The case is made for HMRC and DWP to migrate from their 0845 telephone numbers to 03 NOW

HMRC and DWP agencies have decided to continue charging for enquiry calls on their "Business Rate" 0845 telephone numbers, rather than migrating to "Geographic Rate" 03 numbers. This decision is apparently supported by a determination that despite the premium charge, allegedly “callers pay less to call 0845 numbers than 03”! Such a perverse determination sadly requires some effort to challenge.

I have some important points to make, on issues of principle and matters of detail. I also touch on the NHS in passing.

Introduction and Summary

I understand it to be accepted that a 1.7p per minute subsidy is derived from receiving calls on 0845 numbers, and that this cost is passed on to callers by their telephone company, which has to pay it. If anyone does not accept this fundamental point, then I must ask that they please make contact with me, or Ofcom, most urgently.

When 0845 numbers are used by taxpayer-funded bodies, part of the cost of providing the service is being passed from the taxpayer to the service user.

For the NHS, this represents a breach of the terms of the NHS Constitution, which demands explicit parliamentary sanction for all NHS charges. Parliament does not sanction any charge for NHS services that is levied at the discretion of the NHS service provider, or can be thought to have a variable impact dependant on the patient's choice of telephone service provider.

The Department of Health has failed to enforce the terms of the Directions to NHS bodies and revisions to the GP contract, which should have had the effect of removing all 084 numbers from the NHS by now (0844 numbers yield a subsidy of around 5p per minute). The DH even repeats the total fiction that there are some 084 numbers that are not expensive to call than geographic numbers and fails to recognise that users of 084 numbers may migrate to the equivalent 034 number during the term of their contract for telephone service. Serious action on this failure will have to follow. (As I continue, focussed on HMRC and DWP, my mind is also on NHS Direct, certain PCTs and hospitals and many NHS GPs.)

The "constitutional" constraint on the NHS is however not matched by any equivalent restriction on the commercial activities of HMRC or the DWP agencies; they are free to levy charges for their services as they may choose. I understand that both intend to continue to do so through their use of 0845 numbers. (Asking about PAYE errors, pensions, benefits and jobseeking is not " free at the point of need".)

I trust that many to whom this briefing is circulated will stop reading here, regarding the practice of charging fees for telephone enquiries by benefit claimants and victims of HMRC errors to be wholly improper. Parallel adoption of the equivalent 0345 numbers as alternatives, is the first easy step that could be taken to address this issue.

I urge those who share my views to make their point loudly and clearly, as I move on to address some of the confusion that is brought out by those who wish to obfuscate this issue.

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Those interested to learn more about the issue may wish to understand the detail and the ways in which the impact of this cost to service users may be assessed. I have attached, and published, a detailed spreadsheet which not only demonstrates that there is no sound basis for any determination that 0845 calls are "cheaper overall" than "Geographic Rate" 01/02/03 numbers, but provides those who wish to attempt to substantiate such claims with a basis for demonstrating how they reach their conclusion.

Background

The 03 range enables those who find a worthwhile use for the additional technical facilities and locational anonymity provided by non-geographic telephone numbers to do so without imposing a charge on callers. Other non-geographic ranges provide these same benefits, but with the associated costs paid for (in part, in full or in excess) by callers.

The option to migrate (in full or to parallel operation), from any 0845 number to the equivalent 0345 number, offers a ready means for those who wish to avoid the expense and confusion of a full scale number change. I have long been proposing the minimal step of simply offering the 0345 equivalent number as an alternative to every published 0845 number. This facility could be advised through a general statement, without the expense of re-publishing literature etc.

The extra cost/benefit associated with calls to 0845 numbers (2p per minute including VAT) is now known by Ofcom as a "Service Charge". It is paid by callers in addition to an "Access Charge", which is added by the caller's telephone company. Under the present regulatory regime, the Access Charge is not clearly identified as such, as it is bundled in with the Service Charge to give a consolidated rate for the call.

