Breaches of the NHS GP contract continue - new 0844 telephone numbers being adopted

This media release draws attention to two recent examples of a continuing national problem,
one in the South East (Herne Bay), the other in the North West (Chester).

Circulation

The release has been circulated addressed and copied to various parties, from whom I have invited comments:

Addressed to:

This message is openly addressed to those who carry some responsibility for this abuse of the principles of the NHS.

•	The practices have a contractual duty to determine that “persons will not pay more to make relevant calls to the practice than they would to make equivalent calls to a geographical number”, before choosing a telephone number. By suggesting that alternative geographical numbers are necessary, they clearly indicate a belief that some will pay more to call the number they have chosen. [Park Surgery (Herne Bay); Northgate Village Surgery;]
•	The PCTs and the NHS Commissioning Board (which is taking over the relevant responsibility) have a duty to represent the interests of patients, by ensuring compliance with the terms of the GP contract. [Ann Sutton - Chief Executive - Kent and Medway PCT Cluster; Felicity Cox - Local Area Team Director: Kent & Medway - NHS Commissioning Board; Kathy Doran - Chief Executive - NHS Cheshire Warrington and Wirral; Moira Dumma - Local Area Team Director: Cheshire Warrington & Wirral - NHS Commissioning Board; Ann Sutton - Director of NHS Commissioning - NHS Commissioning Board;]
•	The Department of Health has a duty to ensure that the respective responsibilities are clearly understood and that the information necessary to discharge them is accessible. [Nick Hall - Deputy Director - Department of Health; David Howarth - Department of Health;]
•	The telephone system provider (Daisy Group) may be used, or may volunteer itself, as a source of information about the tariffs used by customers of telephone companies, including and other than that (Talk Talk) for which it acts as a reseller of the numbers in question. If claiming any competence in this role, it has a duty not to provide inaccurate information. [Matthew Riley - CEO - Daisy Group]

Copied to:

This message is openly copied to those who have a clear interest in the issue, for the reputation of themselves and that of the “reformed” NHS.

•	Clinical Commissioning Groups and Local Medical Committees represent their local GP communities. They will both be concerned to show that those they represent are clearly committed to the principles of the NHS. In the former case, they are stepping forward to accept a duty to apply them in making major commercial decisions. [Canterbury and Coastal CCG; West Cheshire Clinical Commissioning Group; Kent LMC; Cheshire LMC;]
•	The GP Committee of the BMA has a national duty to represent its members. After initially declaring its opposition to the intention of the contractual revisions (suggesting that patients should pay according to the quality of service received), it now accepts that it has failed to secure this "reform" and support the continuing principles of the NHS. [Dr Laurence Buckman - Chairman - BMA GPC;]
•	Local MPs have a duty to represent the interests of their constituents. As members of our parliament they share a duty to protect “our NHS”. [Roger Gale MP; Stephen Mosley MP;]
•	Health Ministers have a duty to ensure that their Department, and those to whom relevant responsibilities are devolved execute the will of parliament, as reflected in the terms of NHS GP contract. [Jeremy Hunt MP - Secretary of State for Health; Anna Soubry MP - Parliamentary Under Secretary of State - Department of Health; Dr Dan Poulter MP - Health Services Minister;]
•	Shadow Health Ministers have a duty to ensure that those they shadow are held to account for the discharge of their responsibilities. [Andy Burnham MP; Liz Kendall MP; Andrew Gwynne MP; Jamie Reed MP]

Oh dear Pudsey! - are you going back to 084 telephone numbers?

Countryfile has launched its 2013 Calendar, which is

“Sold on behalf of the BBC   for   Children in Need    by   Hallmark Consumer Services
    … phone our order line on      0844 811 7044”.

Pudsey gave up 084 numbers in 2008

After extensive campaigning in 2008, BBC Children in Need replaced its 084 telephone numbers with the 034 equivalents. This ensured that callers paid only the cost (if anything) of a call to a geographic number to donate or request a fundraising pack.

It appears that something has gone badly wrong. Callers to 0844 811 7044 pay a premium Service Charge of around 5p per minute to the operator of the order line, plus a premium Access Charge of up to 35p per minute to their telephone company.

See the announcement clip below. This is also available on the Countryfile website.

New regulations

As part of its new regulations to “simplify non-geographic numbers”, Ofcom will shortly be announcing a requirement to always state the Service Charge included in the cost of calling any 084 number. There is no current requirement to hide this charge, although many do!

If the BBC chose to follow Ofcom's suggested format (see this example), before it was compelled to do so, it would look something like this:

Is Pudsey happy with agents imposing service charges?

If Hallmark Consumer Services is content to levy a Service Charge on callers to its order lines, in the knowledge that telephone companies will add their own premiums, then that is matter for it to decide. We understood that Pudsey wanted to stay away from this practice.

The fair telecoms campaign argues that Service Charges (applied whenever a 084 number is chosen) should only be imposed in very particular circumstances - not by Pudsey!

Ofcom attacked for its failure with Silent Calls

A feature article in the Sunday Post today draws attention to Ofcom's failure to address the nuisance of Silent Calls. (see content and facsimile copies)

In 2006, Ofcom was told by parliament:

“We expect you to use your powers to eradicate the nuisance of Silent Calls” [see Hansard, Sound clips]

Ofcom continued to fail to properly deploy the range of powers available to it, and continued to follow a policy of “regulation”, i.e. qualified tolerance, rather than eradication.

Under the current government in 2010, parliament granted Ofcom a further extension to its powers to levy financial penalties. The debate made no reference to the failure to comply with parliament's previous expectation.

This has resulted in one such penalty, focussed on an isolated incident lasting only six weeks. Ofcom only dealt with the incident over 3 months after it had ended, and then took a further 12 months to reach a determination that a financial penalty was necessary.

This action was only taken because a major telemarketing company had, on this occasion, breached the 3% tolerance rule. So far as we know, this same company, and many other household names, continue to terminate 3% of connected calls in silence.

Ofcom has a full range of powers, including the ability to impose an enforceable requirement not to continue making Silent Calls - this power has never been used. If such a requirement were breached, in addition to imposing repeated financial penalties, Ofcom has the power to seek for the requirement to be enforced through an injunction. If this were necessary, any further breach would become a criminal offence, with potentially most severe consequences for any offender.

This power has always been available - there should be no issue with the maximum financial penalty! This was the very point being made when it was increased from £5,000 to £50,000.

