David Hickson's Media Releases

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Thursday, 24 September 2009

NHS Trusts funded by patients

This message is addressed to those listed on the web page - NHS bodies using 084x (copies to selected media)

On 14 September 2009, the Department of Health announced NHS TO BAN PREMIUM RATE CHARGES. I quote from this announcement.

"Phone numbers that charge the public or patients a premium rate to contact the NHS are to be banned in England, Health Minister Mike O'Brien announced today"

This was the long awaited outcome of a consultation that closed on 31 March 2009.

Implementation of the ban is demanded by over 40,000 citizens who have signed a petition to the Prime Minister that will be presented for a response on 28 November.

"The ban means that GPs and other NHS organisations remain free to use 084 numbers, providing patients are not charged more than a local rate number."

For the time being this qualification effectively excludes all 084 numbers. There is no expectation that every one of the over 200 telephone companies that provide service in the UK will increase the price of calls to local numbers for all customers, so that it exceeds that imposed when they incur the additional cost of revenue sharing on 084 numbers.

As a single example, the call charges I currently incur as a NHS patient, during the daytime, showing the pence per minute rate and set-up / connection fee, are as follows:

BT (Unlimited anytime)
Virgin Media (Talk Weekends)
Orange (Racoon)
A local number
inclusive (0p)
inclusive (0p)
0845 number
9.79p + 6.85ppm
0844 number
(call type g6 / PG6)
8p + 4.894ppm
8.8p + 6.84ppm
(I provide links to the published tariff documents to enable verification and an opportunity to review the situation for those on other tariffs.)

It is highly likely that many patients who call you are (like myself) subject to tariffs that cause them to incur premium rate charges. For many the premium is much greater, and not all have the choice that I enjoy when at home. To escape the terms of the ban, I understand that you would have to somehow show that not one of your patients would incur a premium rate charge at any time.

"The ban will be enforced through proposed changes to the GP contract (in consultation with the British Medical Association's GP Committee), and the issuing of Directions to NHS PCTs and Trusts."

I understand that no Enforcement Directions to NHS PCTs or Trusts have had to be issued as yet, and so I trust that you have already privately indicated your intention to comply. Will you please advise when you will be complying with the ban, by ceasing use of the 084x number, so as to avoid enforcement action having to be taken against you. It would be a disgrace if bodies that proudly subscribe to the principles of the NHS had to be reminded of their duty to patients by enforcement action. Whilst the changes to the GP contract are subject to a lengthy process, there is no indication of when the Department will begin issuing Enforcement Directions to PCTs and Trusts that fail to comply.

Please advise if the ban will cause you to withdraw the telephone access currently provided by the 084 number, because the financial subsidy currently being indirectly obtained from patients cannot be replaced.

Alternatively, please let me know what alternative arrangements are in place so that patients may continue to access your services by telephone without incurring premium rate charges. In most cases this is simply achieved by publishing the geographic number to which calls are re-directed. (I accept that this simple option is not available in cases where complex algorithms are invariably involved in routing calls to various call centres. For such cases, a swift migration to the equivalent 034x number is the most convenient option, unless alternative arrangements have been made.)

"NHS Direct will retain its current 084 number [0845 4647]"

Whilst this singular number will, exceptionally, never be subject to the ban, most other 084x numbers will doubtless also remain in use for a period. There is no reason why NHS Direct (like all other NHS providers) could not introduce a temporary alternative during this period to enable patients to avoid premium rate charges. Having two numbers in use concurrently for the same purpose is never desirable, but in the particular circumstances of a transition it represents an essential expedient measure. Any alternative number for access to the NHS Direct telephone advice service would need to published properly, but not in a manner that would cause confusion or undermine the service in any way. 0345 4647 is known to be already setup and available for use.