This should therefore be a simple issue of a "premium"; however it is complicated due to certain historic factors. Those who may wish to conceal the fact that their callers are paying them a Service Charge would naturally wish to exploit these complications to obfuscate the issue.

BT

BT is the leading provider of telephone calls, being responsible for originating around 25% of all non-business calls made in the UK. Currently BT is prohibited by regulation from adding any Access Charge on calls to 0845 numbers, so callers through BT only pay the "Service Charge" when calling 0845, and some other non-geographic numbers. All telephone companies are required to charge for calls to 03 numbers on the same basis as calls to other "Geographic Rate" (01/02) numbers. BT is not regulated in its charges for calls to Geographic Rate numbers.

Since January 2009, BT has taken payment of the Service Charge for calls to 0845 numbers as part of its "Call Plan" subscriptions, making no further charge when calls to 0845 numbers are made under the terms of the Call Plan.

The major complication arises when BT customers make calls outside the terms of the Call Plan which they have selected. An un-regulated and severe “penalty charge” is imposed for calls to 01/02/03 numbers, however BT is only able to recover the lower "Service Charge" on 0845 calls. (I repeat this same point later.)

Call Cost declarations

Because BT is the largest single provider of telephone call services, it is common for its rates to be quoted as if they were some sort of norm, from which others vary. This practice totally misses the point that BT is in fact unlike all other providers, being compelled to charge unusually low rates when originating calls to 0845 numbers.

The fact that all telephone service providers now base their contracts on packages including calls to Geographic Rate numbers, makes quoting rates for such calls largely meaningless. The intention is that these calls are made without a specific call charge, which is why penalty rates are applied when calls are made outside the terms of the package. Even some PAYG top-up deals provide a package of calls, contrary to the principle of PAYG.

Because of the need to not only cover costs and make a margin but also to pay on a Service Charge, most telephone companies exclude calls to 0845 (and other 084, 087 etc.) numbers from their packages. BT is in a wholly unusual position in that it can afford to include 0845 calls in packages without pushing the price for the package unreasonably high, because it cannot include any charge of its own.

Using the highly unusual case of BT when giving an example of call costs can be very misleading. IF BT rates are the only example given then it may appear that an attempt is being made to conceal the impact of the "Service Charge" on callers in general. Referring to those who apply an Access Charge as well as the Service Charge as being the ones who "vary", is to misstate the situation; it is BT that is the odd case.

Current Ofcom proposals for clarification

To deal with the fact that many users of 084 and other non-geographic numbers seek to conceal the benefit that they derive, Ofcom is currently consulting on proposals for them to be made subject to regulatory requirements to be transparent. (I hope that public bodies such as HMRC and DWP would not wish to be seen to be waiting to be compelled to do so by regulation before they are transparent about their Service Charges.)

To achieve this through its regulatory powers, Ofcom would have to classify them as providers of "Premium Rate Services". This would require them to subscribe to Phonepay Plus and adhere to the conditions it sets as the self-regulator of the "phone-paid services" industry. (I am not sure if it is distressing or amusing to think of JobCentre Plus as being in the same industry as providers of telephone chat-lines.)

Ofcom suggests that in place of references to the uniquely regulated rates charged by BT, a statement in the following form be used to describe the cost of calling 0845 numbers:

"Calls to our 0845 numbers cost 2p per minute, plus an additional charge added by your telephone company".

Ofcom also proposes that the present regulation on BT be replaced by regulation to cover all telephone companies, requiring them to adopt a simple structure of Access Charges which are clearly declared as such and to show the Access Charge and Service Charge as separate items on the telephone bill.

Whatever may emerge from Ofcom in future:

there is no good reason why such a statement could not be used today.

If reference were to be made to particular charges from particular widely used telephone companies, then information about the absence of an Access Charge from current BT tariffs should perhaps be accompanied by a reference to the fact that T-Mobile currently charges contract customers 41p per minute for calls to 0845 numbers.

