The Mental Health and Wellbeing (MHW) Commission have enormous powers of enquiry, but the evidence suggests that they are simply resorting to information gathering inside the system, and downplaying their power to conduct wide ranging enquiry outside the system.
The MHW Commission was put in place to help solve a seemingly intractable problem: an under-resourced, overburdened system and increasing rates of brain-related psychiatric illness and suicidality. A system challenged by people with complex chronic conditions that remain inside the system for decades.
The MHW Commission’s primary focus concerns ensuring better and equitable mental health and wellbeing outcomes for Kiwis. What must be addressed for this to be achievable?
There’s extensive evidence that demonstrates that mental – but let’s call it brain – health is intertwined with biological, psychological, spiritual and social factors. Current treatment approaches to health are sub-optimal. They don’t address biological health and brain nutrition, and they can.
The MHW Commission just let the Physicians and Scientists for Global Responsibility New Zealand (PSGRNZ) know that nutrition for the brain is a topic they do not want to consider – for the next four years.
A familiar manoeuvre in public governance is to grant a Commission formal powers without providing the resources required for robust scientific enquiry. It is therefore possible that the Commission does not have the budget to engage expert scientists in metabolic nutrition to review the evidence base. If this is the case, it should be stating this openly and publicly.
However, I suspect that institutional framing in the first three years set the Commission’s agenda in ways that placed inquisitorial research beyond its perceived remit, and outside the hearts and minds of senior decision-makers.
PSGRNZ sent them an open letter, addressed to senior executives and the board, together with a recently released paper Reclaiming Health: Reversal, Remission and Rewiring. The paper highlights the association of poor dietary intake and inadequate nutrient status with not only psychiatric illness, but many of the symptoms that underlie diagnoses. One working day later, the front desk responded with an email advising us that:
‘The paper you have sent falls outside areas we have prioritised in our Statement of Intent it is not something we can bring our immediate attention to.’
In a quick, dismissive email, New Zealand’s MHW Commission informed PSGRNZ that the issues contained in this in-depth paper, which explicitly discussed mental health, and interventions that would support mental health, particularly for children, youth, pregnant women, and people who are treatment-resistant or suffer from psychiatric drug side effects, are not relevant to their work programme.
We asked whether the board and senior executives had received our open letter. We received no reply.
PSGRNZ understood that the MHW Commission had extensive powers of investigation. As the primary author who appreciated the drivers of the initial 2018 inquiry, the He Ara Oranga findings, and the legal function of the MHW Commission, I had believed that the MHW Commission would take the Reclaiming Health paper seriously, given that it contained new information not held by the Commission. The report contains over 600 citations to support the information, and experts, including in brain and paediatric health, have widely supported it.
The brush-off then spurred us to look deeper into policy development and framing problematisation at the MHW Commission. What we appear to be observing here is a situation of an institution focussed on the efficiency of systems where the priorities are timeliness of general practitioner, psychiatric, emergency, community and counselling services. But the services are based on speed of access, cultural appropriateness and feeling seen and heard. Biological brain health is not in the mix.
The evidence suggests that the MHW Commission has integrated the Ministry of Health approach, where brain health is exclusively a function of psychological and social factors to be addressed by counselling, behavioural shifts, medical prescribing, exercise and community connections, and to ensure that the system focuses exclusively on promoting these issues.
This is not just incorrect, but wrong. It is morally, ethically and scientifically wrong.
Nutritional interventions address inequities
The MHW Commission is directly tasked with contributing to better and equitable mental health and wellbeing outcomes for people in New Zealand. Equitable mental health outcomes for people involve symptoms receding, and people waking up every day and wanting to live healthy, loving, creative lives. All people suffer from different levels of trauma and grief; however, nutrients can have powerful effects in recovery and improving resilience. People with poorer nutritional status are less resilient.
Let’s get this straight: Health equity isn’t a person being ‘OK’, but taking multiple medications. That is medical equity. Health is political. It’s just as political to ignore nutrition as it is to discuss it. It’s just as political to fail analyse and disclose risks from psychiatric medication, the extent and degree of treatment resistance (including by dosage). Does the prescribed treatment directly improve a patient’s quality of life?
