NHS Bodies undermine attempts to end the GP telephone number rip-off

Whilst efforts to enforce the ban on use of expensive telephone numbers by NHS GPs in England continue, they are undermined by NHS bodies doing the same.

NHS bodies in breach

I have picked out a list of 20 significant cases, where Directions issued by the Department of Health in December 2009 to NHS bodies in England have been disregarded. (See my blog.)

The most notable examples however are the NHS Direct Health Advice and Information service for England (0845 4647) - shortly to be withdrawn, NHS Direct Wales (0845 4647) and NHS 24 for Scotland (08454 24 24 24).

By their "approved" use of revenue sharing telephone numbers it may be seen that the principle of "co-payment" - i.e. subsidy from patients through payments made as they access NHS services - is sanctioned by the respective governments, although not by the respective parliaments.

GPs in breach

Not only are cases like this seen to breach the very principles of the NHS, they also make it more difficult for independent contracted providers of NHS services to be brought in line with those principles.

My database of officially listed cases of use of expensive telephone numbers by NHS GPs, currently shows the following total numbers of cases:

•	England	1,270
•	Wales	61
•	Scotland	48
•	Northern Ireland	22

Failure by Governments

Following a public consultation, the then Minister of State (Health Services) said on 14 September 2009:

"We want to reassure the public that when they contact their local GP or hospital, the cost of their call will be no more expensive than if they had dialled a normal landline number."

As we approach the second anniversary of that statement, it can be seen that both the previous and the current UK government have failed to deliver that reassurance. The governments holding devolved authority are in no different position, indeed that have not even declared the intention.

By proposing reform that does not address the problem of the projected massively increased costs of publicly provided health services, indeed by loosening the mechanisms that may hold back their scope to within the bounds of public affordability, the UK government clearly intends that payment for access will become necessary in England.

With England having thereby opted-out from the NHS, can we be sure that it will continue in the remainder of the UK?

NHS Dentists warned of the danger of being misled about the cost of calling 084 telephone numbers

Like their colleagues in General Practice, NHS Dentists are committed to upholding the principles of the NHS as they deliver NHS services to patients.

This article, by practice consultants PSDS, warns that practices can be misled when choosing a telephone system.

The article refers to a particular un-named company providing systems for Dentists and GPs, which requires practices to adopt a 0844 telephone number. All 0844 telephone numbers are "revenue sharing" which means that a premium payment by callers is used to subsidise the cost of the system to the user.

This could be a reference to "the original and still best telephony solution in the UK for dentists", which is described as being a "revolutionary co-funded telephone systems solution , designed specifically for dentists".

The same company also offers "the original and still best telephony solution in the UK for GP’s", which is described as being a "revolutionary co-funded enhanced telephony systems service designed specifically for GP surgery and general practice".

One could reasonably assume that "co-funded" means that part of the cost of the system is paid for by patients, as is the case when 0844 telephone numbers are used.

There is however a further extraordinary claim made about the telephone numbers used to part-fund these particular systems, as they allegedly defy the standard charges levied by all telephone call service providers. It is claimed that the 084 numbers used are "not more expensive to call than using an ordinary number".

I must urge those able to identify the provider of these systems to obtain a clear and accurate understanding of how the systems are "co-funded" and accurate details of how exceptional charges are applied by all telephone call service providers for calls to these numbers.

I see it as most important that inaccurate information about this company and the services it provides is not placed in the public domain. It is vital that the issues raised are discussed with total respect for accuracy by all parties.

NHS Contracts

The contractual terms which apply to delivery of both NHS GP and Dentistry services make it clear that any payment by patients to the benefit to the practice (or a third party, e.g. a telephone system provider) can only be those on standard scales approved by parliament and with exemptions applied as defined. (See GMS contract clause 483 and GDS contract clause 241.)

As this principle had been widely abused, general regulations about telephone numbers have now been applied to GP contracts (see GMS contract clause 29B). It has not yet been seen to be necessary to apply similar general conditions to NHS Dentists.

In 2005, specific regulations regarding only some particular types of telephone number were applied to both. (See GMS contract clause 29A and GDS contract clause 70.) Unfortunately in 2005, the government had itself been misled about the cost of calling 084 numbers, as it made the extraordinary and inaccurate claim that these "offer patients a guaranteed low call rate" (see this media release).