The effect of "the BT anomaly"

One would naturally expect that with a 2p per minute additional cost to the call originator, all calls to 0845 numbers would be more expensive than equivalent calls to 03 numbers. The Ofcom proposals will undoubtedly have that effect, if and when they are adopted, as they will release BT to compete alongside other providers with Access Charges and Service Charges unbundled.

In the meantime there remains this historical anomaly dating from the time when BT was the monopoly provider of all telephone services; before widespread use of mobile phones, competition in the landline call market and inclusive packages as the primary basis for charging for ordinary calls.

To encourage use of advanced telephone features, BT was compelled to charge for calls to 0845 numbers at what was then the "local rate" - the distinction between "local" rate and "national" rate disappeared for charging purposes in 2004. Regulation of BTs charges for calls to "ordinary" numbers has been lifted, whereas that covering 0845 (and other non-geographic ranges) remains in place, in the form of a prohibition on BT making any money from originating these calls. No other provider is regulated in this way.

Back up to date

(Please forgive some repetition of points made previously.)

Most telephone companies now bundle calls to "Geographic Rate" (01/02/03) numbers into inclusive packages - the BT term is "Call Plans". For those who do not use their landline during weekday daytimes, there are cheaper Call Plans available (covering Weekends and optionally Evenings). If calling a "Geographic Rate" number outside the period covered by the Call Plan which the subscriber selects, a "penalty charge" is imposed. Those who use their BT landline for anything but the most occasional of calls during weekday daytimes (now up to 7.00 pm) are best advised to subscribe to the "Anytime" Call Plan.

The current BT penalty charge for weekday daytime calls to "Geographic Rate" (01/02/03) numbers, when not covered by their Call Plan, is a call setup fee of 11.5p plus 7p per minute. This is obviously greater than the 0845 service charge of 2p per minute which is all that BT may charge for such calls. (This was recently adjusted to 2.042p per minute to reflect the increase in the VAT rate.)

From April this BT penalty rate will increase to 7.5p per minute and the call setup fee to 12.5p; at the same time, the cost of the Unlimited Anytime Call Plan will be reduced from £5.00 to £4.70 per month. These changes will provide a further incentive for those who make calls through BT to switch to the appropriate Call Plan.

It may therefore be seen that the perverse effect of the current regulatory position is to cause those who would incur penalty charges for making daytime calls to 01/02/03 numbers outside the terms of their call plan to benefit greatly from the fact that BT cannot add any charge of its own for calls to 0845 numbers.

Non-BT providers

There are some landline call providers who choose to follow the same approach that BT is required to follow. Others however (notably Virgin Media) do not inflate their package fees so as to include the (higher) cost of 0845 calls. Neither do these others take inflated margins on other calls so as to cross subsidise to cover a failure to take any margin on originating 0845 calls. This is what is currently forced on BT, and some choose to copy it.

Virgin Media currently charges 10.22p per minute for weekday daytime calls to 0845 numbers, which fairly reflects the additional costs that it incurs over its charge of 8.68p per minute for non-inclusive calls to Geographic Rate numbers.

I note that some have argued that all telephone companies should be subject to the same regulatory requirements that are imposed on BT. I fear that such suggestions can only come from those who do not understand the situation. Alternatively they may be trying to defend an indefensible position as "improper" users of 084 numbers seeking to have their subsidy paid for by all telephone users rather than just those who call them.

What callers pay

The fact that some callers do not bear any additional relative cost as a result of paying the Service Charge on 0845 numbers, leads some users of 0845 numbers to rush out with claims that they (or taxpayers) are benefitting from subsidy at no cost to callers! If the recognition that this exemption from additional cost is neither natural nor universal is not enough to halt them in their tracks, then I have to press on.

In seeking to determine the extent of the financial impact on callers as a result of the use of 0845 numbers, it is necessary to make some determination about what they pay. I address this point with reference to four methods, all of which are reflected in the attached spreadsheet, which I will describe later.