As current public focus on this issue, and related issues, strengthens, the fair telecoms campaign stands ready to engage in serious debate over the measures that are necessary. We have a number of specific outline proposals as to how the powers held by Ofcom (and those held by the ICO to deal with improper telephone marketing activity) may be more effectively deployed.

The original outline of these proposals was covered in - “Ofcom the useless Quango …”.

Further refinement is in hand.

The fair telecoms campaign comments on premium rate numbers for wheelchair Paralympics tickets

A LOCOG statement has been issued denying responsibility for the imposition of premium rate charges on wheelchair users visiting the London 2012 Paralympics. Although the statement contains false information about the cost of calling 0844 numbers, it is correct in saying that it has enabled appointed contractors to impose these charges.

It seems that Ticketmaster has been awarded the contract to provide the “Accessibility Team helpline” on 0844 847 2012 and the “Disabled parking call centre” on 0844 921 2012.

This seems to be fully in line with government policy for the disabled. The Department for Transport recently awarded administration of the Blue Badge scheme to Northgate Information Solutions, which operates Blue Badge helplines on 0844 463 0213/4/5.

These 0844 telephone numbers provide a subsidy to the service provider, through a “Service Charge” of between 3 and 7 pence per minute, which offsets the costs of their operations. Because of this modest subsidy however, callers pay not only this charge, but also the additional “Access Charge” levied by their own telephone company, which is almost invariably well in excess of the cost of a call to an ordinary number.

For a BT subscriber using the most popular BT Call Plan a 10 minute call to 0844 847 2012 would cost 65p (6.5 pence per minute) as against zero for a call to a 01/02 or 03 number.

An Orange contract caller would pay £4 for a 10 minute call to any of these 0844 numbers, as against zero for a call to a 01/02 or 03 number.

Ofcom will shortly be introducing new regulations which will require the “Service Charge” and “Access Charge” to be declared separately - see “Ofcom proposes a fairer system for telephone call charges”.

Last Monday, the Department for Trade and Industry announced that use of 084 numbers will shortly be prohibited for contact with customers - see “fair telecoms campaign welcomes ban on use of 084 / 087 numbers by businesses”.

David Hickson, of the fair telecoms campaign comments:

“The cost of calling a 0844 number has never had anything to do with ‘local rates’ - the ASA and Trading Standards are now quick to jump on any organisation that makes such false representations. 0844 numbers offer a very inefficient way of getting callers to subside the cost of a running telephone call centre. The 03 range offers all of the same facilities to the service provider, but the caller pays no more than they pay (if anything) to call a geographic number.

“When the government allows contractors to subsidise the cost of their service by imposing ‘Service Charges’, it should think carefully about when it is right for service users to pay in order to either reduce the cost to the taxpayer, or to make a government contract more profitable for the contractor.

“Allowing Service Charges to be imposed on callers to a Blue Badge helpline, a Disabled Parking call centre and a Paralympics Accessibility Centre does not seem to strike the right note for UK citizens at large, as we prepare to celebrate the achievements of a select group of disabled people from around the world.”

fair telecoms campaign welcomes ban on use of 084 / 087 numbers by businesses

UPDATE: - This issue was discussed on You and Yours today - listen here.

A government consultation has been launched today outlining the basis of new rules to stop business using expensive 084 and 087 telephone numbers for contact from customers.

The consultation is published at this link. It includes some issues open to discussion and a request for evidence of cases where consumers feel disadvantaged.

The fair telecoms campaign welcomes this long overdue move, compelled by a EU Directive, but asks the question:

“If it is wrong for businesses, why is it still seen as OK for the government?”

Even the consumer helpline, operated for the government by Citizens Advice, uses an expensive number - 08454 04 05 06.
Citizens Advice Bureaux have long used expensive numbers for access to their own services, including a recently launched national number - 08444 111 444.

HMRC and the DWP agencies use 0845 numbers for enquiries and helplines. The single exception is the HMRC Tax Credits helpline, which has recently switched from 0845 to the 0345 equivalent number.

This matter also highlights the failure of many NHS bodies to eliminate the use of these numbers, despite Directions and contract revisions issued in 2009/10.

Calls to all 03 numbers are charged at the basic geographic rate - now generally zero for those with landlines and contract mobile phones. Calls to 084 / 087 numbers cost landline users up to 13p per minute and mobile users up to 41p per minute.

Migration to the equivalent 034 / 037 number is what all users of 084 / 087 numbers should be considering, unless they can justify the imposition of a "Service Charge" on callers. New Ofcom regulations will shortly require this "Service Charge" to be declared in all cases.

The "two tier NHS" has arrived

It has come to my attention that some NHS Primary Care Trusts are permitting their GPs to offer TWO-TIER ACCESS TO NHS SERVICES by telephone. (See details of a new case below.)

These GPs offer a "basic" normal local telephone number, with "enhanced facilities" available on an expensive 084 number as an alternative option. The cost of calling all 084 numbers includes a “Service Charge”, to the benefit of the person called, in addition to the “Access Charge” to the benefit of the caller’s telephone company.

The choice of a 084, rather than 03, number ensures that the generally greater cost of providing enhanced facilities through non-geographic numbers is met by callers, rather than the GP. A 084 number also provides funding for the basic elements of a telephone system, such as switchboards and handsets.

The so-called "enhanced" facilities are those provided by many GPs on normal (geographic) numbers, where they are paid for by the GP out of the NHS funding provided for the purpose; e.g. call queuing, recorded messages, voicemail, re-direction of calls to out-of-hours services.

Regardless of the benefits (or value for money) offered, it has never been permissible to offer two types of access to NHS services, differentiated by a charge …

…, or perhaps now it is, given that this approach is sanctioned by the local bodies responsible for adherence to the principles of the NHS!

This causes me to pose the question: Is a two-tier "NHS" the way of the future?

∗	“Basic” services, at no charge from the NHS provider, for the poor and needy (who meet only their incidental expenses in accessing NHS services),
∗ ∗ ∗	“Enhanced” services, charged for (directly or indirectly) by the NHS provider, for those who can afford to chose a better service

That is not the universal "NHS", funded from general taxation, which will celebrate its 64^th birthday on Thursday, July 5^th.

A line from a Beatles song comes to mind – “will you still need me, will you still feed me …?” – there are many parallels, even “Dave” is named as one of the grandchildren.