NHS Direct may prefer to continue to get the full benefit of the £1 million pounds per annum that it currently receives as subsidy (or donates to BT Global Services, as has been alleged) due to the revenue share contributions from callers' telephone companies. Failing to take the obvious measure of offering the 0345 4647 alternative (in a suitable manner) would undermine the consistency of the ban, which is vital for it to be accepted by GPs and other NHS bodies that might demand special treatment. Such failure would also leave the NHS Direct Trust and / or BT Global Services open to accusations of deliberately and unnecessarily profiteering at the expense of NHS patients. Please let me know what will / should be done about this.

Please contact me with your answers and if I can help in any way.

Friday, 18 September 2009


It is now time for politicians of all the major parties to be honest and admit that after 61 years they are prepared to formally sacrifice the principles of the NHS for the sake of consumerism.

I note the comments of Andy Burnham in his speech to the King's Fund and related commentary. Mr Burnham's speech includes the extraordinary phrase, for which I cannot find a proper context, "pay more for better patient experiences". I do not believe he meant that government spending would inevitably increase if experiences improved, or that having to spend less would be expected to make things worse for patients. His focus was on a "people-centred NHS" being upgraded from "good" to "great".

I read this after becoming very familiar with the following parts of the announcement about premium rate call charges on Monday.

"The ban on the use of numbers charging patients a premium rate to call NHS services will allow a marketplace to evolve where 084 numbers compete alongside 01, 02 and 03 numbers, but where patients will pay no more than the cost of a local call. The ban means that GPs and other NHS organisations remain free to use 084 numbers."

"The ban will be enforced through proposed changes to the GP contract".

Notwithstanding other less oblique comments in the announcement, it must be understood that it is telephone companies, not the DH or GPs, who determine the cost of a call to any particular type of number. As they compete with one another, they have to decide how to fund the additional cost they incur in providing the revenue share that benefits all users of 084 numbers. One option for them is to do as BT will be doing from 1 October, increasing the price of a non-inclusive call to a local number (by 33% in 12 months) so that it becomes greater than the most expensive type of 084 number (the type used by GPs). Maybe GPs will be able to point to this isolated and atypical example to prove compliance with their contract. (This perverse effect arises because some of BT's prices are still regulated, whereas others are not.)

Those who subscribe to BT packages and all customers of every other telephone company will continue to pay a premium to call 084 numbers. There is nothing that GPs can do about that.

Health policy now clearly seeks for "choices" to be exercised by "consumers" in a "market". If there is no price distinction between the cost of calling different GP's telephone numbers, then there is no "market". It cannot be fair "competition" for some GPs to benefit from the extra funding derived from a revenue share on their 084 telephone numbers, whilst others (on 01/02/03) do not, unless the patient has to set this off against some negative consideration. If it is considered acceptable for some patients to pay a premium rate to call their GP because that premium is used to pay for a telephone system or some other feature of the surgery (e.g. a smart waiting room or a smiling receptionist) that may offer "a better experience" than may have been enjoyed previously, then my arguments about "free at the point of need" can be seen as outdated and irrelevant.

I have always argued; if it is acceptable for NHS providers to indirectly charge for telephone calls when delivering or providing access to NHS treatment, then how will we be able to stop providers using other, perhaps less indirect, ways of imposing charges for NHS services.

If getting patients to pay for NHS services is the only way that the NHS spending can be maintained whilst dealing with the National Debt, then now is the time to be honest about this difficult choice that has been made in order to achieve cuts. Alternatively, this may be seen as desirable policy in its own right - there is no better way of "empowering" patients than by giving them direct control of the purse strings.

The issue of premium rate call charges may not itself be central to the debate on public spending and the future of the NHS, however it is the subject of the second most supported e-petition on the number 10 website, with over 40,000 signatures. A lot of people value the principles of the NHS above their own direct personal interests. Such a level of support must show that this is about more than what is for many just a few pence on the phone bill.

By proposing that a "ban" be implemented through contractual arrangements with those who are totally unable to have any influence on what is allegedly being banned, the government is clearly doing nothing at all about this issue. It may not be the biggest issue in itself, however it does provide a clear indication of what happens when the principles of the NHS are tested – that is why I got involved in this matter. If "competition" and "consumer choice" in "markets" is now seen to be more important than "free at the point of need" here, then why not elsewhere?