Method one - the "Service Charge"

I personally take the view that one should look first at the impact of the "Service Charge". That is the sum of money which is passing (indirectly) from the caller to the person called. It is for the caller to decide if this is a reasonable fee to pay the person they are calling for the service provided, in addition to whatever they pay their telephone company. To make such a decision however, they must either be well acquainted with the issue or told about the Service Charge.

Every caller pays the Service Charge, even if this is bundled into a package fee or imposed without any Access Charge being added.

If HMRC and DWP are not content to impose a charge on callers for calling them, they cannot continue to use 0845 numbers, and must migrate away immediately. If they are content to impose this charge, then many would think it improper not to announce it to callers.

Method two - adding the effect of the Access Charge

Secondly, one may wish to consider the additional impact of the Access Charges imposed by the various telephone companies. As these are not currently declared separately, this can only be done by looking at the total cost of the call. It is therefore reasonable to make comparison with the equivalent cost of a call to a "Geographic Rate" number. In the current situation, the Access Charge inflates the impact of the Service Charge considerably, when it applies.

There are anomalous cases where the inability to impose an Access Charge (or even take a fair margin) on the cost of calls to 0845 numbers actually makes them cheaper. Where the Service Charge and Access Charge are bundled into a package fee, along with charges for calls to ordinary numbers, there is no clear distinct price for a single call.

Such cases therefore have no place in an assessment of the impact of the Access Charge and Service Charge. Any such assessment must therefore exclude cases where there is no impact.

Method three - aggregating cases

A third, and somewhat irregular, approach would be to consider the net overall relative cost (0845 vs. 03) as if one could play off one group of callers against another. This calculation is achieved by adding in the cases excluded under Method Two as neutral or negative. I understand that this approach is popular, although I struggle to see how it could be valid.

I cannot see how the fact that one caller can exploit BT's inability to impose a significant penalty when they call a 0845 number outside the terms of their call plan can have any bearing on the case of someone who is unable to rent a BT landline (due to their poor credit rating) or who chooses Virgin Media because of its broadband or cable TV services.

I certainly cannot see how public bodies would wish to promote BT against its competitors and furthermore discourage BT customers from selecting the "Anytime" Call Plan, so that they incur penalty charges at a lower rate for 0845 than 03 numbers.

Method four - "winners vs. losers"

A fourth, even more odd, approach is the "winners" and "losers" game. I am astonished to see this favoured by DWP, a department with agencies that are specifically focussed on meeting the needs of minority groups using funding from the majority of citizens.

This method looks at whether more callers would gain by calling a 0845 number than would so by calling a 03 number. This would cause 8 "winners" who breach the terms of their BT Call Plan and thereby each save 25p (a total of £2.00) on a 5 minute weekday daytime call to a 0845, rather than 03, number to outweigh a single caller on T-Mobile who "loses" by paying a premium of £2.05 - by a factor of 8:1.

My personal view is that 100 "winners" would do nothing to eradicate the damage to a single "loser", even if the respective individual amounts were the same. The "loss" is caused purely by the fact that a public body is obtaining subsidy; the effect is compounded by the vagaries of telephone tariffs, but that is not the cause of the loss.

If we are thinking about the administration of social benefits, there will (we hope) always be more taxpaying "losers" than "winner" beneficiaries. If the "winners and losers" game were to be taken as being a sound basis for policy decisions then all benefits would have to be scrapped.

My calculations

I have constructed some tables based on currently published telephone tariffs and the apportionment of calls between the various providers as published by Ofcom.

On top of this I have the added "parameters" to deliver models based on certain assumptions to give what amounts to an average call cost for calls of a particular duration.

The variables I use are as follows:

•	Call duration (differing approach to duration rounding make this best seen in terms of whole minutes to avoid odd distortions caused by calculating actual call costs)
•	The proportion of calls at Daytime rates (100% is applied in the cases used)
•	The proportion of calls from Landlines / Mobiles / Public Payphones.
•	The proportion of landline callers paying penalty rates vs. calling under the terms of their package.