Approval

The following Primary Care Trust Chief Executives explicitly permit their GPs to offer this two-tier telephone access service:

•	Christopher Long	NHS York and North Yorkshire
•	Mike Potts	NHS Calderdale, Halifax and Kirklees
•	Caroline Taylor	NHS North Central London
•	Debbie Fleming	NHS Southampton, Hampshire, Isle of Wight and Portsmouth

It is strongly suggested that many other PCTs apply the same unusual interpretation of the NHS Constitution in forming their policy on this issue.

Government ministers claim that PCTs have been issued with clear guidance to not only prohibit this appalling breach of the principles of the NHS, but also to enforce the ban which applies to use of expensive telephone numbers under any circumstances. I understand however that the Department of Health is unable to enforce compliance with the statutory duty to have regard to the NHS Constitution held by all NHS bodies and their contractors, nor may it compel PCTs to enforce the terms of GP contracts as approved by parliament.

With the NHS in England now increasingly being "liberated" from central control, unaccountable local bodies have extensive discretion in how they apply the principles of this "National" service. The authority to make these decisions is now even passing from public servants to GPs.

Please refer to the additional information given below. This covers a recent new case which clearly demonstrates my point, and explains the position with older cases.

I must encourage, and am happy to assist with, attempts to obtain a formal statement of the position taken by the Department of Health with regard to enforcement.

Please obtain direct confirmation of the policy being followed by any (every) local PCT. I have named only those cases where I am sure that the policy is stated openly. There is extensive evidence to show that it is in effect.

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A clear example to demonstrate this point

Skelmanthorpe Family Doctors, a NHS practice in Huddersfield, has just adopted a new additional telephone number (08443 878186) offering "advanced functions". It retains a "Basic Line" on 01484 766918.

The advanced functions are funded by a subsidy of around 4p per call minute which is paid through the surgery's network telephone service provider, Talk Talk, by whichever telephone company is used to make the call. This cost is invariably met by callers as a "Service Charge", with an additional "Access Charge". (See below examples of relative call costs.)

I have been assured by the local Primary Care Trust, NHS Kirklees (part of the Calderdale, Halifax and Kirklees Cluster, led by Mike Potts), that it has fully investigated this arrangement and it is deemed to be compliant with the PCT's interpretation of the relevant contractual requirements

I personally find Mr Potts (in common with many of his colleagues) to have made a rather perverse decision, given that every NHS GPs is under a contractual obligation not to “enter into, renew or extend a contract or other arrangement for telephone services unless it is satisfied that, having regard to the arrangement as a whole, persons will not pay more to make relevant calls to the practice than they would to make equivalent calls to a geographical number”.

The option to call an alternative “basic line”, offering inferior services, does not ensure that “persons will not pay more”. This arrangement explicitly presents the opportunity to “pay more” in order to gain “enhanced” access to NHS services.

An indication of how much more is paid to call the 084 number in question is given below. Unless it can be shown that "the arrangement as a whole" does not include any users of the commonly used tariffs listed, then the practice and the PCT may be seen to have been "satisfied" without reference to relevant information about the cost of telephone calls.

Alternatively, they may have deliberately set aside this requirement, which is intended to reinforce the current longstanding principles of the NHS. They may have chosen to adopt the wholly different principle that it is acceptable for patients to have a "Choice" of NHS service, differentiated by price.

It is also possible that, rather than checking actual call costs, they may have only consulted some highly opinionated marketing material, which is referenced on this page of the practice website. I have commented on two of the published items - “Supporting Surgery Line” and “… Enhanced Telephony”. If the "poster" which is illustrated is displayed in the surgery, then a number of items warrant investigation by the ASA.

Relative cost of calling the two numbers

The type ‘g11’ call incurs both a “Service Charge”, which is around 4p per minute in all cases, and an “Access Charge”, which is currently seen to be widely variable. These two elements are currently “bundled” together into a single rate. The cost of calling geographic numbers is also, although far less, variable. Because the relevant regulations refer only to the difference between the cost of calling the practice and the cost of an equivalent call to a geographic number (prohibiting cases where this is positive), only the differences need be shown.

The additional cost of calling 08443 878186 (call type ‘g11”), over that of calling 01484 766918 (for a call of the stated average duration of 3 minutes) is as follows:

£	BT (most popular call plan)	8.6p per minute
£	Talk Talk (most popular call plan)	10.6p per minute
£	Virgin Media (most popular Talk Plan)	13.3p per minute
£	Vodafone (pay monthly)	35.0p per minute

(There are many further and more extensive illustrations of the difference between the cost of a call to a geographic number as against various types of 084 number in the table - “NHS 084 numbers - Evidence of call charges”. This includes references to published tariffs in all cases, to support the information given above.)

NHS GPs which have long been using expensive numbers

The case highlighted above is notable because it has only recently arisen, with a new 084 number. This two-tier approach is also followed by many GPs who have been using expensive numbers for many years. In some cases they are explicitly directed to use the two-tier approach by the PCT.

Those who were using expensive numbers when the current contractual revisions were introduced in April 2010 are required to:
“take all reasonable steps … to ensure that, 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 geographical number”

The option to call an alternative “basic line”, offering inferior services, does not ensure that “persons will not pay more”. This arrangement explicitly presents the opportunity to “pay more” in order to gain “enhanced” access to NHS services.

All users of 084 telephone numbers are able to take the “step“ of migrating to the equivalent 034 number, so as to retain all of the “enhanced” features of their telephone service. All calls to all 03 numbers are charged at the same rate as calls to geographic number – thereby no caller would ever “pay more”. Because calls to 03 numbers do not incur a "Service Charge", migration would cause the subsidy of the costs of the practice telephone system to be lost.

I have not seen any evidence to show that any PCT thinks that it may not be “reasonable” for a NHS GP to meet the costs of its chosen telephone system in full. I have not seen any evidence to show that any provider of telephone service to GPs imposes penalty charges on those who choose to migrate during the term of an arrangement, so as to cause this step not to be “ reasonable”.

The telecoms industry in general thinks it “reasonable” to offer migration at any point during the term of an arrangement without penalty. I am aware that some have made unsubstantiated claims that one particular provider of GP telephone systems fails to adhere to this general industry policy. Until there is clear evidence of this unreasonable behaviour, one must assume that migration to the equivalent 034 number is a “reasonable step” open to NHS GP users of 084 numbers.

fair telecoms

The fair telecoms campaign fully supports the Ofcom proposals for the “Service Charge” and “Access Charge” elements, which comprise the cost of calling a 084 number to be “unbundled” so that they can each be seen separately.