Monday, 14 September 2009


After reviewing the full material and some of the reactions, I have:

A sense of déjà vu

On 24 February 2005, The Department of Health announced:


The only special service numbers the NHS will be able to use in future are freephone numbers or those that offer patients a guaranteed low rate call, such as '0845' or '0844' numbers.

Neither “0800” (from mobiles), “0845” nor “0844” numbers have ever offered patients a guaranteed low rate call, since the introduction of competition in the provision of telephone services. There was no such guarantee then, there is none today and there can be none in the future, unless existing competition law is changed. There is no regulation of the charges for calling these numbers (other than of the per minute element of some of rates charged by BT).

On 14 September 2009, The Department of Health announced:


It has however shown that it still does not know how this may be achieved:

The Department does not intend to ban the 084 number range; rather, it intends to amend legislation and issue supporting guidance to the NHS to ensure that patients contacting the NHS do not pay more than the equivalent cost of a call to a geographic number, regardless of the number they call.”

It is the telephone companies we use to call the NHS who set the charge rate for calling particular types of number. They normally charge a premium for 084 numbers because a defined premium is paid on to the “terminating” telephone company; this is known as “revenue sharing”. The premium may be used to discount the cost of the facilities provided or passed on directly to the user of the number.

If the Department of Health wants all telephone companies to fund this premium through package fees or premium charges on non-inclusive calls to ordinary numbers (like BT does), then it needs to talk to them. It will fall foul of EU competition law if it tries to fix rates by legislation. There is no point in asking, or trying to compel, individual Hospitals and GPs to fix retail telephone call charges from each of over 200 providers, whilst protecting their source of subsidy; their work is in providing NHS healthcare, funded exclusively by taxation.

Dr Richard Vautrey, deputy chairman of the British Medical Association’s GPs committee, is quoted as saying:

we’re pleased that the phone companies who supply these lines to practices have agreed to ensure that their tariffs are in line with local charges”.

Dr Vautrey’s practice (like most GPs with revenue sharing numbers) is supplied by the business-to-business division of Talk Talk (Opal Telecom). Residential Talk Talk customers pay over 32p for a five minute call to the 0844 477xxxx number, from which the practice earns money to subsidise the cost of its phone system. Talk Talk customers enjoy free local calls and pay for inclusive calls to 0845 numbers through increased package charges, in line with BT. Neither Dr Vautrey nor Talk Talk have any control over what the other 200 telephone operators charge, or which of these his patients use.

Dr Vautrey goes on to say that:

the GPC would like to see more phone companies include 084 numbers in the comprehensive call packages they offer customers

He seems to be unaware of the fact that no landline or mobile telephone company includes 0844 numbers (as used by most practices that benefit from revenue sharing) in a comprehensive call package.

Some have been misled by the announcement to believe that:

Patients will still dial numbers starting 084 to get through to their surgery but will only pay for the cost of a local call.”

Even Dr Vautrey appears to believe this complete nonsense:

Combining the benefits of 084 numbers with an assurance that they won’t cost more than a local phone call is the best solution for patients and practices.”

This seems to suggest that the BMA thinks that the Department of Health has done the fix, whereas the Department of Health thinks that GPs will be able to do it.

In its response to the consultation, the Department of Health places great emphasis on the benefits of non-geographic numbers. These are equally available on 03 and 08 numbers.

Ofcom is quoted as saying:

We recently introduced 03 numbers, where calls are charged at standard national rates as an alternative to more expensive 08 numbers, and we are encouraging public bodies to use them.”

I am quoted as saying:

The government has failed to realise that the only way to ensure people only pay a normal charge is by prohibiting numbers that might charge more, the only way to do it is to prohibit 084 numbers."

I could not have put it better.

The government got this wrong in 2005 and is showing every sign of having repeated, rather than corrected, its mistake (perhaps by again taking poor advice from an interested party).

I want the Minister to be able to deliver his reassurance, as this is essential to re-affirm the principles of the NHS. He has failed to indicate how this may be achieved.