I have extracted the spreadsheet (published at tinyurl.com/dhtiny/0845costs) from my tables to provide a standalone tool to demonstrate the results of the four different methods of assessment referred to above.

The only variable explicitly offered in the extract is that of the call duration. The distribution factors are shown and could be amended, on a copy of the worksheet, to reflect an alternative view of the different sources of calls. The tariff information is also shown, so this could be adjusted to reflect upcoming changes or alternative providers and terms. The calculation formulae may be copied to add new rows to the table.

For those interested in the schoolboy mathematics: A proportion for the total population of callers is attributed to each line for which call cost information is held, and extended by the duration. The proportion factor is applied to give "weighted costs" which may be totalled to give an overall average cost (for Method 3). Average costs for groupings (or the selection, in the case of Method 2) are obtained by aggregating the respective "weighted costs" and then dis-applying the respective aggregated factor. Method 1 is very simple. Method 4 avoids the "weighted costs" using simply the call cost and the factors. To reflect the structure of the original from which this extract was taken, the Totals for Methods 2 and 3 are assembled at the bottom of the worksheet and then presented at the top.

To produce absolute values, I provide the opportunity to enter a number of calls, so that the ratios and averages may be extended to give actual figures.

The conclusions as presented

The model in place reflects a ratio of 82%:15% for landline to mobile, with 3% for public payphones. I have also reflected an assumption that 90% of landline callers are paying penalty charges rather than calling under the terms of a package.

These are assumptions that have been applied by others, but I must stress that I do not think that these assumptions are reasonable at present. (I cannot believe that anything like as many as 90% of landline calls are subject to penalty charges. Furthermore, I believe that these assumptions will become less valid over time, as more callers recognise that they should not be suffering BT penalty charges.

I have however deliberately understated my case, as the conclusions quash any suggestion that callers benefit overall from use of 0845 numbers under present tariff conditions.

•	Under method 2 the excess cost to callers grossly exceeds the benefit of the subsidy to the taxpayer. This suggests that certain telephone companies are the primary beneficiaries of a decision to retain 0845 numbers.
•	Under method 3, where the excess cost to some is offset by perverse savings by others, not only is the net relative additional cost of 0845 calls still positive, it also exceeds the benefit of the subsidy to the taxpayer. Even when we allow for the current restricted position of BT, telephone companies as a whole are still net beneficiaries of the decision to retain 0845 numbers.
•	Under method 4, there are more 03 "winners" than 0845 "winners", except for a call duration of 1 minute, where the minimum call charge for payphone calls consumes the 0845 excess, tilting an always close overall balance on lower durations (2-6 minutes) in favour of 0845. If this odd method, which equates a 50p saving with a 1p or £4.10 loss, cannot produce the result that advocates of charges for public services may seek, then the game must be up.

I hope that those responsible for these matters will take the time to look into this in detail. I continue to offer my services to assist in the cause of a proper objective understanding of the issues.

I will be very happy to answer any questions from any source and to provide further information.

(The spreadsheet to accompany this release is published at tinyurl.com/dhtiny/0845costs. Please refer to the explanatory notes above).

Conservative Health Minister repeats Labour mistakes by not banning expensive GP telephone numbers

In a written parliamentary answer Simon Burns, Minister of State (Health), shows that he is repeating a key mistake made by his predecessor.

When referring to what should be a total ban on use of 0844 and 0845 numbers for delivery of NHS services, in effect by 31 March 2011, he says:

"Organisations remain free to use non-geographical number ranges such as 084, providing that patients are not charged more than the equivalent cost of calling a geographical number to do so."

This is mindless repetition of nonsense issued by the previous government. ALL 084 NUMBERS ARE MORE EXPENSIVE – there are no exceptions.

(The same mistake has already been repeated by the Welsh government and there are fears that Scotland may also follow.)

