchmarking Public Procurement 2017 report, New Zealand scored highly on the quality of its tender processes and is highlighted as having effective and efficient payment and complaints systems.
That approach is not universally loved - it's good to be hated for the right reasons:
Businesses can be, and often are, critical about government procurement. They have been most vocal about large contracts being awarded to offshore suppliers – such as the Christchurch Convention Centre contract, which was awarded to an Australian-based supplier that then engaged its own supply chain, rather than hiring local firms, to do the sub-contracting work. Some New Zealand businesses would like to see New Zealand take the Buy Australian, Hire Australian approach of some Australian states and territories.
I have no clue about the merits of various bids, but I would lean heavily against Buy NZ approaches. It would risk the rather nice outcomes we've been able to achieve:
Overall, New Zealand’s government procurement policy framework is effective. It treats businesses fairly, is open and transparent, and encourages good procurement practice. It promotes the use of simplified processes and documentation, early engagement with the supply market, and early notice of opportunities. It supports New Zealand’s exporters as tender responses are assessed on the basis of merit rather than country of origin. This enables New Zealand businesses to compete for government contracts in our trade partner countries on the same basis. I note that the Ministry will continue to work with agencies to improve procurement practices.
The Cabinet Paper starts going a bit ... off ... after that. It's making the best fist it can of a conflicting mess of coalition and agency objectives around procurement, where the different parties want to use procurement policy to push a pile of other barrows. The paper suggests four outcome priorities be bundled into procurement:

  1. "Increasing New Zealand businesses' access to government procurement" - basically, support helping non-traditional suppliers to navigate the GETS system.
  2. "Increase the size and skill level of the domestic construction sector workforce". I read this one as prioritising construction bids by firms committing to take on apprentices and the like.
  3. "Improve conditions for workers and future-proof the ability of New Zealand business to trade. Agencies would require suppliers in targeted industries to ensure their business, sub-contractors and domestic suppliers comply with employment standards and demonstrate good health and safety practice. This priority aims to protect workers from unfair and unsafe behaviour, and incentivise well-performing firms while ensuring they are not undercut by firms who have reduced costs through adopting poor labour practices." - I expect that unionised firms would wind up getting preferential treatment in contracting through this one. 
  4. "Support the transition to a net zero emissions economy and assist the Government to meet its goal of significant reduction in waste by 2020." This one makes little sense for contracting in sectors covered by the Emissions Trading Scheme. There's also mention in here of prioritising timber: "This would include consideration of the life cycle environmental benefits of timber reflecting the Think Timber policy currently being developed by the Ministry for Primary Industries." 
The first priority seems a non-crazy way of dealing with New Zealand's First's insistence on prioritising New Zealand suppliers - which would risk breaking international trade agreements from which NZ suppliers benefit when hoping for fair treatment in bidding for government contracts abroad. 

The second one could prove costly where construction projects start trying to achieve employment goals rather than just building stuff. From the document:
This priority has been agreed to by Cabinet as part of the Construction Skills Action Plan 68(DEV-18-MIN-0187). Its intent is to use Government procurement as a lever to encourage suppliers to invest in workforce development and training. Agencies will be required to give consideration and a weighting to skills development and training in the tender process of construction projects valued over $10 million. Other initiatives of the Action Plan will also support employment opportunities for targeted groups (e.g. NEETs, women, Māori, Pacific people) within those government construction projects.
The third one risks being a de facto way of skewing contracts towards union shops.

And the fourth one is guaranteed to be a more expensive way of mitigating carbon dioxide emissions than by contracting with the most efficient provider and using the savings to buy back and retire ETS credits. Some of it seems a sop to NZ First's timber interests.

But it could have been rather worse had they listened to all the stakeholders.
98. A number of agencies noted that leveraging broader outcomes is likely to add cost to contracts and complexity to procurement processes and operationalising the approach would need to minimise those costs. This has been covered in the implications discussion.

