The lack of detail and some of the disconnection between it and planned amendments to existing health law, and other actions already taken or signalled by the government, are among the issues.
There is also the thorny question of whether it can do what it says it will.
According to Health Minister Simeon Brown, the plan, covering financial years from 2024 to 2027, outlines how Health New Zealand Te Whatu Ora will deliver on the government’s health priorities.
But former Auditor-general (AG) John Ryan, who, under existing law, must audit the costed plan before it goes to the minister, could not give it a green light.
He was unable to form an opinion on whether the plan provided a reasonable basis for delivering publicly funded health services to achieve desired improvements in health or gave reasonable effect to the Government Policy Statement on Health.
Mr Ryan said the plan did not provide a clear explanation of how the actions intended to improve aspects of the health system had been selected and prioritised, and how they would contribute to the achievement of the desired improvements and targets.
Health New Zealand said the plan was indicative of the level of maturity of the organisation and not costed to the level of traceability and integration between the financials, activities and desired improvements from a fully mature plan.

Mr Brown says removing requirements for auditing the plan pre- and post-delivery aligns HNZ with other crown entities. The organisation would still have its annual financial statements and statement of performance audited by the AG.
While we understand there might be concern such an audit before the plan becomes public may be time-consuming, it is hard not to see this removal of specific scrutiny of the plan altogether is more about avoiding criticism rather than ensuring greater transparency and accountability.
It is not the only time recently the Auditor-general’s office has been critical of health plans.
We have already written of the AG’s concerns about whether the government’s push for more planned surgery to the private sector may result in patients with complex issues, not suited for such referral, waiting longer than they otherwise might have.
As the office pointed out at the health select committee last week, faster care did not necessarily mean more equitable care.
It is still not clear how HNZ plans to ensure its plans do not exacerbate inequity, which should include looking at unmet need.
The health plan has some clangers in it which do not align with the current government position.
In the section on improving timely access to primary and community care, it says "we are resolving pay equity claims and improving nursing recruitment and retention by ensuring there is consistency in nurses’ pay".
That would have been a surprise to those in the sector who still do not have pay parity with their colleagues in HNZ and whose pay equity claims were scuppered after the government’s ambush law changes earlier this year.
Public health advocates may have been buoyed by the statement "we aim to reduce the availability and social acceptance of alcohol" in the section on modifiable risk factors, along with reference to strengthening compliance and regulatory approaches in this area.
However, recent RNZ reporting showed initial plans to reduce off-licence sale hours now appear to be off the table nationally, and there will be an emphasis on reducing red tape for alcohol retailers to make life easier for them.
Hard on the heels of the release of the health plan came another damning report about the health post-code lottery, this time for the treatment of heart disease, the biggest single cause of death in New Zealand.
It was another illustration of how much work the government has to do to convince the public it has a cohesive plan for an equitable health system.