All calls to 0844 and 0845 numbers, at what is now known as "Business Rate", are subject to a "Service Charge" - a premium which is paid on to the telephone company at the receiving end of the call. The premium is used to subsidise the cost of the telephone service provided, or paid over as a "cash-back". This applies to every 0844 and 0845 number. Charges for calls to Geographic Rate (01/02/03) numbers do not include this premium.

This means that for all calls from Virgin Media landlines, all PAYG and contract mobiles and public payphones every call to a 084 number is charged at "more than the equivalent cost of calling a geographical number". Unless it could be shown that calls from these sources are blocked, then 084 numbers cannot be used.

I continue with more briefing, concluding with my Message to Mr Burns.

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Calls from BT landlines - why they are different

BT landlines are seen to be omitted from the list of sources given above. BT landline call charges are currently subject to special regulations intended to prohibit BT from making any money out of calls to 084 and other "Business Rate" and "Premium Rate" numbers. BT is however now free to charge whatever it wishes for calls to "Geographic Rate" numbers. This makes the situation for BT landline callers more complex.

Like other providers BT provides calls to "Geographic Rate" numbers through inclusive packages, imposing a penalty charge for calls made to these numbers outside the terms of the package. For weekday daytime calls, the BT out of package penalty charge rate for calling Geographic Rate numbers is greater than the level of the "Service Charges" that apply to calls to 084 numbers.

Patients who incur the BT penalty charge for making calls to Geographic Rate numbers outside the terms of their Call Plan therefore would not pay more to call any 084 number. This is the exceptional case - it has got nothing to do with particular 084 numbers – it applies to all of them.

The situation is further confused by the fact that because the Service Charge for calls to 0845 number is relatively low (around 2p per minute, rather than up to 5p per minute for 0844) BT can get away with recovering this money through its fees for Call Plans and therefore makes 0845 calls inclusive. BT landline users therefore do not pay more to call 0845 numbers under the conditions imposed by present regulations. This additional confusion does not apply to calls to 0844 numbers, BT landline customers who do not breach the terms of their Call Plan will always pay more to call 0844 numbers.

Although not compelled to do so by regulation, there are some other telephone companies offering calls through BT lines who are able to copy the BT approach to charging.

The big mistake

The attempt to address the problem with use of Business Rate numbers for access to the NHS was sadly made in apparent ignorance of how telephone tariffs apply through the UK – there are no local variations. The new government is continuing to apply this ignorant approach to implementation of rules which are sound if applied properly.

The exceptional cases where callers do not suffer the impact of the Service Charge on calls to 084 numbers, relative to the cost of calling geographic numbers, have got nothing to do with the particular number they are calling, but with their choice of telephone service provider. Due to unique regulation, BT is the exception to the general rule – it is BT rates that vary from the norm. It is because some BT charges are regulated, whereas others are not, that one has the situation where a call that includes a Service Charge is cheaper than one which does not!

I am not aware of any sponsorship deal between BT and the NHS! NHS patients are no longer required to have BT landlines in order to access NHS services by telephone – even if the situation was different 62 years ago.

Virgin Media provides rental free (inclusive) lines to those who subscribe to its cable TV or Broadband service. Many are unable to afford landlines, or may not be at home at times when they need to contact the NHS - they would therefore use mobiles or public payphones. 75% of non-business telephone calls are NOT originated by BT.

BT currently originates less than 25% of non-business telephone calls. Ofcom is therefore consulting on proposals (supported by BT) to implement the long-overdue removal of the remaining restriction on its charges. This currently creates the perverse effect of encouraging use of premium rate numbers and offers the potential for misrepresentation of the relative cost of calling them.

This is linked in with other proposals for making the cost of calling 084, and other ranges that include a Service Charge, clearer. Under the terms of these proposals GPs would have to make the following statement wherever they gave their 0844 number:

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

There is no good reason why such a statement could not be made today. The difficulty is that the phone company "access charges" vary enormously, even within tariffs, with BT compelled to have an access charge of 0 pence per minute. This issue is also addressed by the Ofcom proposals.