99. Several agencies have asked for additional outcomes or targeted areas to be prioritised;

99.1 The Ministry for Primary Industries proposes alignment of this proposal’s priority outcomes with the Think Timber policy currently being developed by the Ministry for Primary Industries. In response, the Think Timber proposed policy has been added to the list of potential areas for priority four.

99.2 The Treasury proposes that government suppliers be encouraged to adopt diversity and inclusion workforce policies and for those firms with boards – policies that support diversity of board members. The Ministry for Women have proposed that a gendered expectation of a minimum percentage investment across-government be included in all contracts.

99.3 Te Puni Kōkiri proposes the paper explores the possibility of preferential purchasing to support Māori firms or other demand side options within free trade rules and explain how the Government’s progressive trade agenda may lead to changes to the way New Zealand considers how procurement is dealt with in free trade agreements in the future.

99.4 The Government Communications Security Bureau and New Zealand Security Intelligence Service propose that security must be a guiding principle for government procurement decisions. In response, it is already planned that the next iteration of the Rules will have a reference to protective security requirements and protocols.
It's always particularly disappointing when Treasury is among the agencies pushing to skew policy.

Friday, 1 February 2019

Household wealth and housing wealth: first quintile oddities edition

In my column over at Newsroom this week, I noted one strange feature of New Zealand's household wealth statistics:
Unfortunately, data on wealth is far worse than data on income – the Government gathers a lot less data on wealth. For example, Statistics New Zealand reports that people in the least wealthy 20 percent have $1.75 in property debt for every $1 in property assets – but no bank in the country would extend a loan on that basis. It is more likely that the survey data misses some houses owned through family trusts where, for example, a 25-year-old takes over the mortgage and effective ownership of their parents’ second home held in the family trust. The mortgage payments and mortgage debt are noted in Household Economic Survey data, but the ownership may be missed. This means their parents’ net wealth will be overstated, their own net wealth will be understated, and measured wealth inequality among younger cohorts would be somewhat understated but overall measured wealth inequality would be somewhat overstated. 
There's an ungated version of the column here.

The effect wouldn't be large because there aren't many households in that situation. But it's odd. So I asked Statistics New Zealand what's up with that, wondering whether the trusts explanation might be what's going on. I'd also asked whether Stats were able to ask follow-up questions of their HES respondents to see what's going on.

Stats' Statistical Analyst Michelle Griffin helps me out:
We’ve had a look at the distribution of owner-occupied property assets and owner-occupied mortgages for those in net worth quintile one. There are about 30 more households (unweighted) with mortgages than homes, and because of this difference, you need to go further along the mortgage distribution to get to the median, resulting in a larger mortgage median and hence a larger debt to asset ratio. So it’s looking like the high ratio is due to a mix of under-reporting and distribution differences.

We’ve had a look at only those with both a home and a mortgage to see what they look like (this is excluding those with a home in a business or trust), and this brings the ratio down to $1.44. This drops even further when you take the median of each household’s individual debt to asset ratio (to $1.26).

We’ve had a quick look at the households with only a mortgage to try and see what might be happening. They appear to be a mix of households with the home in a trust or business which is assigned to someone else (which could be a situation like you’ve described below), and households which say the home is in a trust or business but then don’t mention this trust/business later on (could be partly due to misreporting or respondent burden leading to households not answering fully). I think the fact that there are so few households in net worth quintile one with owner-occupied property is making this quintile more sensitive to these issues. Unfortunately, we can’t follow up with the respondents later on to confirm these situations – although it would certainly be interesting!
So restricting things to those households in the first quintile fixes some of the problem, but we're still at a debt-to-equity ratio on housing debt well out of step with sane banking practice, let alone existing LVR rules. And while there aren't many households with mortgages without homes, it's hard to tell whether debt to asset ratios for a broader set of respondents elsewhere mightn't be wrong too. 

Michelle suggests that keeners might apply for microdata access to really drill down into what's going on. It would be a great Honours thesis for somebody wanting to get microdata experience who has a qualified supervisor.

Many thanks to Michelle and to Statistics NZ for the helpful and detailed response.