Under these proposals, Skelmanthorpe Family Doctors would have to declare alongside 08443 878186 -
“A call to use the enhanced facilities will cost you 4p per minute, plus your phone company’s access charge”.

We believe that opening up the situation in this way will be welcomed by those who have difficulty in making their Service Charge clear, whilst the wide variety of Access Charges are hidden within bundled rates, as they are at present. We believe however that there is no essential reason to wait until this becomes a regulatory requirement. Because BT is presently prohibited from adding an Access Charge, the current level of the Service Charge is seen in the current BT tariff.

We encourage all those who benefit from Service Charges to start the process of declaring and justifying this charge now – noting that the same enhanced facilities can be provided using 03 numbers with no Service Charge. The action required of those who cannot justify a Service Charge is obvious and straightforward – if they require a non-geographic number, they must migrate to 03 without delay.

Any comments here that relate specifically to the political issue of retention of the NHS, with its very specific principles, are personal to David Hickson. If the NHS is to be replaced by an alternative service for England which permits charges to be imposed on those accessing health services, as they do so, then the fair telecoms campaign is only concerned that these charges be clearly declared.

It may be that the love affair between the people of England and the NHS has been shown not to have lasted up to its 64^th birthday, because COLLECTIVELY they think they do not need it and they are not prepared to feed it. If so, the fair telecoms campaign can only campaign for its new replacement to behave properly, by being totally open in the way that it takes money from them for its services.

The NHS Direct 084 telephone number rip-off is extended by at least six months

The delay in completing implementation of the 111 service for urgent access to NHS services (see DH news release) means that the withdrawal of the non-urgent health advice and information service provided by NHS Direct on 0845 46 47 will be delayed.

Although BT, which provides this number and benefits from a revenue share payment of around 2p per minute when it is called from non-BT services, includes 0845 calls in its call plans, most telephone call service providers (who have to pay this fee to BT) do not. Callers therefore pay up to 41p per minute to access the NHS Direct service.

Plans to migrate NHS Direct to 0345 46 47 were shelved when the 111 service was announced. Calls to offer the 0345 46 47 number to run in parallel (with minimal publicity so as to avoid confusion) have not been heeded. All calls to all 03 numbers are charged on the same terms as calls to geographic numbers (commonly free of charge).

Exactly the same situation applies to the many other 0845 numbers used by NHS and other public bodies - notably HMRC and the DWP agencies - all of which should have begun the move to 03 numbers many years ago. Adopting the 034 equivalent of a 084 number, a facility assured by Ofcom, provides a convenient and cost-effective way of making the transition, or even allowing for extended parallel operation.

The BMA, which has welcomed this delay, will no doubt be grateful for the assistance provided for non-urgent cases by NHS Direct during its industrial action. It continues to sanction an extension to the rip-off being practiced by its GP members using 0844 numbers (which are never included in Call Plans), by denying the fact that they too can migrate to 034 numbers for the remaining period of their use of systems which require non-geographic numbers from a particular provider.

Whilst the BMA continues to support what many see as simple greed by some of its members, getting their chosen telephone system paid for by their patients, its chances of securing support from the public for its industrial action in defence of their financial interests are significantly diminished.

(There is much to say about 111 itself!)

Who is undermining the NHS - GPs or a private sector businessman?

Despite being given 12 months in which to change their arrangements (from 1 April 2010), over 1,000 NHS GPs in England and Wales 2 continue to breach the terms of their contracts by using 084 telephone numbers. These numbers cost patients up to 41p per minute more to call, than for an equivalent call to a geographic number.

The obvious solution

The obvious way for those who wish, or are contractually obliged, to continue to take advantage of the “enhanced telephony” features available with non-geographic numbers would be to switch to the 034 equivalent of their 084 number - e.g. 0844 477 1799 becomes 0344 477 1799. All calls to all 03 numbers are charged at no more than the cost (if any) of an equivalent call to a geographic number and the cost of the “enhanced telephony” features is met by the user of the number, rather than callers.

The BMA advises it members 3 to claim that it would not be “reasonable” for them to vary their arrangements in this way, as is demanded by the terms of their contract with the NHS. As NHS GPs are provided with funding to meet the costs incurred in providing their NHS services, meeting the cost of their telephone system without subsidy at the expense of patients must surely be regarded as “reasonable”. (This is indeed what the overwhelming majority of NHS GPs do.)

The obstacle?

It is standard practice in the telecoms industry to permit migration from a 084 number to the equivalent 034 number at any point during the term of an arrangement, without penalty. For this variation not to be a “reasonable step” for a GP to take, the telephone service provider in question must therefore be deviating from this standard.

There are roughly 12,177 NHS GP surgeries in the UK. One provider of a Surgery telephone system using 084 numbers, offers migration to the equivalent 034 number 1, although not one of its customers is known to have taken up this offer. It also claims that 1 in 5 (20%) of these surgeries are using its system 1, whereas there are only 1,322 cases (11%) of surgeries using 084 numbers 2. Even if one allows for a little marketing hyperbole (however sickening), there can be no question that this company is primarily responsible for the numbers which the BMA claims cannot be “reasonably” changed to 034 - even though it cannot be responsible for as many as 184% of the cases! (My estimate is around 84%.)

The Chief Executive of this company was seen on television on Sunday evening, declaring that exaggerated claims made him feel sick (view this clip). He was also seen stating that command of the detail of one’s business is absolutely vital (view this clip). I was delighted to see him lay out his principles in this way.

My challenge

I have written to the businessman in question, asking him to confirm that his company does indeed allow its NHS GP customers to vary their arrangements on “reasonable” terms. I stress the need for this to be made clear to those who are responsible for enforcing compliance with the GP NHS contracts. Although I wrote before his TV appearance was broadcast, his broadcast comments present the hope of a swift and accurate response.

If such an assurance is provided, then attention must switch to the BMA. At a time when the BMA is seeking public support for its battle with the government over pension arrangements, it would not be well placed if it were seen to be arguing 3 that it was not reasonable for its members to meet the full cost of their chosen telephone systems, without the benefit of subsidy at the expense of patients.

The Department of Health has been involved in an extensive investigation of this matter, involving both the BMA and the provider of this surgery telephone system. In its recently published Further Guidance 4, it has however failed to make any explicit reference to the option of migration from 084 to 034 numbers.