If these proposals come into effect in perhaps one or two years time, I wonder if this issue will be seen as insignificant alongside other provider-set charges for access to NHS services!

My message to Mr Burns

Your suggestion that there may be 084 numbers that are not more expensive to call than geographic numbers is FALSE.

If the government is committed to maintain access to NHS services "free at the point of need", then the ban on use of 084 numbers must be implemented NOW.

NHS bodies should have stopped using them by 21 December 2010, GPs have until 31 March 2011. Users of 084 numbers may migrate to the equivalent 034 (Geographic Rate) number within the term of a contract for telephone service - so there can be no excuse for failing to comply.

Whilst it would be absurd for a complete number change for 0845 4647 to be implemented at present, it seems rather greedy of NHS Direct not to formally, but quietly, offer the 0345 4647 alternative for those who could thereby save up to £3.70 (58p on average) on an average duration call, even though this would cost NHS Direct 15p per average call in lost subsidy. A bonus of 43p per average call is a generous gift to the telephone companies. (The NHS Direct NHS Trust also operates many other 0845 telephone numbers, which were excluded from the ban for no apparent reason.)

N.B. The above text includes some drafting revisions from the circulated version of this release.

Ofcom is allowing - not stopping - Silent Calls

In a press release issued today - Ofcom 'must stop more silent calls', Margaret Hodge MP, chair of the Public Accounts Committee, rounds on Ofcom’s persistent failure to use the powers that it holds to properly address the problem of Silent Calls.

Ofcom has been told by parliament – “We expect you to use your powers to eradicate the nuisance of Silent Calls”.

Despite being granted a higher possible penalty, Ofcom has responded by revising its policy on Silent Calls to include an even greater tolerance of this unacceptable and unnecessary nuisance than that which it has applied for the last 8 years.

When asked to explain the new policy on BBC television last week, Lynn Parker, Ofcom Director of Consumer Protection confirmed the point that I have been making:

Interviewer: "So companies are allowed one silent call per day?"

Parker (Ofcom): "YES"

¾ See BBC News item with recording

This is, of course, one per recipient per caller per day. If a large call centre makes 20,000 calls a day in total Ofcom is already content if 600 of these are Silent Calls. They can now make a further Silent Call to any victim the following day, whereas a three day gap was previously suggested.

Telephone calls to the NHS - an expensive mess - NHS Direct now at the heart of this

NHS Direct - a model for NHS Charges

Whatever the rights and wrongs of it getting involved in making GP appointments behind the highly expensive 111 telephone service, NHS Direct has long been a model to demonstrate how patients can be made to contribute to the funding of NHS services as they use them.

The current NHS Direct telephone number 0845 4647 delivers a subsidy of around £749,700 (¾ million) per annum - 15p per call - from patients.

Patients pay premiums of up to 41p per minute (an average of 58p per call) over the cost of a call to an ‘ordinary’ number. Other 0845 numbers used by NHS Direct probably deliver a similar level of subsidy.

(These figures are based on current tariffs, an average call duration of around 9 minutes and a total of 4.9 million calls per annum - see notes below.)

Landline and contract mobile customers generally do not pay call charges for calls to "ordinary" (01/02/03) numbers. They are included in unlimited packages or bundles, so an extra call costs nothing extra. NHS Direct has long made provision to take advantage of this by having the alternative number - 0345 4647 - set up and ready for use. It has however continued to refuse my urgent pleas for this to be introduced, even as an alternative running in parallel with 0845 4647, to avoid the expense and confusion caused by a total change of number. (Even for PAYG mobile callers, 0845 4647 is on average 43% more expensive to call than 0345 4647.)

It appears that NHS Direct is keen to retain a 15p (0.6%) subsidy towards the £25 it spends in handling each call, despite the fact that this subsidy costs callers an average of 58p, a maximum of £3.69, extra. (Yes, some callers pay £3.69 so that NHS Direct can gain a 15p subsidy – see notes 4/5.)