This is the full briefing and commentary issued subject to the embargo on publication prior to 00:01 on Monday 14 September of the Department of Health media release. I was working from an embargoed copy of what was subsequently published.

From: David Hickson – campaigner for the NHS



This is a great victory for campaigners, as the principle has been ceded and action to apply it finally promised, for the first time. The suggestions about implementation create some cause for concern, as they appear not to recognise the implications of the primary announcement.

It is vital that the Minister is asked to confirm that he truly means what he says and that it applies now, rather than being an aspiration for what may be achieved in many years time. As such confirmation would render many of the other comments meaningless, if that it is confirmed we can describe this as a ban on use of revenue sharing 084 numbers in the NHS.


Three cheers for our beloved NHS
Simple Points of Concern
The Heavy Stuff
Specifying the "ban"
Further action for campaigners
GPs and Hospitals that do not use 084 or revenue sharing numbers
Further information and comment

Three cheers for our beloved NHS

This is what I have been campaigning for over the last two years. I cannot but celebrate this announcement and congratulate the Department for finally recognising the need to act to re-affirm the principles of the NHS in this way. It is "our NHS", of which governments in power from time to time are only the temporary custodians.

"Free at the point of need" means that NHS services are delivered without charge to the patient by the service provider. Fees set by the NHS (approved by parliament and subject to exemptions) and charges for non-NHS services are a different matter. Elimination of any indirect charge, e.g. through use of a revenue sharing number for which any patient's telephone company imposes a premium rate, is vital and long overdue.

We will always incur incidental third party costs in accessing public services, for example, the bus or taxi fare or the cost of parking in a public car park when attending an appointment. It is not unreasonable to incur the cost imposed by our chosen telephone service provider for an ordinary call when contacting the NHS by telephone. When the ban is delivered, this will be "free at the point of need".

When the Department of Health is able to deliver the promised reassurance 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", I will be totally content. I have been assured that this applies to all NHS patients, not just some subjective interpretation of the concept of "patients in general".

As things stand, this will therefore (in effect, if not by intention) have to represent a ban both on revenue sharing and use of 084 numbers. It will not be possible to provide this reassurance whilst revenue sharing and use of 084 numbers continue.

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In addition to the 3,000 who responded to the Department of Health consultation, one must mention the 40,000 citizens who have signed the e-petition to the Prime Minister on this very subject. Their demand that the promised reassurance be delivered remains in place and the Prime Minister must respond to this at the end of November in the light of what is seen to be being delivered at that time. Guy Mayhew, the originator of this petition is deserving of particular credit, and also has a good personal story to tell.

Those who may have doubts about the reassurance offered by Mike O'Brien should be encouraged to sign the petition now.

There are also many other campaigners, some of whom have been working on this issue for much longer than myself, who should be credited. I have the names and contact details of those who have worked closely with me, however I know that there are many others.

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Some aspects of what is proposed as the method of implementation are worthy of positive comment.

Addressing the issue from the point of principle, rather than by specifically prohibiting use of particular types of telephone number, i.e.  084, represents a necessary correction to the mistake that was made when addressing this issue four years ago.

There is some good sense shown in expressing reluctance to prohibit NHS providers from gaining the benefit of revenue sharing when this can be done at no cost to callers, i.e. where the benefit to call recipients is funded purely out of excess profits earned by telephone companies.

We will only know whether this ban will work in practice when we see the detail of how the reassurance is going to be delivered. We will join the Minister in checking that the action taken ensures delivery of his reassurance. Department of Health officials have been engaged continually on this issue since an evidence gathering exercise was begun in January 2008. They have benefitted from extensive briefings from contributors to the public consultation and in other ways. One must expect that they therefore have gained a full appreciation of all of the issues and been able to apply it. There should be very little left to do.

BUT, the comments accompanying the announcement suggest otherwise.

I would be delighted to conclude at this point, however I continue in order to address matters of concern that are raised in the notes accompanying the basic statement in the news release.