I comment

If the principles of our beloved NHS are to be retained through the on-going reforms, it is vital that scams such as the improper use of 084 telephone numbers as a way of indirectly obtaining subsidy at the expense of patients are firmly and swiftly eradicated. Those who are opposed to these principles are entitled to express their views, however we need to know where they stand and what we can expect from those who administer the NHS and those who serve it.

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Notes

1.	The claim about the number of users of the system in question and the option to migrate to 034 numbers are found on this web page.
2.	My listing of cases from NHS sources can be found from this summary.
3.	The relevant BMA advice to its members is found, underlined beginning with the words “in cases such as this …”, on the second page of this Guidance.
4.	The Department of Health “Further Guidance” on this issue is published here.

NHS GPs are still adopting 084 telephone numbers, 2 years after this was prohibited

From: David Hickson of the Fair Telecoms Campaign - campaigner for the NHS

New regulations were added to the NHS GP contracts in April 2010, prohibiting use of telephone numbers which cost more than an equivalent call to a geographic number.

Except in a few cases, where callers incur sizeable "out of plan" penalty charges for daytime calls to geographic numbers, the 0844 numbers listed below are more expensive. This applies to callers from landlines, mobiles and payphones.

The higher cost is simply explained by the fact that all 084 numbers attract a "revenue share" (paid by the call originating telephone company to the benefit of the user of the number). The amount varies, but in the case of the numbers listed below, it is equivalent to a 4p per minute subsidy being paid by the caller to the person called.

On 27 March 2012, Secretary of State for Health Andrew Lansley confirmed in parliament:

"We have made it very clear that GPs should not be using 0844 numbers".

There are 1,247 surgeries still using these numbers in England and Wales note. They have failed to comply with their contracts, which demand, in effect, that they vary the terms of their arrangements by migrating to the equivalent 034 number. If they wish, they could cancel their existing arrangements altogether, but this is not demanded.

Of perhaps greater concern is the fact that the following NHS GP practices have newly adopted these expensive numbers in the last couple of months:

◊	Handsworth Medical Practice - Handsworth Avenue, Highams Park, London, E4 9PD - 0844 387 8525
◊	Chadwell Heath Health Centre - Ashton Gardens, Chadwell Heath, Romford, Essex RM6 6RT - 0844 387 8044
◊	Knowle House Surgery - 4 Meavy Way, Plymouth, Devon, PL5 3JB - 0844 387 8895
◊	Abbey Dale Medical Centre - 50 Common Edge Road, Blackpool, Lancashire, FY4 5AU - 0844 387 8685

Positions taken on this issue

(see Possible sources for further comment below)

•	Enforcement of the terms of the GP contracts is currently the responsibility of the (shortly to be abolished) Primary Care Trusts.
	Mr Lansley may care to explain how he believes that the ban may be enforced, and why enforcement is not being carried out.
•	The British Medical Association appears to support this form of co-payment - patients subsidising GPs' telephone systems.
	It claims that practices would not be able to afford the cost of their chosen telephone system without this additional financial support from patients.
•	The four numbers listed above in red are assigned to Talk Talk Business. It appears that they have been allocated to a reseller - NEG Ltd (part of the Daisy Group).
	NEG stoutly defends use of these revenue sharing numbers, especially for the provision of "socially important services".

As well as the practices themselves, it would be interesting to know which of the above believe that access to NHS services should continue to be "free at the point of need". It is fair for us to pay our telephone services providers for calls, but incurring a premium to subsidise the costs of the NHS provider is unacceptable and prohibited.

Some may suggest that in the new "patient-centred" English Health Service, patients should pay to subsidise the costs of a GP's telephone system. I campaign for the retention of the NHS in England.

I comment -

Mr Lansley's ongoing reforms are intended to remove central control from the NHS.

If he cannot ensure that its basic principles, which he affirms, are enforced, then we no longer have a NATIONAL Health Service worthy of the name.

See my proposed remedy below.

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Note: The contractual conditions referred to by Mr Lansley apply only to the NHS in England. Identical conditions apply in Wales, where they are enforced by the Local Health Boards.

Possible sources for further comment:

♦	The Department of Health. The Department will be able to clarify the terms of the relevant contractual requirements. Andrew Lansley's office will be able to confirm what he meant by "… should not be using …".
♦	The British Medical Association. Comment may be provided by Dr. Richard Vautrey - Deputy Chairman of the BMA General Practitioners Committee and partner in Meanwood Group Practice, Leeds (0844 477 1799). Each area is served by a Local Medical Committee, representing the interest of local GPs.
♦	Talk Talk. The numbers provided by NEG are on services provided by Talk Talk Business. Talk Talk will be happy to confirm that all of its direct clients are able to migrate from 084 to 034 numbers at any point during the term of their contract, without penalty. If this same facility is not withheld by NEG, then its NHS GP clients are able to utilise it so as to comply with their NHS contractual requirements at a cost which is not unreasonable.
	Talk Talk will also be able to confirm that its residential customers who use their landline for weekday daytime calls are advised to subscribe to its Talk UK Anytime tariff. This charges 13.1p + 6p per minute for calls to the (type "g11") 0844 numbers listed above, as against "zero" for a call of up to one hour to a geographic or 03 number. (Those who subscribe to its Talk UK Evenings and Weekends tariff are penalised for "out of plan" Weekday Daytime calls to geographic numbers at the rate of 13.1p + 7.95p per minute.)
♦	Daisy Group Plc - owners of NEG. Daisy Chief Executive, and "Apprentice" judge, Matt Riley, is ready to defend his company's role in pressing these numbers on GPs and to contradict the view of the Secretary of State. (See this BBC North West Tonight item from 2 August 2011.)
	Mr Riley seems not to understand how the industry works. His broadcast statement could be taken to suggest that Talk Talk, along with all other landline call providers, charge for 0844 calls at "local rates". Nobody has ever done this. Daisy itself charges 6.5p per minute for "type g11" 0844 calls, as against 2p per minute for "local, regional and national" calls (see Daisy Fixed Line Tariffs).
	When he says " we'd only charge a local rate call", Mr Riley fails to suggest under what circumstances Daisy would alter its present charging policy; he is certainly not referring to the situation as it exists.
	The BBC was wrong to suggest that Daisy is in any way a party to the contracts between its GP clients and the NHS. If GPs use information provided by Daisy, it is they who are fully responsible for the accuracy of that information.
♦	Primary Care Trusts. These are now managed on a "Clustered" basis by 50 bodies covering areas of England. Each of the Clusters appears to have adopted a slightly different policy regarding enforcement. In almost all cases this amounts to tolerance of this breach of the principles of the NHS.

