Our Submission on the Draft Mental Health and Wellbeing Strategy

The Women’’s Rights Party was formed in 2023 as a voice for women whose interests were being ignored by most sectors of society in the name of ‘inclusivity’. As a registered democratic political party that is advocating strongly for the interests of women and children, we are an organised force for change. The Women’’s Rights Party advocates for women’s sex-based rights, so that these rights are respected and extended, and not eroded.

We are campaigning to protect the rights of women and children.  We focus on issues that directly impact on women and girls and recognise that, in addition to women’’s sex-based rights, such interests are wide ranging, including women’’s healthcare, our children’s education, and recognition of women’’s contributions to society. We aim to bring greater public awareness to threats that include lifelong harm to children.

We are committed to ensuring New Zealand legislation reflects the commitment of our Government to the Convention on the Elimination of all forms of Discrimination Against Women (CEDAW)¹ and to the UN Convention on the Rights of the Child.²

While the primary focus of the Women’’s Rights Party is protecting the rights of women and children and advocating for sex-based rights, we are concerned with issues that affect all New Zealanders and our future generations.

The Women’’s Rights Party welcomes the opportunity to provide a submission on the draft Mental Health and Wellbeing Strategy. We support the aims and objectives of this strategy and agree that every person who needs mental health support in New Zealand deserves timely access to quality mental health and addiction support. However, we caution against the inadvertent pathologisation of life events which leads to the over diagnosis of mental health problems³. We are also concerned about the serious lapse in safeguarding for children and consider this a serious priority for action.

We have completed the questions provided in the consultation below.

We wish to be informed when the summary of submissions is available.

We consent to our submission being published on the Ministry’’s website.

1a: A lack of accessible and appropriate services – particularly primary services to enable people to stay well. Barriers to accessing support for mental health or addiction services are many and include geographical difficulties for the rural population causing inequity in access, financial pressures, unavailability of timely and appropriate services for women, and the difficult lives that women in poverty or those who live in violent situations experience. Access to addiction services is a priority for all who require this.

1b: Public health strategies and prevention are keys to avoiding more serious mental health issues. It is important to recognise that we are living in an age of overdiagnosis, self-diagnosis and diagnostic overshadowing. When people self-diagnose difficult life events as mental health issues this surely reduces the resources available for those with serious mental health diagnoses – the ones less likely to have a voice in advocating for themselves.

1c: There have been some concerns cited about public mental health awareness campaigns paradoxically contributing to a rise in mental health problems, with individuals reporting their milder forms of distress as mental health problems.3 Foulkes and Andrews present a “prevalence inflation hypothesis” as occurring via two mechanisms – improved recognition and overinterpretation. A greater awareness of problems can lead to better recognition of conditions by some individuals, but overinterpretation can lead to individuals overpathologising common psychological experiences. Diagnostic overshadowing can also be an issue. This occurs when a health professional assumes that a diagnosis of a major condition (for example Autism Spectrum Disorder) explains all other problems/symptoms experienced by the patient. This means that co-existing conditions may be overlooked and undiagnosed. There is also some work examining social media use in young people which suggests a form of social contagion can lead to self-diagnosis with mental illness.⁴

1d: Psychiatrist Dr Jon Jureidini discusses overprescribing as being symptomatic of the medicalisation of distress, and how most diagnoses of anxiety and depression are “descriptions masquerading as explanations⁵”. Life circumstances, relationships, difficult feelings, and disappointments may cause struggles in life but this does not mean there is necessarily a medical explanation. Jureidini also describes how the overprescribing of antidepressants is a symptom of our lack of attention to the social determinants of mental health: ““It’s depressing to be poor (especially when your neighbours seem rich), unemployed or in an awful workplace, inadequately housed or fearful of family violence. It’s wrong to locate the problem in the individual when it belongs to society.””

1e: Many women are forgotten in terms of their access to appropriate services. We are interested in advocating for the most vulnerable women who have effectively had their voices silenced – incarcerated women and mothers and babies in prison. There are many women with mental health issues in our prisons – many of whom have histories of sexual abuse and violence against them.

