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Tuesday, 29 December 2009

NHS Charges - car parking consultation to follow failed telephone charges consultation last year


From: David Hickson – campaigner for the NHS

Whilst we wait for the Department of Health to properly sort out the failure and mess that followed the consultation on premium rate telephone charges last year, another issue has been put out to consultation.

Fairer NHS car parking charges – a consultation is launched today.

NHS providers are not always able to provide car parking facilities for in-patients, out-patients and visitors. Where they are, it is vital that this is done without breaching the principles of the NHS.

In looking at this issue, it is too easy to take a “consumerist” view, forgetting that the principles of the NHS make this wholly unacceptable as a starting point.

The realities of funding the NHS make it appropriate that proper use is made of land owned by NHS providers. A delicate and well refined approach is however necessary to ensure that proper financial management of assets does not conflict with the principles of treatment “free at the point of need”. It is vital that this does not descend into an argument about which patients should contribute towards the cost of providing NHS services and which should not.

Payment for NHS services by citizens can only come from taxation. Income from proper charges for car parking facilities must never be confused with this.

Noting the (still unresolved) mess that followed the consultation on premium rate telephone charges last year, where the clearly expressed wish of respondents was effectively disregarded, we must hope for a better outcome from this consultation.

Please contact me for further comment and information on either of these issues.

Wednesday, 23 December 2009

Expensive telephone numbers for calling the NHS - The Department of Health funks it

After a 3½ month consultation, a 6½ month delay, a confusing and misleading announcement on 14 September and a further 3 month delay ...

the Department of Health yesterday issued the following directions:

Directions to NHS Bodies concerning the cost of telephone calls 2009

These directions fail to protect the principles of the NHS. They explicitly permit the continuing use of revenue sharing 084 telephone numbers, which cause patients to pay (indirectly) for access to NHS services.

Patients who call these numbers are subject to a premium charge, necessarily imposed by their telephone service provider in order to recover the money paid over in revenue share.

This truth remains, notwithstanding the fact that regulation, cross subsidy and other factors sometimes lead to the perverse situation where an equivalent call to a geographic number (not subject to revenue sharing) costs more. The payment by the patient may be hidden in a package subscription, or a cheap rate, and that received by the NHS provider may be concealed within a discounted price for telephone services, but the flow of money between the two is always in effect when a “revenue sharing” number is used. All 084 numbers are “revenue sharing”.

These directions totally miss this fundamental point by inviting providers to consider whether “having regard to the arrangement as a whole persons will not pay more to make relevant calls than they would to make equivalent calls to a geographic number.

The “persons” will be subject to a wide variety of telephone tariffs.

For the principles of the NHS to be protected, a revenue sharing number could not be used unless EVERY CALLER was somehow protected from bearing the cost of the revenue share that is paid to the benefit of the NHS provider.

As may be seen from the information which follows, it is highly unlikely that any NHS provider would only be serving those who benefitted from this protection.

What are NHS Trusts being asked to do?

Having regard to the arrangement as a whole” at the very least requires them to have comprehensive knowledge of the general characteristics of the telephone tariffs to which all possible patient callers will have subscribed - I address this in the grouped table below.

A more measured consideration would require knowledge of the precise detail of the cost differentials for the respective tariffs, along with the average call durations for callers from each. This is made more ridiculous by the fact that all forthcoming changes would also need to be considered.

The whole concept is however simply wrong in principle. The idea of balancing out discounts obtained by some patients against costs incurred by others has no place in the NHS. This type of consumerist nonsense is totally unacceptable in the context of any public service.

Who pays less and who pays more?

For these purposes, callers may be broken into the following general groups:

A) BT customers outside the terms of an inclusive package (some other landline providers copy this tariff).

For this group the rates for calling 084 numbers are set at a low level by regulation. Rates for calling geographic numbers are not regulated, and are subject to a “penalty” rate to encourage subscription to inclusive call plans (this rate is steadily increasing, at 30% per annum).
The current differences are 0.25 (0844) and 3.25 (0845) pence per minute against geographic numbers.


B) BT customers within the terms of an inclusive package (some other landline providers copy this tariff).

Calls to 0845, but not 0844, numbers are treated as inclusive, i.e. at the same rate as calls to geographic numbers.
In the worst case the difference is 0 vs. 9p + 5p per minute.


C) Virginmedia customers.

Whether or not an inclusive package is in effect only affects the degree of difference. In the worst case it is zero vs. 10p plus 10p per minute.

D) Most customers using mobile telephones (PAYG or contract).

In the worst case it is zero vs. 40p per minute.

E) Subscribers to some selected mobile contracts.

F) Users of public payphones.

The determination of whether calls to a 084 number are more expensive than to a geographic number may be made for each group as follows:

Group
0845
0844
A
Cheaper
Cheaper
B
Same
more expensive
C
more expensive
more expensive
D
more expensive
more expensive
E
Same
more expensive
F
more expensive
more expensive

It is important to note that BT (Group A) is the exception. It is common to quote BT rates with the qualification that others may vary. This table shows how this approach has things the wrong way around.