Enhanced telephony

The "enhanced telephony" facilities available on 0844 numbers are equally available on 03 numbers, and may be available on some 01/02 numbers. (Identical facilities are available on all non-geographic numbers: 03, 070, 080, 084, 087 and 09 ranges.)

Calls to 03 numbers are charged on the same basis as calls to geographic numbers for all callers. Use of 03 numbers is therefore fully compliant with the principles of the NHS.

Those offering NHS services, paid for only through NHS payments to the practice and specifically stated and authorised charges, cannot use 0844 (or indeed 0843 or 0845) numbers. Use of 070, 080, 087 and 09 numbers is also prohibited (except where exceptional arrangements are made in the case of 080).

Returning to compliance

The PSDS article fails to indicate that it is not necessary to terminate the entire contract to move into compliance with the principles of the NHS.

Provision of network telephone service is only part of the contract, which is primarily a leasing agreement covering the provision of locally installed equipment. Whilst the revenue sharing financial benefits are derived from use of a 084 number, the enhanced telephony features are available on other numbers.

Any practice which wishes, or has already chosen, to invest in "enhanced telephony" for the benefit of its patients can adopt or migrate to a 03 number at any time - the equivalent 0344 number is reserved for this specific purpose.

It is standard practice in the telephone industry to allow migration from one type of non-geographic number to another at any point in the term of a contract, without penalty. There is no good reason why any system provider would wish to impede a move from 0844 to 0344, as this would do nothing more than shift the on-going cost of the system from the patient to the Dentist / GP.

Any system provider that sought to prevent its clients from complying with the principles of the NHS (and the terms of their NHS contracts), when this involved no compromise of its own interests, would be taking a most extraordinary position. I hope that nobody would suggest that any company is behaving in this way without first verifying the accuracy of such a claim.

It may be noted that the BMA makes such a claim about provider(s) to GPs - "many GP practices have signed multi-year contracts with telephone services providers which cannot be varied, renegotiated or terminated without substantial financial penalty" (I quote from comments on this specific issue in the latest BMA Guidance).

"The leading provider of enhanced telephony to the health sector"

Many would assume that the comments made above all relate to a company which describes itself as "the leading provider of enhanced telephony to the health sector".

My concern is that only accurate information about this company is placed in the public domain. There are concerns about inaccurate information having been published, which have been heightened as a result of its new owner having chosen to take a prominent public position, through the broadcast media.

Ofcom shows why public service providers must cease using 0845 telephone numbers, initially providing 0345 alternatives

Some interesting figures emerge from the Ofcom Communications Market Report 2011 - published on 4 August 2011. See Conclusion.

It is well known that, due to special regulations which apply only to it alone, BT is able to offer calls to 0845 numbers without charging a premium over the cost of an ordinary call. (BT does however charge a premium for 0845 calls made by those who subscribe to its "social tariff" - BT Basic.)

All call originating telephone companies have to pay on a revenue share of around 2p per minute to the call recipient on 0845 calls. Except when under the conditions which apply to BT, they may pass this on directly to the caller as a premium over the charge for a call to a geographic number. Most commonly they exclude these calls from discounted and call inclusive arrangements, thereby effectively applying a much greater premium. This is seen most clearly in the mobile market where intense competition causes the cost of calls to ordinary landline numbers to be kept very low. Calls to 0845 numbers from public payphones are charged at 30 times the rate of calls to ordinary numbers.

It is common to refer to BT Call Plans (which provide free calls to geographic and 0845 numbers) as if these applied to an overwhelming majority of callers, with the dismissive comment that "others may vary".

The figures shown below indicate the proportion of the population who are being dismissed in this way by public service providers.

I refer, in particular, to NHS Direct, HMRC and the various DWP agencies - all of whom primarily use 0845 numbers for enquiries.

Public service providers must consider the whole of the population they are serving, not some selective group, nor what may be (perhaps wrongly) thought to be a majority.

Those requiring "non-geographic" telephone numbers must move away from 0845 numbers and IMMEDIATELY OFFER THE 03 EQUIVALENT AS AN ALTERNATIVE.