My proposed remedy

Where the technical benefits available with "non-geographic" numbers are thought to be cost-effective, these can be provided using 03 numbers - for which calls are charged at the same rate (if any) as calls to geographic numbers in all cases.

03 numbers are not subject to revenue sharing, so GPs choosing to deploy the benefits obtained must meet the full cost of their telephone systems without the benefit of subsidy at the expense of their patients. GPs are funded, from our taxation, to provide NHS services. If they believe this funding to be inadequate, they can argue their case. Whilst the principles of the NHS remain in effect, they cannot be permitted to take money from patients.

For those currently using systems which rely on the features of non-geographic numbers, they must immediately migrate from 084 to the equivalent 034 number. A plan for this can be agreed by the parties. This could include a gesture on the part of Talk Talk Business to relieve some of the costs of using non-geographic numbers.

Silent Calls - Ofcom imposes penalty of £750,000 on HomeServe

From: David Hickson, of the Fair Telecoms Campaign - veteran Stop Silent Calls campaigner

Ofcom has today announced that it will finally use the increased powers granted by parliament in 2010.

For the first time, it will impose a serious penalty against a company found to be making Silent Calls - See Update note - 19 April 2012.

After nearly nine years of my campaigning on this topic, it could be that Ofcom has finally decided to use the powers which it has always held.

The detail of the scale and precise nature of the nuisance caused by HomeServe, so as to warrant a penalty of £750,000, is still unknown.

I fear that it may be no greater than that caused by many other companies who operate within the tolerance limits set by Ofcom -

•	Hanging up in silence is OK if you make enough calls that day on which you speak to someone.
•	Repeated Silent Calls are OK on successive days, but not on the same day.
•	Use of ineffective Answering Machine Detection equipment (which inevitably causes Silent Calls, on an unknown scale) is tolerated.

I comment -

If this penalty is deserved and is to be effective as a deterrent for others, then Ofcom must make the situation totally clear.

I believe that Ofcom must respond to the wishes of parliament, clearly declared in 2006 -

" we expect you to use your powers to eradicate the nuisance of Silent Calls".

This is not an issue of market regulation, requiring balance and tolerance, it is a case where Ofcom must simply prohibit unacceptable behaviour in the public interest.

(See my blogging "HomeServe and nPower - my response to Ofcom's persistent misuse of its persistent misuse powers")

Ofcom proposes a fairer system for telephone call charges

From: David Hickson of the Fair Telecoms Campaign

Ofcom proposals released today announce the end of the 084 telephone number "rip-off" practiced by many businesses and public bodies. (See Simplified call charges to help consumers.)

Ofcom also proposes to clear up the situation with calls to 080 numbers, so that the recipient pays the full cost, whether the call is made from a landline or a mobile.

As with calls to "Premium Rate Service" 087 and 09 numbers, all calls to 084 numbers include a cost which is passed on to the person receiving the call - a "Service Charge".

At present the charge is only regulated when the call is made using BT. The new proposals will cause the cost of all calls to 08, 09 and 118 numbers to be transparent to the caller in all cases - including the separate amount of the charge to the benefit of the person receiving the call.

This will have a radical effect on banks, insurance companies and others who use these numbers for "service" lines, at a charge to their benefit which is not presently being declared. Even more radical will be the need for public bodies, notably NHS providers but also HMRC and the DWP agencies such as JobCentres and the Pensions Service, who cannot charge for their services, to simply stop using these numbers.

Where necessary, they will have to switch to numbers from the 03 range, on which calls are charged at the same rate as call to "geographic" (01/02) numbers, with no revenue sharing permitted.

The proposals are detailed and complex, but the essential principles are solid.

If, for example, a GP were to continue using a 0844 number, its website and patient leaflet would have to include the advice:

"This call will cost you 5 pence per minute plus your phone company's access charge"

No provider of NHS services could do this! There are still over 1,000 NHS GP surgeries using these numbers.

When complete, this will represent a fulfilment of what I have been campaigning for over many years - most especially with relevance to the NHS. In conjunction with other campaigners I will be consolidating efforts to ensure that these changes are understood and fully implemented under the banner of the " Fair Telecoms Campaign".

The NHS Hospital Phone rip off continues, although with one less example

Aside from permitting the scandalous misuse of "personal numbers" for bedside phone services by appointed contractors, the NHS itself continues to use expensive 084 phone numbers (see details below). It also allows contracted GPs to do the same (see details below). An idea of the additional costs incurred is found from this table.

Following a public consultation in 2008/9, Directions from the Department of Health gave NHS bodies 12 months from 22 December 2009 in which to cease use of numbers that were more expensive than the cost of an equivalent call to a geographic number. The same requirement was imposed on contracted GPs with effect from 1 April 2010.

The possibility of future changes by Ofcom makes it impossible for the regulations to directly specify particular numbers or ranges. Under current conditions however,
the undeniable meaning of these regulations is a ban on use of all 084 numbers.

The hospitals and other bodies listed below continue to fail to comply, however I am pleased that one has just announced that it will now start to comply, over 15 months late.

The Switch

From 2 April 2012, the North East London NHS Foundation Trust will switch from 084 numbers onto 03 numbers. (see this press release)

All 03 numbers are guaranteed to cost no more than the cost of a call to a "geographic" 01 or 02 number. This applies to landlines, mobiles and payphones and covers the terms of call inclusive packages and bundles.

The switch from 084 to 03 is what many NHS Bodies and GPs should be doing, as this enables them to continue to take advantage of the features of what is known as "Enhanced Telephony", but without the cost being passed on to the caller. With 084 numbers telephone companies often take advantage of the situation by adding their own excessive premium as well. This is also prohibited on 03 numbers.

Some NHS Bodies have already done the switch, including NHS Blood and Transplant (0300 123 23 23) and the NHS Choose and Book Appointments Line (0345 60 88888).

The same is happening (again too slowly) throughout the public sector. A former hard case, the DLVA, has switched (0300 790 680x). Even HMRC has started the process with the Tax Credits helpline (0345 300 3900), although it retains all its other numbers on 0845 without offering the 0345 equivalents as an alternative.

The three Gloucestershire bodies listed below are intending to do the same switch within the next six months (up to 21 months late).

---

NHS Bodies that still fail to comply

The following list shows direct providers of NHS services still failing to comply with the effective ban on use of 084 numbers more than 15 months after the 12 month period of grace granted to them has expired.