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Simple Points of Concern

  • The National Health Service does actually include services that are provided nationally. These would appear to fall outside the terms of the quoted reassurance as it refers only to "their local GP or hospital". The reassurance would also appear to exclude other local NHS services provided and commissioned by PCTs, such as Dentistry and Pharmacy.
  • It has already been announced that the NHS Direct telephone advice service (but not the other services provided by the NHS Direct Trust) will be retaining its 084 number - 0845 4647. In order to meet the reassurance offered by the Minister, it will be necessary for the alternative 0345 4647 to be brought into use in parallel so that all patients may access this service at a cost that is "no more expensive than if they had dialled a normal landline number".
We await news of the new number for the "Choose and Book" appointments line to replace 0845 608 8888. I have published a list of 084 numbers used by NHS bodies.

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The Heavy Stuff

click here to skip this section
To support my further detailed remarks, I refer to useful and relevant publications by Ofcom and the Contact Council, which explain how revenue sharing applies on all 084 numbers. I have confirmed that the named senior representatives of these bodies will be happy to assist with verification of the comments that I make.

Officials from the Department of Health have declined my offer to discuss what appears to be confused thinking. I have been thanked for the contributions I have made and told that their work is done! I am therefore left with the task of trying to make some sense of what has been published. I regret that I cannot explain it, but only react.
  • One must initially express surprise that it has apparently not been recognised that use of 084 / revenue sharing numbers currently causes most callers to incur a premium charge. Regardless of how the intentions and method of implementation are described, the stated reassurance cannot be delivered without effectively banning their use, although this seems not to be understood.
  • It would take a considerable amount of time (several years), and Ofcom intervention of an unprecedented scale, in pursuit of new objectives and possibly requiring amendments to EU competition law, for "a marketplace to evolve where 084 numbers compete alongside 01, 02 and 03 numbers, but where patients will pay no more than the cost of a local call". That is certainly not what is in place today, as telephone companies quite properly pass on the costs of revenue sharing to their customers, in one way or another.
  • If "the ban on the use of numbers charging patients a premium rate to call NHS services" is introduced before such an unexpected, perverse and probably undesirable change occurs, all use of 084 numbers would be covered by such a ban.
  • The only way in which one could see this perverse approach to pricing been achieved is if all telephone companies that are not regulated in their charges for revenue sharing numbers follow the example of BT, the only one that is. With effect from 1 October, BT will increase its unregulated charge for ordinary calls to a level above that set for revenue sharing calls by regulation. BT customers with an inclusive call plan in effect are not affected by this change - they are now compelled to pay for some types of revenue sharing calls as part of their package fee and always pay for others only if they make them, at the unchanged regulated rate. This is obviously greater than the zero charge for inclusive calls to ordinary landline numbers.
  • There is a disturbing suggestion of conditionality in the statement, "GPs and other NHS organisations remain free to use 084 numbers, providing patients are not charged more than a local rate number". One must hope that this is not evidence of the sadly common misconception that those acquiring a telephone number can determine the rate that is charged for calling it. This is completely untrue. The only influence one may have is by selection of a particular type of number, in the knowledge of the rates currently being charged for calling numbers of that type by the various providers.
It is vital that changes to the GMS contract do not attempt to place contractors under a general obligation regarding the level of cost incurred in calling them. This is something over which they have no control and so it would be ineffective and unenforceable. (I am reluctant to suggest that the Department of Health may have been tricked into attempting an ineffective method of implementing the ban, however it has been seen to have been deceived previously – in 2005 it believed that 084 numbers "offer patients a guaranteed low call rate"; that was untrue then and will remain so .)

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Specifying the "ban"

In determining the necessary changes to the GMS contract and the terms of directions to PCTs and Trusts it will be necessary to offer more clarity than is offered in this statement about precisely what is being banned. Terms such as "premium rate", "a normal landline number", "the cost of a local call", "local rate", "national charge rate", "normal geographical", "cost of calling an 01 or 02 number", are all used regarding call costs that will be relevant to the specification of the ban. One could believe that so many different terms have not been used for the purpose of providing clarity.