Citizens who cannot afford a telephone, choose Virgin Media as their telephone provider, find a mobile phone best for their needs or subscribe to BT Basic, should not be required to suffer a premium charge for contacting public services providers.

The Cabinet Office sets the standard for all public services, through Guidance or Direction. I note that an e-petition to the Cabinet Office, on this very point, has just been started.

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I refer below to data from Section 5 - Telecoms and Networks of the Ofcom Communications Market Report 2011 - published on 4 August 2011.

Shares of non-business call origination

Calls from Landlines

The report notes on page 286 - "BT’s share of retail residential UK voice call volumes falls below 40%".

The most recent, and fully inclusive, figure (from Table 8 of the Telecommunications market data tables for the three months to March 2011) is 39.9%.

This means that significantly less than half of all residential landline calls are made under the specially regulated terms which apply only to BT.

Share of all Calls

By breaking down the respective totals for Business and Non-Business calls (see note) it may be seen that only 61.4% of non-business calls are made from landlines.

This shows a BT percentage of total call volumes at (39.9% x 61.4% =) 24.5%.

Less than a quarter of all non-business calls are made under the specially regulated terms which apply only to BT.

Household availability of landlines

Where important services are provided by telephone, one must have regard to those households which are unable to access these from a landline, and would therefore use a mobile or public payphone.

The Ofcom report publishes (on page 319) the proportions of households, categorised in various ways, which DO NOT have a landline telephone:

Total Population: 16%

Socio-economic groups DE: 27%

Households aged 16-24: 32%

Households aged 25-34: 23%

Over a quarter of households both of the socially disadvantaged, and of younger families, do not have a landline.

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Conclusion

BT may be the largest single provider of telephone call services, however its charges for calls to 084 numbers are wholly atypical due to unique regulation. Attempts to justify use of revenue sharing 084 numbers on the basis of BT charges are thereby fundamentally invalid.

The figures given above indicate the proportions of the population who are being subjected to improper premium charges when required to access pubic services through a 0845 number.

Where non-geographic numbers are required, 03 numbers offer the only equitable option - * Callers pay only the cost of a normal telephone call. * Providers meet the cost of their telephone operations, unsubsidised.

Migration to 03 numbers – initially parallel operation of the 0345 equivalent of every 0845 number, as an alternative – is not only vital, but conveniently and inexpensively achieved.

The Cabinet Office, which initially pressed for the introduction of 03 numbers, must sieze this issue as a way of demonstrating the government’s commitment to equity.

Department of Health decides to roll out 111 nationally - without knowing the cost

In a letter published today, demanding plans for implementation of the 111 telephone service throughout England, it is announced that the roll out will happen. This decision has been taken before the planned evaluation of the pilots which was scheduled for the Autumn. Most disturbingly, it has been taken before any of the costing figures from the pilots have been assembled.

Cost was a primary motivation behind the decision to abandon the nationally managed NHS Direct health advice and information service, in favour of the locally run 111 service.

The modest subsidy which NHS Direct derives from its use of a 0845 telephone number (at much greater premium cost to callers, e.g. 1.7p per minute vs. 41p per minute) goes little way towards offsetting the considerable costs it incurs in providing a comprehensive health advice and information service by telephone.

The 111 service was said to be ONLY for URGENT, but non-emergency, calls. The evidence from the few pilots that are currently running shows that many non-urgent calls are being received and handled. This is not identified as an issue that needs to be addressed.

The NHS Direct NHS Trust has been awarded the position of being the default provider of the 111 service, despite its poor record for economy. The idea that each locality could address the needs of its people in the most suitable manner has been abandoned. A needless rush will, most likely, simply transfer the same costly NHS Direct service from one number to another, whilst also adding further costs.

Rather than benefitting from a fraction of the premium rates paid by patients to call the 0845 number, calls to the 111 service will be at no charge to the caller. Even if the caller would have been able to call a local or 03 number at no cost, the NHS will pay every telephone company for every call to 111. When the figures are assembled and released we will know how much that amounts to.

At a time when great care is being taken with public spending, it is extraordinary to see such recklessness. I am not opposed to spending money on the NHS, nor to the concept of the 111 service. I am however disturbed to see so much money being spent on ill-justified reorganisations and unproved projects at a time when resources are under pressure.