1f: It needs noting that allowing men who ‘identify’ as women to be incarcerated in women’’s prisons is a serious breach of women’’s rights. The Women’s Rights Party consider that any male criminal who is placed in a women’’s prison represents an extreme and unacceptable threat to incarcerated women. We consider that placing a male criminal offender in a women’’s prison amounts to discrimination against women which will inflict emotional pain, create a threat to physical safety, and create fear, distress, and intimidation. We consider this a breach of women’’s rights, humanity, dignity and safety. In effect – this is torture, and it is unacceptable. The United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules) stress the importance of keeping men and women in separate facilities to ensure dignity, safety and wellbeing.⁶ The United Nations Rules for the Treatment of Women Prisoners and Non-custodial Measures for Women Offenders (the Bangkok Rules), were adopted by the United Nations General Assembly on 21 December 2010⁷. The Bangkok Rules acknowledge that violence against women has specific implications for women’’s contact with the criminal justice system, as well as their right to be free of victimization while imprisoned and they state that physical and psychological safety is critical to ensuring human rights and improving outcomes for incarcerated women. The ‘Women in Prison: New Zealand’ ⁸report from the Human Rights Commission (HRC) recognised the over-representation of Maori women in prisons and noted that Corrections was “not acting with the necessary urgency to address the harms to women experienced under the current system which is not adequately equipped to address the specific needs of women in prison”.⁹

2a: Non-judgemental support. A supportive family. Upholding sex-based rights. Feeling like they are making a positive contribution to society. Access to support services when needed in a timely manner. GP services that spend time listening to patients – rather than immediately prescribing medication. Access to non-pharmacological interventions such as enhanced social support and/or psychological interventions. Monitoring and follow up of patients with serious mental health challenges.

2b: Being wary of the pathologisation of normal life events.

2c: Children in our NZ schools are being indoctrinated into misguided beliefs about sex. Teaching children that there are more than two sexes and that they could have been ‘born in the wrong body’ has already been a recipe for disaster for many children. It is time to remove activist groups, activist literature and activist displays from our schools and to implement the new RSE guidelines without any gender identity ideology. This includes in primary schools where the indoctrination starts.

2d: The evidence is clear from many systematic reviews – exposing children to this misinformation and reinforcing a belief that sex can actually change leads to unnecessary and largely irreversible damage with the use of puberty blockers and cross sex hormones. These hormones, and the surgeries that often follow, can alter hormone production permanently. In the context of mental health, we know that sex hormones are critical to mood regulation and children and young people exposed to these treatments may suffer lifelong mental health issues which going through puberty has been found to resolve for the majority of children. Some children may present in sex nonconforming ways – this is to be expected in children and it does not need to be pathologised.

2e: The most recent study that clearly shows a deterioration in mental health with these interventions comes from Finland. This study in Acta Paediatrica looked at 2,083 individuals under 23 who contacted Finland’s specialised gender identity services between 1996 and 2019¹⁰. Study findings showed serious declines in mental health. For males who received oestrogen and related treatment, the need for specialist-level psychiatric care rose from 9.8% before referral to 60.7%. For females receiving testosterone and related treatments, there was an increase from 21.6% to 54.5%. For the control group the rates were unchanged.

2f: The difference between the licensed use of puberty blockers and unlicensed use needs to be understood as this distinction is often blurred in the media and in activist language. We expect the Ministry of Health to correct this misinformation immediately when it occurs – along with other sources of misinformation propagated in the media. Licensed use is for precocious puberty where premature activation of puberty has occurred in young children. This is distinctly different to the unlicensed off-label use in children experiencing what is being termed ‘gender dysphoria’ or ‘gender distress’. In these situations, a normal critically important physiological process and its timing is being inhibited.

2g: Tegg describes the issues with puberty blockers and lack of mental health benefit. ““Puberty suppression shares features with illegitimate treatments. There is no underlying somatic pathology. There is no mental health benefit. The intervention induces a recognised disease state in a healthy body to modify it to conform to the false beliefs of the patient. Treatment rationales rest on a theory of identity that conflicts with mainstream developmental psychology, and the framework forecloses differential diagnosi”s”(Tegg, 2026).¹¹

3a: We support the aims of the strategy. We support availability and timely access to services, uncomplicated referral processes, avoidance of replication of services, culturally appropriate services, and single-sex services when necessary for dignity, privacy and safety.

4a: Aside from references to pregnant women and parents with young children, there does not appear to be a strategy to address specific mental health issues of women. The Ministry of Health Manat? Hauora’s 2023/24 New Zealand Health Survey reported higher levels of psychological distress among women compared with men in the four weeks prior to the survey, i.e. 15.52% of women (aged 15+ years) compared with 10.2% of men. The Ministry reported a statistically significant upward trend in high or very high levels of psychological distress among women since 2011/12, when 5.4% of women reported high or very high levels of psychological distress¹².  The same survey showed 12.1% of women (aged 15+ years) experienced an unmet need for mental health and addiction services in the previous 12 months (up from 9% in 2022/23), compared with 8.9% of men (up from 5.3%).  Statistical data for public hospital injury discharges show that rates of self-harm among women are double those for men and that these are rising¹³.