Anyone with an understanding of the UK telephone system and its charges knows that one must try to avoid unnecessary reference to "local rate", or even "local call" in the context of charging, at any cost. (I will not address this horribly difficult topic any further here, but I must urge those reporting these matters to avoid these terms.)

The simplest and most accurate way to express the requirement necessary to meet the Minister's desired reassurance would be to state that the cost of accessing NHS services by telephone must be no greater than the cost of a national UK call. This means the cost of a call to any number beginning 01 / 02 / 03.

Because there is no general regulation of the charges for calling any other type of number available to NHS providers, there can be no assurance that the cost of a call would not be greater. Indeed there is no such type (including 0800) that meets this condition at present. There is no expectation of any further new cost-regulated type of number being introduced and recent experience with 0870 has shown that Ofcom is unable to regulate the cost of calling existing ranges.

With all other options effectively needing to be banned, one may as well stipulate that only 01 / 02 / 03 numbers may be used. That is certainly what must be delivered at present to achieve the intended effect of the announcement. Yes – it could have been this simple!

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Further action for campaigners

The best way for someone to ensure that the cost of calling a GP or Hospital is no more expensive than if they had dialled a normal landline number is by dialling a normal landline number.
Many revenue sharing numbers simply re-direct calls to a normal landline number – others use more sophisticated call delivery mechanisms. Despite attempts to suggest otherwise, because the potential does exist, in many cases all of the advanced features offered are actually provided locally (by equipment at the hospital or surgery), and are therefore fully accessible by calling that normal number. Those who feel entitled to benefit from the premium charge paid to call the revenue sharing number will aim to conceal the normal number, so that callers cannot avoid paying the premium and thereby deny them that benefit.

Now that the Minister of State has offered a reassurance that the cost of calls to GPs and Hospitals will be no more expensive than if a normal landline number had been dialled, there would appear to be no good reason why the normal numbers should be concealed in such cases.

I do not support the idea of a two-tier NHS, with advanced telephone features funded by revenue sharing on numbers that attract a premium charge and only basic features on a normal landline number. I totally reject the idea that patients should have the "choice" of which number to call, depending on what they are prepared to pay, as this would be a fundamental breach of the principles of the NHS. Whatever may be the benefits of "choice", there is no place for this type of consumerism in the NHS.

I would not wish for anyone to disrupt the provision of NHS services or show any discourtesy towards staff of the NHS or its contractors. It is also important that revisions to the GMS contract are dealt with properly, although I think it fair to refer to clause 483 of the existing GMS contract.

I am however keen for the Minister to be supported in the prompt delivery of his reassurance. Given these qualifications, if anything can be done to hasten and ensure the swift implementation of the "ban" then I cannot oppose it. In most cases this could be quickly and easily achieved by the replacement of 084 numbers with the equivalent 034 number in every case where a non-geographic number provided benefits in respect of the service provided, or where a contract for provision of telephone service from Talk Talk has to be honoured.

http://www.saynoto0870.com/ collects and displays the normal numbers that may be used as alternatives to all types of expensive numbers. If any NHS provider makes the relevant number available, directly or indirectly, then this could be added to those already appearing there. It would obviously be preferable if these numbers were published in the normal way. One may however expect that many will keen for the Minister's reassurance to be delivered more quickly than if the processes associated with the long-delayed implementation of the ban were left to take their natural course.

Dave Lindsay of saynoto0870 has already issued a briefing on this topic and will, I am sure, be ready to help with further information.

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GPs and Hospitals that do not use 084 or revenue sharing numbers

We must remember that most GPs and Hospitals do not obtain any subsidy from callers in their provision of telephone facilities and would share the view that this means of funding is wholly unacceptable.

Many would endorse the view of the Head of the General Practice that I attend who would "not touch one of these numbers with a bargepole". The BMA appears to only represent the views of a minority of its members.

The University of Leicester Hospitals recently introduced a 084 number, but on belatedly recognising the implications for its patients reversed this decision within a few days and adopted a 03 number instead.
NHS Blood and Transplant recently changed from using 084 numbers to 03. There are many other similar examples, which demonstrate that 03 numbers are appropriate and that it is only a minority of NHS providers who need to be reminded of the need to respect the principles of the NHS.