The cost of 111

At a time when reducing the deficit was not seen as such a priority, arrangements were made for the cost of every call to the new 111 number to be met by the NHS, even if a caller would have paid nothing to call a 03 number.

Consortia who adopt 111 not only pay to handle each telephone call they also pay the telephone companies to receive it. When we see the analysis of the pilots in the Autumn, I hope that this aspect of the costing will be published.

Even more barmy

Whilst NHS Direct is taking subsidy from patients, as well as helping the telephone companies (by 43p per call), and consortia are needlessly going to have to pay for incoming calls, a further abuse of the principles of the NHS is being allowed to continue.

Despite the fact that NHS GPs should by now be complying with a contract variation which prohibits use of expensive telephone numbers, many are continuing to use the even more expensive 0844 numbers, despite a deadline of 31 March for this to cease.

The Department of Health and the relevant Minister have confirmed that they are taking no action to ensure that this important embodiment of the principles of the NHS is enforced.

Conclusions

Public money and patient's money (all of it "ours") is being thrown around with abandon out of a misguided sense of urgency to cure an illness that does not exist. The private health sector and the telecoms industry do not need injections of our money to keep them alive.

At the age of 62, "our NHS" needs to do some work to keep fit; it does not need further extensive surgery, as that which was delivered, whilst vital at first, had started to become purely cosmetic. "Our NHS" is not a candidate for euthanasia, even though those who are currently charged with caring for it argue that this would be for the best, whilst claiming to have its best interests at heart.

Ofcom is currently consulting on proposals to classify NHS Direct and GPs with expensive telephone numbers as providers of "Premium Rate Services", along with TV quiz lines.

With the high cost base of NHS Direct and of the 111 service, it will not be difficult for a commercial competitor to undercut these options.

The NHS is in a very precarious position.

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Notes

1. I will be happy to provide any level of detail from my calculations to support the figures quoted above. The primary sources are Ofcom and the telephone companies it recognises as being the major providers of call services.

2. An average duration of 528 seconds for calls to the NHS Direct was given in this written answer - 3 Feb 2009 Column 1109W.

3. The figure of 4.9 million calls a year is found on this web page - http://www.nhsdirect.nhs.uk/News/FactsAndFigures.

4. Ofcom suggests that calls to 0845 numbers attract a termination fee that is enhanced by around 1.7p per minute. (9 x 1.7p = 15.3p)

5. T-Mobile charges its “pay monthly” customers 41p per minute to call 0845 numbers. (9 x 41p = £3.69). All its price plans include calls to 01/02/03 numbers.

OFCOM AND SILENT CALLS - NO NEWS | THE NEWS

Silent Calls - NO NEWS

The fact that Ofcom can now impose penalties of up to £2 Million against Silent Callers is no news. (e.g. - http://www.bbc.co.uk/news/uk-12331160)

Since 2008, when it last used its powers against Silent Callers:

•	Ofcom received a total of over 15,000 complaints about Silent Calls
•	Ofcom claims to have secretly investigated 22 companies

Every one of the companies covered by these complaints and investigations were found NOT to breaking the rules which Ofcom applies in determining what is "persistent misuse of an electronic communications network or service".

Not one company has been even subjected to a public notification that it is practising misuse, let alone any financial penalty.

Silent Calls - THE NEWS

From today, Ofcom not only allows 3% of calls made to result in silence if no agent is available, it now approves use of Answering Machine Detection equipment (AMD). AMD listens to our voice as we answer the phone, so we hear a period of silence - often assuming that this is a Silent Call - as indeed it is, but not for Ofcom.

Ofcom acknowledges that AMD is not guaranteed to accurately tell the difference between a recorded message and a live person. It therefore qualifies this new tolerance of AMD by suggesting that each caller may only make one silent call each day to any person. Ofcom actually encourages AMD users to repeat each of their Silent Calls on the next day.

OFCOM FORMALLY TOLERATES SILENT CALLS - FROM TODAY, MORE OF THEM