Update: An informed reader writes:
A couple of thoughts about the data on wealth:
  • There is a wider problem with data for people at the top and bottom of the distribution. Surverys include lots of trade offs between clarity, comprehensiveness and accuracy. For instance survey data on the benefit population substntially under-reports income from second and third tier payments (that is all loans, one off payments, disability allowance and accommodation supplement). Since this is a relatively small part of the population, SNZ makes the reasonable decision not to overcomplicate their survey to deal with the problem, but the consequence is continuous understatement of income for many people. The same applies at teh top where it is hard for surveys to capture the many different assets people with many assets have.

  • More technically there is problem using a small number of  discrete categories like quintiles to describe a continuous variable. The general point is that if someone makes a mistake they have have to go somewhere in the discrete categories, so effectively there is a cut off at the top and bottom that will skew the results. It's easy to think of this through an intuition. If a person's income is roughly in the middle, say $50 000, and they miss a zero then they drop to the bottom of the distribution ($5000) while if they add a zero by accident ($500 000) they go to the top of the distribution. However a person whose income really was $5000 who makes a mistake either stays in the same place or goes up (ie income is $500 or $50 000); while a person with income at $500000 either goes down, or stay at the top. Even if we assume the liklihood of a person making an error and its direction are independent of income, the measured income will be pushed to the extreme quintiles. "On average" it may be right, but it will overstate the dispersion. My guess is this will be even more pronounced with wealth because it is so much harder to measure and thus more likely to generate error-prone answers.

  • Finally, they are using snapshots for variables that change over time. I know this is a problem with flows like income and employment, but I sometimes wonder what it means for wealth. In particular, there is an issue with measuring transitions. The following example is made up, but gives a clue what might be happening. Say some % of people selling a house to buy another spent a couple of weeks where they had two mortgages while the paper work was settled. For the individuals the cost might be a few hundred dollars - which is not a lot when you get real estate agents involved! - but two weeks is approx 4% of the year so you would expect your snapshot survey to include some small % of people with double the mortgage debt relative to their asset. It is not many people, but it does not need to be because they will be a small percentage of the population but they will concentrated in decile/quintile. 
To me the deeper problem is that surveys tend to be designed to be "on average right", whereas the data is often used to make distributional statements. And Bryan Perry’s incomes report notes the problems with the extreme tails of the distribution.

Thursday, 31 January 2019

Fun studies for someone else to do: contraceptive access

"While current dispensing restrictions limit how often a person can collect their Levlen ED prescription, this should not stop patients from accessing their medicine or taking it as directed.

"We thank pharmacies and wholesalers for their assistance in helping to manage this stock issue and apologise for any inconvenience," Fitt explained.

Concerns about the availability of Levlen in New Zealand were raised earlier this month.

Recently, pharmacies had been asked to dispense the pill in one-month courses, rather than the three-month courses usually given out.

But on Friday that request will become mandatory as officials step up efforts to maintain sufficient supply until the medication was restocked in late March.
So a fun Masters thesis for somebody: use regional variation in the timing here to check the extent to which the fixed costs of going to the dispensary affects both the likelihood of scripts being filled and unplanned pregnancies. Prescriptions like this should be in Pharmac data accessible in IDI.

I'm not sure what you could do with this second natural experiment though, noted in the same story:
In April, medical professionals were asked to ration prescriptions of Durex condoms for men with large penises, as increased demand contributed to a global shortage.

Durex Confidence 56mm condoms and Gold Knight Larger were the Pharmac-funded brands affected by dwindling supply.

At the time, Pharmac said the Durex condoms would be temporarily unavailable in New Zealand, but the brand's five other varieties in differing sizes were available.

In July, a disagreement between the brand's owner and its Indian partner cut up to 60 per cent of supply.
Of course, condoms remain accessible (at a somewhat higher cost) at the supermarket; it's just the subsidised ones that are short. No non-prescription options for birth control pills.

The Stuff comments thread is more amusing than most.