These are viewed as scientific concepts, yet they are well understood by people in the ‘system’ with lived experience. However, prevailing health agency cultures and human decision-making have demonstrably ignored the multi-system, complex benefits of optimum nutrition, while failing to fund independent research into drug risks and drug failure by age and gender. This can occur via systematic literature reviews and by regular data-gathering inside the system.
People on psychiatric medication are likely to be on medication for other illnesses. It is more normal in New Zealand to have multiple conditions (multimorbidity) than a single condition. When people are diagnosed with multiple conditions, they will most likely be prescribed multiple medications.
For years, the science on nutritional psychiatry has exploded. It makes sense, because:
‘The brain consumes 20–40% of the nutrients and energy we ingest, which is disproportionately higher than its weight’ (Rucklidge, Johnstone, Kaplan 2021).
For decades people have been told that their brain is chemically imbalanced, but the only answer seems to be psychiatric medication and counselling. Yet the brain metabolism is dependent on nutrients to function. Just as people are more likely to be deficient in a spectrum of nutrients, the evidence suggests that multinutrient formulations support mental health more effectively than treatment with a single vitamin or mineral.
The question is, what can be enacted at a policy level to improve brain health and brain function, interventions that might improve equity, act protectively and preventatively and reduce the potential for substance use, that is not currently integrated into the health system?
This is where the Mental Health and Wellbeing (MHW) Commission can step in and address Ministry of Health failure. The Commission was established in the first place to shine a light on what hadn’t been done in the past, because what was being done in the past was not working.
Reclaiming Health explains how and why many vulnerable groups would benefit from a nutritional approach to mental health and that interventions could go a very long way to improving equity for brain health and wellbeing outcomes.
This includes children, youth and young people in important developmental stages whose symptoms and challenges may reflect insufficient nutritional status; pregnant women for whom psychiatric medication may be judged too high a risk for the developing foetus; people who are treatment-resistant (for whom medications do not work); people who are likely to experience adverse effects; and people who experience adverse effects and then who are likely to be labelled ‘non-compliant’ due to the intolerable character of those side-effects.
These groups, which form a large sector of at-risk people, fall outside the presumed ‘traditional medical model’.
Children, young people and pregnant women may be the most poorly served if a system exclusively prescribes counselling and psychiatric medications. Unfortunately, independent, longitudinal, real-world, multimorbidity-sensitive safety data is not published for the latter. These therapeutic modalities cannot address nutritional deficiencies.
Reclaiming Health highlights a key and not well understood issue – our nutrition guidelines, and macronutrient recommendations (protein, fat and carbohydrate) do not concern optimum health, but relate to preventing abject deficiency. The macronutrient and micronutrient evaluations which establish the guidelines have not reviewed the relationship between nutrient intake and mental health, particularly in the vulnerable populations – which involve growing humans in key developmental stages.
New Zealand has one of the world’s most expert scientists on brain health. Professor Julia Rucklidge should be an invited advisor from an early stage, but from what we can see, her expertise is out-of-scope.
Nutrition and issues with psychiatric medication out of scope by design?
MHW Commission research and documents contain no language for multimorbidity, brain-nutrition, polypharmacy, adverse drug events, or what to do when treatments do not work. There is no language that addresses why the most vulnerable populations are most at risk.
An expert advisory group (EAG) was established in October 2020. The terms of reference for the EAG did not include any requirement to consider individual nutrition or the evidence of the extent of adverse effects and non-treatment responders, all issues that directly impact mental health and wellbeing outcomes, particularly for ‘long-termers’.
The earliest work (September 2020-March 2021) involved asking selected groups for feedback on a ‘framework for monitoring mental health services and addiction services should look like’. The three key questions that were asked, included: (1) why monitor, (2) what to monitor, and (2) how to monitor.
This work did not consider the opportunity to monitor individuals for healthy physiological outcomes (i.e. improved nutrient parameters, reduced reliance on psychiatric medication, fewer people experiencing adverse drug events, and shorter lengths of time as patients). The discussion centred around services in general.