4b: We agree with the need to grow community-based supports and services, and enhanced models of care, to foster positive mental health and wellbeing for pregnant women and parents with young children, and to support mental health and addiction needs within the family. It is time that supporting mothering and parenting is viewed as an investment, rather than a cost. All efforts to support perinatal mental health and wellbeing are critically important not only for women, but also for infants and children. Pregnancy, childbirth and mothering are times of great significance in the lives of women.

4c: Recognition of social issues that impact mothering and parenting and how all mothers, parents and babies can have a good start that supports health and wellbeing represents an urgent discussion. Any wellbeing or health promotion strategy is unlikely to be effective where there are conditions of serious hardship and poverty, despite the best of intentions. Mothering and parenting require support, and attention to disadvantage and issues of poverty represents a good opportunity to make a positive difference for the wellbeing of mothers, parents, families and whanau.

4d: The Women’’s Rights Party strongly support a significant investment in the first 1000 days of life, which requires a dedicated focus on health and wellbeing in pregnancy, and early childhood. There is a growing body of evidence showing maternity care is a critical building block for the foundation of health. Giving every baby the very best start in life is crucial to preventative health care and to promoting health equity across the life course. The ‘First 1,000 days’ global initiative has the stated mission of making the wellbeing of women and children in the first 1,000 days a priority. We support all the key indicators described in the ‘First 1,000 days’ framework which includes social investment in infants and children, and the statement which draws attention to the need to care for pregnant women and mothers¹⁴.

4e: Socioeconomic and environmental conditions need to be addressed urgently within the development of any strategy concerned with mental health and wellbeing. The Families and Whanau Status Report 2016, highlighted how financial and psychological stressors impact on the ability of wh?nau to function well¹⁵. The stress of unsafe and unhealthy living environments and the highly likely deterioration in physical, spiritual, and psychological health places an unacceptable burden on pregnant women, women with newborn infants and young children and their whanau.

4f: Bauer et al. estimated the cost of extra provision for perinatal mental health in the UK was equivalent to about £400 per average birth¹⁶. Perinatal mental health problems were estimated as imposing costs of around £10,000 per birth for society as a whole, with costs of around £2,100 per birth falling on the public sector. Bauer et al. concluded that because “the costs of perinatal mental health problems indicate the potential benefits of intervention, even a relatively modest improvement in outcomes as a result of better services would be sufficient to justify the additional spending on value for money grounds”. Results from the Bauer et al. economic analysis suggested that investment in a comprehensive range of interventions during the perinatal period is likely to “offer good value for money.

4g: For a small number of new mothers, support services in the community are insufficient and in-patient services are necessary. There is a lack of dedicated mother and baby facilities for women with serious perinatal mental health issues. These services are unavailable in most centres. Poinso et al. (2002) describes how a residential mother-baby unit “enables a mother to obtain care for psychiatric disorders and simultaneously receive support in developing her identity as a mother. This care is meant to prevent attachment disorders and mother-baby separation¹⁷.” The Women’’s Rights Party supports initiatives that protect the mother-baby relationship and which avoid mother-baby separation unless absolutely necessary. Research does indicate that mother-baby units positively impact on maternal mental health and the mother–infant relationship¹⁸.

4h: The protection, promotion and support of breastfeeding for the up to 98% of women who initiate breastfeeding in New Zealand is a public health priority that also represents a mental health priority. Unsupported breastfeeding has the potential to worsen mental health, whereas women who are supported to establish breastfeeding and receive assistance with any challenges have benefits to their wellbeing due to the positive hormones involved in lactation and breastfeeding. Research has highlighted the importance of women’’s infant feeding intentions to the development of postnatal depression¹⁹. A British survey, the Avon Longitudinal Study of Parents and Children measured the effect of breastfeeding on women’’s mental health, and the estimated effects of breastfeeding on PND differed according to women’’s intentions.

For women who were not depressed during pregnancy the lowest risk of PND was found among women who had planned to breastfeed and who had actually breastfed their babies. The highest risk of PND was found among women who had planned to breastfeed but had not gone on to breastfeed. Longer and more flexible maternity leave could be considered protective of the mental health and wellbeing of many mothers. Reduction of stress and support to continue breastfeeding has benefits for mothers and their babies.