In those cases marked with a "*" an alternative geographic number is published, however the 084 number remains in use and is sometimes even mistakenly commended as being cheaper to call.

Those shown in italics are known to have firm plans to comply.

The NHS Direct NHS Trust is exempted from the regulations. 0345 46 47 has been specifically set up for use as an alternative to 0845 46 47, but it refuses to make this available.

LONDON
Barking, Havering and Redbridge Hospitals NHS Trust	0845 130 4204 *
Barnet and Chase Farm Hospitals NHS Trust	0845 111 4000 *
Basildon & Thurrock University Hospitals NHS Foundation Trust	0845 155 3111 *
North East London NHS Foundation Trust	0844 600 1200
University College London Hospitals NHS Foundation Trust	0845 155 5000 *
NORTH OF ENGLAND
Bradford and Airedale Teaching Primary Care Trust	0845 111 5000 *
Calderdale and Huddersfield NHS Foundation Trust	0844 8110101 *
Mid Yorkshire Hospitals NHS Trust	0844 811 8110 *
Northumbria Healthcare NHS Trust	0844 811 8111
Northumberland, Tyne and Wear NHS Trust	0844 811 5522
MIDLANDS AND EAST
North Staffordshire Primary Care Trust	0845 602 6772
Luton and Dunstable Hospital NHS Foundation Trust	0845 127 0 127
Spire Parkway Hospital, Solihull (providing NHS services)	0845 850 1451
SOUTH OF ENGLAND
Gloucestershire Primary Care Trust	08454 221500
Gloucestershire Hospitals NHS Foundation Trust	08454 222 222
Gloucestershire Care Services (currently a NHS body)	08456 598100
Maidstone and Tunbridge Wells NHS Trust	0845 155 1000
Plymouth Hospitals NHS Trust	0845 155 8155 *
NATIONAL
Blackpool Teaching Hospitals NHS Foundation Trust (National Artificial Eye Service)	0845 60 50 561
Marie Stopes International (many centres - providing NHS services)	0845 300 3740

GPs that fail to comply

I publish a database, derived from NHS Choices for England, of those NHS GPs which use 084 numbers. This was recently presented as evidence in support of a parliamentary debate on the subject (see Hansard).

In responding to the debate, Simon Burns MP, Minister of State (Health Services), gave a strong indication that he does not share my view that our NHS is a universal service in which use of 084 telephone numbers is unacceptable. He referred to my published list of cases - http://tiny.cc/Burnslist and the associated table of call costs for leading providers of telephone call services (http://tiny.cc/GP084Costs) as follows:

"People say that there are 1,300 GP practices that charge more than they should; what they do not say is which practices they are, and they do not provide the robust proof that overcharging is happening …

"GP practices are adhering to the regulations and not costing patients more than they should. The PCTs vigorously enforce the regulations."

In my briefing for the debate, I referred to there being "nearly 1,300 surgeries", not "1,300 practices". I have never alleged that telephone companies are “overcharging”, they bill in accordance with their published tariffs.

By alleging that NHS GPs are allowed to levy any charge on NHS patients, Mr Burns was getting ahead of himself, as this aspect of the government's "NHS reform" plans has not yet even been published.

NHS Bodies forced to re-assess their policy on tolerating use of 084 telephone numbers

Pressure from campaigners has finally produced a positive response from the Department of Health to the widespread failure to implement the ban on use of expensive telephone numbers in the NHS, which was first announced on 14 September 2009.

Yesterday the Department of Health issued Further Guidance on The use of 084 numbers in the NHS. This was addressed to NHS bodies which themselves use these numbers and to the Primary Care Trusts which are required to enforce the contractual conditions imposed on GPs.

There are currently over 1,000 GP practices using 084 numbers and many NHS bodies also persist in subsidising the cost of their telephone systems at the expense of patients and other callers. All 084 numbers provide a subsidy to the user at the expense of callers.

This only applies to England, although the devolved governments would do well to address this problem also - especially as they have no current plans to replace the NHS with an alternative system.

Details of all the GPs and the costs of calling them are published in my database.

Some of the key NHS bodies are listed here.

The New Guidance

It is important to understand that the "Further Guidance" does not in any way change the formal position. It simply restates what is contained in the relevant Directions and regulations and confirms the understanding which all should have derived from this. Sadly, many have been misled as a result of efforts to maintain this abuse of the principles of the NHS.

The key points made are as follows:

•	To ensure that the requirements may be sustained through forthcoming changes to telephone regulations, there is no explicit permission or prohibition of any particular group of telephone numbers. Determination of what is prohibited is based on meeting the following requirement:
	"Persons should not be charged more to contact an NHS body or Primary Medical Service contractor, than they would if they were calling a geographic number in the same manner."
•	Evidence to enable this determination should be based upon:
	ο	Cost-per-call information from telephony providers.
	ο	Information provided by patients showing the cost of calling as against the cost they incur when calling a geographic number from the same phone.
•	This specifically rejects suggestions that it is appropriate to make the determination in other ways.
	ο	It is not acceptable to use only opinions offered by interested parties, e.g. the provider of telephone service to the GP or NHS Body. An "assurance" that a provider believes that their number should be cheap to call is of no value whatsoever.
	ο	Alleged "industry standard" methods for presenting a minimum call cost, with the proviso that it may be greater are of no use in making a determination.
		It is made clear that the determination must be made on consideration of "the arrangement as a whole", not just the circumstances of a particular group of callers. It is stated:

The conclusion

If one considers the reality of the current situation with telephone tariffs and the variety of tariffs that are used, there is no 084 number that may presently be used in compliance with the regulations and Directions. – See my table of relative costs.

All users of 084 numbers, who are bound to retain use of a non-geographic number from a particular provider due to a contract, or who wish to deploy the benefits of a non-geographic number, are free to migrate to the equivalent 034 number. Calls to 03 numbers are guaranteed to be charged are no greater rate than that of calling a geographic number from the same mobile, landline or payphone, including through the terms of call inclusive packages. All known providers of telephone service to 084-using NHS bodies and NHS GPs are known to offer this facility. Other more appropriate remedies may be available, but this is known to be available in every case.

03 numbers do not provide the financial subsidy (at the expense of callers) that is enjoyed by users of 084 numbers. The consequential increased cost would return that NHS provider to the same situation as other similar providers, who meet their costs from the NHS funding provided for the purpose. There is no way that such a situation could be deemed to be "unreasonable".