Therefore, it’s not surprising that metrics reporting on nutrition status for brain health, adverse drug events and the extent of treatment non-responders (by age and gender) were never incorporated as decision-making variables in the summary paper or the June 2021 report. There are no experts on the board or in the senior executive team that can speak to these issues. It’s likely the Commission has never invited experts in advisory roles to flesh out these knowledge gaps.
A few months later in August, the Ministry of Health released their Kia Manawanui Aotearoa Long-term pathway to mental wellbeing report, which was followed in 2023 by an Update. The Ministry of Health understood the Mental Health and Wellbeing Commission was in the process of establishing itself, yet elected to release these two major documents, framing them as a ten-year approach ‘Implementing the Government’s response to recommendations in He Ara Oranga’.
Why would the Ministry of Health not hold off for a year or two to wait for a comprehensive plan as led by the brand-new independent Commission? The Ministry of Health papers, as the He Ara Āwhina co-define phase had just done, failed to consider optimum nutrition for brain health and the outcome of a minimum of adverse drug events, as issues that could protect health and improve health outcomes.
These early activities likely played an early, instrumental role in structuring institutional resistance to knowledge from outside the system. One where optimum nutrition for brain health, where adverse drug effects (which can plague sufferers who have been prescribed psychiatric medications) and where individuals who are not responsive to psychiatric medication (treatment resistant) are simply not considered. These issues are not seen as ‘real’ because there is no institutional focus on them.
Brain health ignored in paper after paper, infographic after infographic
It shows. The MHW Commission has launched multiple investigations, and report constantly on poor mental health. Paper after paper, for example, including the Youth Wellbeing Insights Report (2023), Assessment of progress – implementation of Kua Tīmata Te Haerenga Report (2025) and the Statement of Intent 2025-2029 demonstrate these issues simply do not ‘count’. They are not worth data gathering, not worth monitoring.
The Statement of Intent proudly outlines the quantity of reports and infographics now available:
We have published more than 17 Reports and Infographics covering broad monitoring of mental health and addiction services, the Access and Choice programme, Access to services for Youth, Kaupapa Māori services, Peer Support Workforce, the Budget19 Investment, Acute Options for mental health care and use of CCTOs. We have an online dashboard with a broad set of measures of mental health and addiction service performance updated at least annually.
We have assessed and reported on wellbeing with more than 14 reports and Infographics, including broad monitoring of wellbeing, a series of eight Covid papers, Pacific Peoples wellbeing, Rangatahi and Youth Wellbeing and access to services.
As an example, a 2024 infographic does not address the nutritional and dietary status of young people. Families with inadequate incomes struggle to supply nourishing diets. But if diet and nutrition are not ‘in the mix’ there is no policy leverage to increase investment in interventions that would directly address nutrient insufficiency, which directly impacts sleep capacity, mental health, learning, behaviour and resilience.
The wellbeing framework discusses being treated with dignity and flourishing, but access to safe and nutritious food is not discussed. A 2022 insights report into the Wellbeing of Rangatahi Māori and other Young People in Aotearoa did not appear to ask young people about the quality of their food, their nutritional status and food addiction.
At a best-guess, the MHW Commission appears to be quietly shelving nutritional status in the catch-all ‘social determinants’ rubric that encompasses the poorer outcomes of, in particular Māori and low-socioeconomic groups.
Unfortunately, the MHW Commission sadly reflects broader governance frameworks that have systematically over time, failed to address the relationship of diet and nutrition with metabolic and mental health. Even a 2024 Auditor-General’s report Meeting the mental health needs of young New Zealanders failed to refer to diet and nutrition.
Brain nutrition is an issue the the Commission can ‘bring their attention to’
Why is brain nutrition for vulnerable populations, who, especially if they fall into a low-income categories, not a topic that the MHW Commission can ‘bring their attention to’?
This is surprising. The Statement of Intent 2025-2029 established the strategic direction of the MHW Commission for the four years ending June 2029.