It is unfortunate and perhaps disturbing that this has had to be achieved through a ban. Even if the attempts at a ban are found to be ineffective as a means of compulsion, it may be hoped that many NHS providers will give up their 084 numbers in advance of, or even without, it being implemented.

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Further information and comment

There is plenty of information about this topic on my campaign resource website. I have also recently started blogging on relevant topics and publishing circulated material.

In addition to the contacts included in the cc: of this email, I also have the details of many other campaigners and interested people.

As this release is necessarily rather lengthy in order to provide a comprehensive briefing whilst under the terms of an embargo, I will happy to provide exclusive brief comments to meet particular requirements and address any questions. (In due course I will publish this document and relevant comments on the detailed issues separately.)

I will comment further in the light of any further developments and on seeing the formal response to the consultation when it is published.

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I am now free to publish my comments on the announcement entitled:


Evidence needs to be taken from Ofcom and from telephone service providers to support the assertions that I make.

The minister declares a desire 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”.

That is something I must applaud and celebrate.

The consultation to which he is responding was on a proposal to “prohibit the use of 084 numbers in the NHS”.

Such a prohibition would be necessary for this reassurance to be delivered, whereas the announcement states that use of 084 numbers will not be prohibited in the NHS.

The cost of placing a call to any 084 number is, and will remain, more expensive than to a normal landline number. This is generally reflecting in a higher charge to the caller. Nothing that can be done by the Department of Health, any single GP, or even Ofcom (under existing competition law) will change that fact.

All users of 084 numbers benefit in some way from revenue sharing. Some telephone companies collect this money from callers indirectly and impose premiums when charging for normal calls outside the terms of a package. Others, quite reasonably, collect it through premium charges to those who call these numbers, thereby excluding them from packages.

A detailed analysis of the proposal and other comments will follow.

The Minister must confirm that he stands by his assurance and will not allow it to be undermined by ineffective implementation of the ban.

Friday, 11 September 2009

Expecting an imminent announcement by the Department of Health

Pending an imminent announcement of the outcome of the consultation by the Department of Health into a proposal to ban use of revenue sharing 084 telephone numbers in the NHS, I have circulated the following comments indicating my hopes and expectations for this announcement.

I must express my hope that it will properly addresses the issue covered in my comments - NHS GPs using 0844 numbers can change to 0344 [1]. The other key issue to which I have repeatedly referred is the need for NHS Direct, unable at this time to comply with a ban, to immediately introduce 0345 4647 as an alternative working in parallel with 0845 4647 [2].

I will react as best I can to whatever is said, hoping to do so in a spirit of congratulation and rejoicing at a reaffirmation of the principles of the NHS, as they apply to all providers of NHS services. We will await a definition of what is understood to be “NHS services” and how far any ban will extend to those who also provide other services, such as NHS Hospitals, GPs, Dentists and Pharmacies [3].

A ban on the use of 084 telephone numbers must address the simple fact of revenue sharing, which applies to them all. It must not be confused by reference to the often perverse means by which telephone companies raise the money to provide the revenue share through complex tariff structures. Any repetition of the concept of “the cost of a local call”, as used in current guidance, would cause any regulatory prohibition to be utterly worthless as this has no meaning in general terms.

The relative costs of different types of calls vary between providers, between different tariffs and even between times of the week and day. With reference to one widely used tariff, calling any revenue sharing number would be cheaper for some than a local call for some during weekday daytimes, but not in the evening or at weekends, yet for others it would be invariably much more expensive. On some tariffs, subscribers benefit from free calls to local numbers at all times, but may need to access NHS services outside their “local” telephone charging area. I do hope that we are not going to have to get into this type of nonsense [4].

Given that the Department of Health has been working on this issue for over 18 months, since an “evidence gathering” exercise began in January 2008, there can be no excuse for not getting all of the detail right. One must hope that the four numbered specific matters to which I refer above have not been overlooked, and if so, that they will be addressed before a public statement is published.

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