Notes


1. A list of 164 of the numbers covered by these directions is found here on my NHS.Patient website.

2. The NHS Direct NHS Trust is totally excluded from this requirement.

An exemption for the 0845 4647 Health Advice and Information Line had already been announced. There is however no good reason why 0345 4647 could not be used alongside as a lightly publicised alternative for the remaining life of this service.

The Choose and Book Appointments Line 0845 608 8888, as well as other 0845 numbers used by NHS Direct (68 of them) are also excluded from these directions.

3. There is no clarification of whether NHS Foundation Trusts are covered by these directions; one might fear that they are not.

4. GPs will be covered by forthcoming amendments to their respective contracts. It is likely that these will be expressed in similar terms. It must be noted that NEG Ltd provider of the “Surgery Line” system used by perhaps 1,000 GPs in England claims that calls to its 0844 telephone numbers are no more expensive than those to geographic numbers. Its GP clients are likely to rest on this advice.

5. There is no provision for other contracted providers of NHS services, e.g. dentists, pharmacists and ophthalmologists, to be covered by similar requirements.

6. The devolved national governments are likely to follow this lead, as the same situation exists in Scotland, Wales and Northern Ireland.

I will return to this issue in conjunction with MPs, PCTs and other NHS Trusts (and with formal confirmation of the charging information from Ofcom), once all relevant personnel have returned from the Christmas and New Year Holiday.

Thursday, 10 December 2009

Rip-off NHS Telephone numbers - New statement from the Department of Health

To:       Concerned MPs and media
CC:       Department of Health enquiries
From:  David Hickson - campaigner for the NHS

Yesterday (9 December 2009) BBC South East broadcast a new statement from the Department of Health on the issue of use of revenue sharing 084 telephone numbers by NHS service providers. I quote,

The government’s position is very clear. Where there is evidence that patients are being charged more than the equivalent of a geographic call, then GPs and all NHS bodies should take all reasonable steps to rectify this. Whilst terminating their contract is an option open to them, the practice could consider altering or re-negotiating the terms of their contract, providing a call back facility for patients, or other options.

Every one of these numbers costs some patients more


The majority (in numeric terms) of telephone tariffs charge more for a call to any 084 number than to a geographic number. There are several exceptions to this rule in respect of 0845 numbers, as used by services such as NHS Direct, and just one in respect of 0844 numbers, as used by over 1000 GPs. Put simply, every patient using a mobile phone to contact the NHS on a 084 number is being charged more, as is every user of a VirginMedia landline.

BT is subject to special and unique regulation of its charges for calling 084 numbers, which therefore vary from the normal pattern.

Does the Department of Health require specific evidence of every individual case before it will take appropriately firm action to apply the principles of the NHS? NHS services must not be funded by payments made by patients as they access those services. I would be happy to become engaged in collecting the necessary evidence, if my general assertion is disputed.

Action required


The first thing that must be done is to prohibit any further 084 numbers being adopted by NHS providers. Waiting for the evidence in new individual cases and then considering alteration to a newly signed long term telephone supply contracts is not a satisfactory way to proceed.

For those already contracted for the provision of non-geographic numbers, there is a simple solution. Telephone service providers allow migration from any 084x number to the equivalent 034x number within the term of a contract. (Calls to all 03xx numbers must, by regulation, be charged at no higher rate than calls to geographic numbers, in all circumstances including through packages and for mobiles and payphones as well as landlines.)

Whilst a possible major change in the near future causes NHS Direct to retain some of its existing 0845 numbers, it would require no effort whatsoever to arrange for the equivalent 0345 numbers to operate in parallel with suitable, but modest, publicity.

The suggested “call back” option is of very limited use and is potentially unnecessarily expensive for all. It is not necessary for NHS providers to relieve callers of the normal cost of a telephone call, they must simply not use revenue sharing numbers that may cause a premium charge to be incurred. On a simple call to arrange a GP appointment, the time taken to arrange a call back is likely to be almost as great as that to complete the transaction; furthermore this would be of little help if the caller has been paying at a premium rate for a lengthy period whilst waiting to get through. The DWP has recently introduced this approach for lengthy calls that are answered swiftly, however this is only an interim step towards a proper and more cost effective resolution.

Action not being taken


We are still waiting to see the Directions to NHS bodies and proposed revisions to the GMS contract announced on 14 September. It is quite extraordinary that in all the time that this issue has been under consideration the Department of Health has failed to recognise that calls to 084 numbers do cost (at least some) patients more than a geographic call. Despite ill-considered suggestions that this will change, there is only one telephone company that has increased the cost of geographic calls to overtake that for calls to revenue sharing numbers.

As the government strives for fairness and equity in difficult times it is a disgrace that those less well off, relying on PAYG mobiles, not only incur the highest call charges, but also incur the highest additional premiums when calling NHS services using 084 numbers.

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