As I stated, PSGRNZ were promptly advised that the subject matter of the Reclaiming Health paper fell outside their prioritised work stream and was ‘not something they can bring their immediate attention to’. Yet the MHW Commission have a strategic priority, outlined in the Statement of Intent 2025-2029, that could quite easily integrate work assessing the importance of dietary and nutritional status, and highlighting adverse drug events and non-responders, particularly for ‘long-termers’ in the mental health and addiction system. Priority [2] states:
Page 20 summarises the strategy:
‘a) We contribute to addressing the determinants of inequitable mental health and wellbeing outcomes for people with lived experience.
b) Early intervention and prevention approaches are used to improve mental health and wellbeing outcomes for youth and rangatahi with lived experience.
c) People have reduced harm from alcohol and other substance use.’
People with lived experience and who are ‘in the system’, – often for decades, have not had their mental health problems solved through the prescribing of, often, multiple prescriptions at various dosing levels. Young people who are diagnosed and then prescribed psychiatric medications are often being diagnosed at much earlier stages than their parents and ancestors.
Yet the Statement of Intent reveals the current modus operandi. It does not draw on the powers of the Commission for wide-ranging enquiry outside of the current mental health system. It frames outcomes as being achieved via the monitoring of government strategies, policies and plans; monitoring government ‘action and leadership’ to address the determinants of mental health and wellbeing; publishing insights to support effective approaches to suicide prevention and reduced harm from addictive substances; and advocating for ‘promotion of wellbeing and oranga and to improve mental health and wellbeing outcomes.’
The Commission: Explicitly required to identify trends affecting outcomes
Let’s be frank – the MHW Commission have been explicitly established to deal with a difficult and challenging topic that is only growing worse. It’s growing worse because it directly involves human health and the navigation of stress and trauma in, all too often, unhappy, under-resourced, chaotic and dysfunctional environments.
The MHWC has a ‘broad remit which reaches beyond the mental health and addiction system and includes the contribution of other government agencies.’
It was the increasingly poor mental health status of Kiwis, that prompted the Government to initiate the 2018 Inquiry. The key drivers that underpinned the 2018 Inquiry included: 11.1 addressing inequalities in mental health and addiction outcomes; 11.2 underfunding of mental health and addiction services; and 11.3 stubbornly high suicide rates.
The He Ara Oranga report subsequently contained recommendations for the future Mental Health and Wellbeing Commission’s purpose, functions and powers (page 201) that explicitly included powers to investigate and report on any matter relevant to mental health and wellbeing, appoint advisory committees and seek expert advice.
These powers were drafted into the Mental Health and Wellbeing Commission Act 2020. The objective of the MHWC is set out in section 10 of the MHWC Act (2020):
In performing its functions and exercising its powers under this Act, the Commission’s objective is to contribute to better and equitable mental health and wellbeing outcomes for people in New Zealand.
Their powers are much stronger than simply being a monitoring device and number cruncher for the Ministry of Health, who ideally, should have been reviewing the data in the first place.
The whole of government seems to dropping breadcrumbs that provide the political license for the MHW Commission to courageously look at the evidence presented in Reclaiming Health. The Statement of Intent affirms the 2024-2027 Government Policy Statement targets for mental health, one of which includes a ‘strengthened focus on prevention and early intervention.’ [SOU-24-MIN-0054]
In addition, the Pae Ora (Healthy Futures) Act 2022 was amended to incorporate a Mental Health and Wellbeing Strategy obligation (s.46A). Not only were the MHWC required to structure a framework that would guide health entities for long-term improvement of mental health outcomes, they were required to assess the medium- and long-term trends that will affect mental health and wellbeing outcomes.
‘System efficiency’ is only one aspect – It’s the information inside a system that drives success
Is it that we can only be ‘scientific’ if we are discussing psychiatric medication, but it is not ‘scientific’ to address low nutrient levels, adverse drug events and treatment resistance?
