Public service providers must immediately cease using "BUSINESS RATE" telephone numbers

Ofcom announcement

Ofcom has published a consultation on proposals for the future regulation of non-geographic telephone numbers - Simplifying Non-Geographic Numbers.

The published information includes a comprehensive analysis of the current costs of calling 0845 and 0844 numbers. 1 This clearly demonstrates that the cost of calling these numbers (now designated "Business Rate") is greater than that of calling "Geographic Rate" numbers for most callers.

Legacy regulation has caused BT landline customers to benefit from a discount when calling these numbers. Ofcom proposes that this special treatment, which does not apply to users of other landlines, mobiles or payphones, be ended.

NHS Regulations

Any NHS body or GP seeking to pretend that their 0844 or 0845 number is not more expensive to call is now seen to be engaged in a deliberate or misguided deceit. Because the NHS is a universal service, such determinations cannot be made using the limited assumption that all patients are BT customers who do not have a call plan in place when calling.

Directions to NHS bodies give them until Tuesday 21 December 2010 to review this matter and make alternative arrangements. In some cases, it may be too late to do the latter, but there can be no excuse for not now declaring an intention to remedy the situation as soon as possible.

Revisions to their NHS contract give GPs until 31 March 2011 to do the same. It must be noted that telephone service providers allow the option to migrate to 03 ("Geographic rate") numbers within the term of their contracts. Associated telephone systems are supported equally by 03 and 084 numbers, so there is no requirement to consider use of a particular system when selecting the type of telephone number, 03 ("Geographic rate") or 084 ("Business rate"), to use.

Bundled tariff

The Ofcom document explains that the present cost of calling 0845 and 0844 numbers (along with many others) includes two "bundled" elements:

1.	The "service charge" - to the benefit of the Service Provider (the user of the number).
2.	The "access charge" - retained by the telephone company originating the call.

Ofcom proposes that these costs be unbundled

Under Ofcom's proposals, NHS Direct, HMRC and DWP agencies would be required to present the cost of calling their 0845 numbers as follows:

"Calls to (0845 4647 / 0845 3000 627 / 0845 604 3719) 2 cost 2p per minute plus your phone company’s access charge".

For 0844 numbers, as used by many GPs, the presentation would be:

"Calls to the surgery on 0844 4771799 3 cost 5p per minute plus your phone company's access charge."

These statements would simply represent the truth as it exists today, notwithstanding the fact that the phone company access charge element is currently totally opaque, highly variable and unrelated to the cost of calling an ordinary (geographic rate) number. The "service charge" element exists today - the Ofcom proposals are simply for it to be made transparent, by regulation.

NHS and other public service providers that may not levy a "service charge" for telephone contact must immediately desist from use of what are now designated as "Business Rate" numbers. Citizens do not engage with NHS providers, HMRC or the DWP agencies on commercial terms.

It is for businesses to determine whether or not they are content for it to be seen that they are levying a charge for access to certain services provided by telephone. Taxpayer-funded service providers cannot be seen to be levying a second charge, on service users.

Geographic rate numbers

Ofcom confirms that only 01, 02 and 03 numbers may be considered to be charged at "Geographic rate". The historic link which once applied to 0845 numbers, BUT ONLY EVER FOR BT LANDLINE CUSTOMERS, will be finally broken.

Only those Service Providers who serve only BT landline customers can claim a link between 0845 calls and geographic rates, until such time as the changes proposed by Ofcom are implemented.

Those who require non-geographic numbers, but cannot present them as being proper to be charged at "Business Rate" or "Premium Rate", must adopt "Geographic rate" 03 numbers.

For ease of migration, the 0344 and 0345 equivalent number for each 0844 and 0845 numbers is reserved. Such migration is permitted by telephone companies within the term of an existing contract for telephone service.

Where considerable cost may be involved in fully changing a number, a sensible pragmatic approach is to offer 0344 or 0345 alternatives as a standard, possibly covering many numbers, operating in parallel with the 0844 or 0845 equivalents and advised as such, as a general principle.

I see the option of parallel operation (0845 / 0345) as particularly suitable for NHS Direct, where the cost of a complete number change would be highly inappropriate as 0845 4647/0345 4647 has only a limited remaining life.

Parallel operation would also be most appropriate for the many 0845 numbers used by HMRC and all DWP agencies. Major number changes are planned for the future and tight budgets make it most suitable to simply issue a general advice that any 0845 number may be replaced with the 0345 equivalent.

To provide full information, HMRC and DWP could make the following statement at present:

"All 'Business rate' 0845 numbers are subject to a service charge of 2p per minute. This is in addition to the access charge levied by your telephone company, which may also include a call connection fee. Current access charges are known to vary from -2p per minute to +38p per minute." 4

If adopting my recommended approach, the following could be added:

"To contact us at 'Geographic rate', call our 0345 alternative numbers. Simply replace the 0845 with 0345 and dial the remainder of the number as quoted."

Circulation of these comments

These comments are published in my blogs 5, and as a general media release. They are circulated to relevant personnel in the NHS 6, HMRC and DWP, to MPs and to others concerned with the issues of fairness and propriety that are brought most clearly into focus by the Ofcom announcements.

I also include members of the "Non-Geographic Numbers Review Team" at Ofcom (NGCSReview@ofcom.org.uk) who will, I am sure, be happy to confirm the points I make here.

I will be pleased to assist with any further information and comment.

David Hickson

---

Notes

1.	See http://stakeholders.ofcom.org.uk/binaries/consultations/nongeo/summary/non-geo.pdf  - Tables A2.4 & A2.5 (p140) vs. A2.7 & A2.8 (p147).
2.	The numbers quoted are as follows:
	0845 4647 - NHS Direct - telephone health advice and information service
	0845 3000 627 - HM Revenue and Customs - for enquiries about tax over/under -payments
	0845 604 3719 - JobCentre Plus - to contact any Jobcentre
3.	The number quoted is that used make an appointment with NHS practising GP - Dr Richard Vautrey - Deputy Chairman of the BMA General Practitioners Committee.
	Dr Vautrey is a strong public advocate of the use of "Business Rate" numbers for provision of NHS services. We exchanged views on this issue on the Radio 4 Today programme 2 years ago.
	The BMA GPC also advocates a service charge for telephone calls to some NHS providers and encourages exploitation of the "Confusion about the price" which the Ofcom proposals seek to address (see GPC GUIDANCE: USE OF 084 NUMBERS IN THE NHS).
4.	The maximum charge for calling a 0845 number is given by Ofcom as 40p per minute, as at August 2010. Prices will be reviewed to reflect the increase in VAT to apply from 5 January 2011.
5.	NHS.Patient blog, Public Services Campaigner blog, Media Releases blog.
6.	My NHS.Patient website includes lists of NHS service providers using Business Rate numbers - NHS Bodies and GPs.