There are some who think that the present NHS re-organisation (which will be simply rubber-stamped when the Health Bill is passed) is just phase 1 of something bolder. Some think that the NHS is being deliberately fattened up with cash denied to others.

**** disrespecting the NHS

On 3 August I published a news release in which I referred to Daisy Group Plc.

I now understand that this may contain material which is misleading and inaccurate.

I must ask that anyone who has read this item contact Daisy Group Plc before using any of this material to ensure that only accurate information about this company is published.

Please accept my apologies if you have been misled in any way.

The telephone rip-off for aspiring university students is here again

As results day approaches, UCAS has apparently doubled the number of staff ready to take calls on its PREMIUM RATE TELEPHONE LINE. (See The Independent - 1 August 2011.)

UCAS advises that calls to its (Phonepay Plus-regulated) premium rate number 0871 468 0 468 "will cost no more than 9p per minute" from a UK BT landline. This statement is false.

The facts

Those looking to study mathematics may be able to work out that after paying a call setup fee of 12.5p and a rate per minute of 9.19p, with the total call cost rounded up to the nearest penny, those using a BT landline will be paying more than 9p per minute. For example, a 7 minute call will cost 77p, 11p per minute. Students of the law may however recognise that such deception is not explicitly prohibited under Phonepay Plus regulations.

Budding economists or students of commerce will perhaps be aware that nearly all of the 9.19p per minute BT charge (including VAT) is passed over to the provider of telephone service to UCAS (Cable & Wireless) as a subsidy towards the cost of its telephone system - at the expense of callers.

Historians will perhaps understand that this unique regulation on BT is a legacy from when it was the monopoly provider. Other telephone companies are able to add their own charges to the rate amount paid to UCAS.

BT charges vary from the rest

UCAS declares that "Calls from mobiles and other networks may vary".

Pedantic logicians may argue that because BT alone is prohibited from adding its own charge - it is BT that varies from the norm by having unusually low charges for these calls.

Virgin Media, for example, charges a call connection fee of 13.24p plus 10.22p per minute for these calls.

Calls from Mobiles

Many 6^th form students will have mobile phones loaded with packages and bundles to offer text messages and / or calls to normal landline numbers and other mobiles at relatively low rates. None of these bundles cover calls to Premium Rate numbers.

All of the major mobile providers charge between 35p and 41p per minute for calls to the UCAS premium rate number. Excluding VAT, only around 7.5p per minute of this benefits UCAS - the rest is simply revenue for the mobile companies.

UCAS may argue that this is a fair "service charge" for use of its Customer Services Unit, including the time spent waiting to be connected to an advisor. This does not however seem to be a particularly effective way of collecting such a charge, when the "agent" (the telephone company) takes so great a premium over its normal call charges.

Budding philosophers will note that this may be a valuable lesson for those starting an independent life. If they cannot secure a place in higher education and call their local job centre; the number is 0845 6060 234. This yields Job Centre Plus only around 2p per minute in subsidy, but the per minute charge rates to call this number from Virgin Media and the Mobile Providers are exactly the same as for the premium rate UCAS number.

The same is true for tax or tax credit enquiries of HMRC - 0845 300 0627 / 0845 300 3900, and even for NHS Direct - 0845 4647.

Conclusion

The modest subsidies which these public bodies achieve from use of these expensive telephone numbers are dwarfed by the additional cost incurred by callers. If they need the benefits of a non-geographic number, these are fully available on 03 numbers.

All calls to 03 numbers are charged on the same basis as a call to a geographic number - in many cases this means that they are covered by an inclusive call package.

Gradual and highly cost-effective migration to 03 is possible by introducing the 03 equivalents of the 08 numbers as alternatives. In every case the equivalent number is reserved for the very purpose and may be very readily put in place, as a replacement or an alternative; i.e.

0371 468 0 468, 0345 6060 234, 0345 300 0627 / 0345 300 3900 and 0345 4647.

If one or more public service providers were simply to advise callers that they could get through at much lesser cost by swapping the second digit "8" for a "3" on any published 084 or 087 number, then this disgraceful and unnecessary rip-off could be ended very easily and swiftly.