When humans experience trauma, grief and chronic sickness we more rapidly utilise nutrients as our body tries to support us to get well again. When diets are poor, we reduce nutrient intake and impair digestive capacity, resulting not only in poor gut function but fewer nutrients being absorbed. When we have fewer nutrients in the body to draw upon, we tip into metabolic and mental illness faster.
Yet nutrition to optimise brain health, adverse drug events and the challenges faced by non-responders to traditionally prescribed psychiatric drugs, are not in the mix. It’s time to stop pretending that mental behaviours, habits and psychiatric medication are the only tools in the toolbox.
What the MHW Commission has not investigated nor reported on across these papers, is that the human capacity to navigate stress and trauma – and importantly to recover, is predicated on general health status. The scientific literature shows a clear pattern: poor diets, poor metabolic health, inflammation and low nutrient status are consistently associated with a wide spectrum of mental health conditions. This includes anxiety and depression, but also ADHD, schizophrenia and bipolar disorder.
Then there is the question of how well current interventions work as the MHW Commission are charged with contributing to better and more equitable health outcomes. Adverse drug reactions and treatment resistance are associated with perpetuating the suffering of people with lived experience, especially the long-termers, but no-one is talking about it.
There are strong evidence-based interventions including health coaching and food addiction counselling that can improve nutritional and health equity and address inequities arising from poor socioeconomic status and disadvantaged households. We know addictions are higher in these communities, and that food addiction to processed and ultra-refined carbohydrate compounds produces dietary habits that displace beneficial macronutrients and micronutrients. Such interventions are also supportive for people plagued by adverse drug reactions and treatment resistance.
Critically, it is children, young people and pregnant women – and their families – who must be the first in line for these policy interventions. They include high dose nutrition and counselling to support dietary shifts to whole food diets where the nutrient intakes are targeted for optimum brain health. Telling exhausted, depressed, disrupted people to simply get outside and exercise and see people more, might not work in the context of fatigue, lack of sleep, and poor gut function which are deeply associated with an enormous range of brain-related conditions.
Does the Commission appreciate how broad their powers are?
It is not good enough that these issues are outside the Commission’ remit for the next four years.
The role of nutrition in supporting mental health and supporting recovery from trauma has not yet been discussed by the Commission; where the lower risk of side effects, particularly for children, young people and pregnant women may be particularly important.
Much of what I write here is vaguely referenced in government documents and presumed to be expressly articulated somewhere, but from my research, this is not the case. Mainstream psychiatry will argue that the claims I make above remain contested. However, the data on SSRI’s remains uncertain and incomplete. Evidence in the literature is often not incorporated in Medsafe Data Sheets, and the underpinning data often remains undisclosed by the companies that fund the trials and we’re yet to comprehensively understand impact by age and gender. While psychiatric drug adverse events on medication information sheets are extensive, serious adverse events are relatively rarely reported, with gastrointestinal distress most likely to be reported (see also here, here, here). Multinutrients are most effectively consumed with food and healthy fats. This a substantial reason to give people a choice in therapeutic treatment.
If nutrition is not considered a determinant, it will not be integrated in policy. If nutrition’s role in recovery from mental illness but also from addiction is not recognised, this will not be incorporated in policy. If side-effects from medical and particularly psychiatric drugs, including combinations of drugs, are not considered and weighed against nutritional interventions, particularly in people with poor diets, how can mental health and wellbeing outcomes be advanced?
I suspect that the public may be witnessing are versions of inter-agency capture and bureaucratic drift where one public agency or institution effectively shapes, neutralises or steers the institution tasked with overseeing it. Add power differentials, resourcing and information advantage which encourage subtle dependence – evidenced in monitoring a perspective, rather than reviewing the global evidence for what works best. The framing of what could be problematised in 2020-2021 laid the groundwork for an institutional scope and framing that produced a form of path-dependency structured around monitoring the agency.
Why is the MHWC exclusively looking inside the system for answers, when even as the mental health crisis continues to escalate?
J R Bruning is a trustee of PSGRNZ and the primary author of Reclaiming Health. Information and chapter-by-chapter online access is available here, and the FAQ section can be read here.