There have been suggestions that some providers impose unreasonable costs or restrictions on migration. If this is so, then evidence of this irregular business practice must be provided, so that these providers can be seen to be engaged in unnecessarily intervening in the politics of the NHS.

My comment

I look forward to hearing that NHS Chief Executives have indeed revised their policies after “considering the implications of this further guidance”, as demanded by the Department of Health. The original measures set deadlines of Christmas 2010 for NHS Bodies and 1 April 2011 for GPs to cease using 084 numbers.

Public support for the principles of the NHS, allegedly also seen from GPs and the government, should help to ensure that we are now finally able to get rid of this blight on the NHS.

Health Services Minister, Simon Burns, challenged on NHS GP charges

Please see my open message to Simon Burns, Minister of State (Health Services), published at this link.

This enables the issue of GPs using expensive telephone numbers to be seen in the context of the government's intentions for health service provision in England.

In a recent debate in parliament, Mr Burns made the bizarre assertion that NHS GPs are allowed to charge patients for access to NHS services.

He accused me, and others, of alleging that they were charging more than they "should".

I most certainly alleged that nearly 1,300 surgeries are listing on NHS Choices as having 084 telephone numbers, which means that the cost of their telephone system is subsidised.

This subsidy is generally provided by their patients and other callers, who pay their respective telephone companies more to call these numbers than they would to make an equivalent call to a geographic number. This fact places the GPs in breach of their NHS contracts.

If Mr Burns and his colleagues succeed in introducing a "patient focussed" health service to replace the NHS in England, then it will be natural for patients to expect to get "value for money" from their healthcare providers, as they exercise choice as consumers.

For the time being however we have a "National" Health Service, funded by taxation, and contracted providers are not permitted to make any charge whatsoever, as services are accessed "free at the point of need". I am fighting to defend and retain this.

Mr Burns also dismissed my evidence because it identified only individual GP surgeries, as shown on NHS Choices, rather than the practices which operate the surgeries.

This petty-minded wriggling approach provides a most clear indication that, despite some warm words, Burns is simply not interested in whether or not the principles of the NHS are being upheld.

I hope that those who are concerned about these matters will recognise this precise, concrete evidence of the way in which Health Ministers are currently approaching their duties.

Please contact me for further information and comment.

Parliament to debate 'Use of 084 telephone numbers in the NHS'

Bob Ainsworth MP for Coventry North East will be leading a debate on this topic in Westminster Hall, at 12:30 next Tuesday, 24 January. A government minister will reply.

This will cover the fact that nearly 1,300 NHS GP surgeries in England continue to use these expensive numbers, despite revisions to their contracts which should have brought this to an end by 1 April 2011.

I hope that Mr Ainsworth, and other MPs who may contribute, will stress the need for the government to make the situation clear to all, and in particular to ensure that officers of the Primary Care Trusts fulfil their duties properly by enforcing the terms of the contracts on their GPs.

The key points are as follows:

•	As telephone tariffs stand, there is no 084 number that can be used in the NHS.
	The NHS is universal in its scope and available to all on equal terms. There will always be some who will pay more to call 084 numbers. (See current tariff examples.)
•	GPs tied into long term telephone system arrangements must still comply.
	If necessary, they can change to the 034 equivalent of their 084 number.
	This would mean that they will henceforward incur the full cost of their chosen telephone system, without the benefit of subsidy at the expense of patients.
	The revised contracts demand that they "take reasonable steps" to ensure that patients do not pay more - this step must be considered to be "reasonable".
	Migration to 03 is an option offered by all telephone service providers, including that responsible for most of these cases. (See this note.)
•	The terms of the GP contracts are clear, but are made confusing by those who oppose their intention and purpose.
	Local NHS officers, who have to enforce the terms of the contracts, have not been able to overcome resistance from those who argue that patients should pay some of the costs incurred by GPs and other NHS providers. This is the privatisation of the NHS, which many fear that the government is prepared to tolerate.
	If the government truly believes in the principles of the NHS, now and for the future, then it must intervene to ensure that these principles are fully respected - if necessary, by strong enforcement action against those who continue to breach them.

GPs may be quick to point out that some NHS hospitals and other NHS bodies also use these numbers, in breach of equivalent Directions issued to them. I argue that these bodies are not only in breach, but are making enforcement of similar requirements unnecessarily difficult. (See the list in my blogging - "NHS Bodies in Breach ...".)

GPs using expensive telephone numbers - the "escape route" is revealed by NEG

Many NHS GPs use expensive 084x telephone numbers as a means of subsidising the cost of their telephone system at the expense of patients. (See my database of cases and a map.) Since April 2011, those in England and Wales have been doing so in breach of their NHS contracts.

Many claim that use of a 084 number is essential to support use of a telephone system called "Surgery Line", provided by NEG, part of The Daisy Group. I am now delighted to be able to report that NEG now confirms on its website - Different Number Ranges - that this is untrue.

It is particularly significant that NEG confirms that Surgery Line may be used with 034 numbers.

Calls to all 03 numbers are charged at no more than the equivalent cost of a call to a geographic number, from all types of phone and including the terms of packages.

034 numbers are however special. They are only available to existing users of 084 numbers for the purpose of migration to the equivalent number, e.g. 0844 477 1799 to 0344 477 1799.

This means that:

all existing users of "Surgery Line" can take advantage of NEG's offer for them to migrate to 034 numbers,
to comply with their NHS contracts, whilst retaining all the benefits of the Surgery Line system.

It has been claimed that NEG imposes contract termination penalties on its customers if they cease use of their 084 number. As it now clearly offers use of numbers from a "migration only" range, it would be absurd for it to penalise those who wish to take advantage of this offer.

It must be noted that those who migrate to 034 will be incurring the full cost of the "Surgery Line" system, as they lose the benefit of subsidy at the expense of patients, which funds the system when a 084 number is used. It is however perfectly normal for NHS GPs to meet the costs of running their surgeries using only the NHS funding provided for the purpose. It would be absurd for them to pretend that meeting the cost of their chosen telephone system is "unreasonable".

I am delighted that Daisy Group, the owner of NEG, has finally made this very positive move.

I hope that this news will be swiftly communicated to:

•    all "Surgery Line" users

•    their patients, and

•    the local NHS bodies who enforce GPs compliance with their NHS contracts.

This option of migration has always been available, but it is now directly offered to Surgery Line users.

I also hope that the BMA, which has shown great interest in this topic, will now advise its members that this option of migration is now explicitly made available, rather than urging them to claim that the cost which would be incurred is "unreasonable".