Many breastfeeding support groups provide significant mental health support for new mothers. Anecdotal accounts from women stating that these groups were ‘their post-natal mental health strategy’ should be considered pertinent as prevention is a significant prong of maternal mental health services.

5a: There appears to be a lack of appropriately funded support services – particularly for women who are barely mentioned in this report as noted above. Community support groups run by volunteers provide a valuable service for women, but these groups and roles need to be adequately funded. Funding is the only means by which sustainability and continuity can be achieved. Funding is needed for organisations and groups who provide single-sex services for women. There should be no coercion to include men in these groups by making funding dependent on removing women’’s sex-based rights. Women’’s refuges, rape crisis centres, breastfeeding support groups – availability of single-sex services and spaces is critically important for health and wellbeing – including mental health.

5b: The Women’’s Rights Party considers it inappropriate to set up screening services for mental health without options for referral for support and adequate, appropriate, accessible services being developed first. Screening when there are only limited, overwhelmed, poorly co-ordinated or insufficiently resourced services, or no services at all, is unethical and wrong.

6a: Remove gender identity ideology in all its forms from legislation, government policies, in our universities and schools, and in language used to describe women, particularly in women’’s health. At the same time, support the collection of accurate data that identifies the ongoing social, economic, mental health and wellbeing issues for women and girls. Collecting data that does not take into account sex has the effect of making women and girls’ needs invisible and therefore impossible to track, measure or adequately address now or in the future.

7a: Before any existing services are stopped, it would be beneficial to do a national stocktake of what services are actually available, where they are available and to whom they are available. We are aware that in some regions access to non-acute services for women is not ideal. A comprehensive understanding of service availability and accessibility would help practitioners identify the appropriate services in each region. At the same time this mapping will identify the gaps in support services.

8. We want to make sure that the things we do are making a difference for people. What should we be checking, measuring or keeping an eye on to know if the strategy is making a difference?

8a: Accurate data collection is essential. This means sex needs to always be collected as it is a fundamental demographic and explanatory variable, and a powerful predictor of almost every dimension of social life and health outcomes – including mental health.

8b: For any mental health initiatives to be effective, there needs to be cross party and cross Ministry collaboration. As identified in the consultation document – other government agencies alongside health have vital roles. We agree that prevention is the key and this requires public health to be a priority.

9a: The Women’’s Rights Party is concerned about a tsunami of young people experiencing deep regret at therapy intended to “transition” them so they can pass as members of the opposite sex. We are particularly concerned about the mental health of girls in this respect, as they appear to be highly susceptible to social contagion, judging by the sudden increase in the number of girls being prescribed puberty blockers from 2011 in New Zealand and other countries. Charlotte Paul and others used Pharmac data that showed up to 2011, the highest dispensing for first time prescriptions of puberty blockers [GnRHa] was in the 0–11 age group, and was much higher for females than males. From 2012 to 2016, and again from 2018 to 2022, there were substantial increases for females ages 0–11, such that the highest prescribing for females was in this age group. In contrast, there was only a small increase for males. The number of females and males aged 12–17 prescribed puberty blockers increased from 2012 to 2016, then, with similar numbers of males and females, rose steeply from 2014 up till 2022. Since 2022, prescribing has fallen for both genders²⁰. Academic scientist Colin Wright referred to a study by Lisa Littman, a physician and researcher, who coined the term “rapid-onset gender dysphoria” in a 2018 peer-reviewed paper to describe a newly emerging cohort of adolescents— overwhelmingly girls with no childhood history of gender dysphoria or even sex nonconformity— who suddenly began describing themselves as transgender, often after friends in their peer groups did the same. Dr. Littman proposed that this pattern was best explained by “social contagion”, meaning the spread of ideas or behaviors through peer influence. The term is a well-established sociological concept used to describe how trends such as eating disorders and even suicide clusters can spread²¹.

9b: The medicalisation of girls’ sex-related distress has irreversible effects particular to women as these girls mature, for example, in achieving pregnancy due to elevated testosterone, and breastfeeding due to breast binding and double mastectomies. In this regard we are interested in the lack of publicly available data about the impacts on children’s physical and mental health, particularly of girls, who have been subjected to puberty blockers and cross sex hormones. Is this because no data exists? No follow up has been done? Or is it because the findings did not show what the clinicians involved expected? Regardless of the reason – any data (or lack of data) should be transparently available and explained.