After a 3½ month consultation, a 6½ month delay, a confusing and misleading announcement on 14 September
and a further 3 month delay ...
the Department of Health yesterday issued the following directions:
Directions to NHS Bodies concerning the cost of telephone calls 2009
These directions fail to protect the principles of the NHS. They explicitly permit the continuing use of revenue sharing 084 telephone numbers, which cause patients to pay (indirectly) for access to NHS services.
Patients who call these numbers are subject to a premium charge, necessarily imposed by their telephone service provider in order to recover the money paid over in revenue share.
This truth remains, notwithstanding the fact that regulation, cross subsidy and other factors sometimes lead to the perverse situation where an equivalent call to a geographic number (not subject to revenue sharing) costs more. The payment by the patient may be hidden in a package subscription, or a cheap rate, and that received by the NHS provider may be concealed within a discounted price for telephone services, but the flow of money between the two is always in effect when a “revenue sharing” number is used. All 084 numbers are “revenue sharing”.
These directions totally miss this fundamental point by inviting providers to consider whether “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 geographic number.”
The “persons” will be subject to a wide variety of telephone tariffs.
For the principles of the NHS to be protected, a revenue sharing number could not be used unless EVERY CALLER was somehow protected from bearing the cost of the revenue share that is paid to the benefit of the NHS provider.
As may be seen from the information which follows, it is highly unlikely that any NHS provider would only be serving those who benefitted from this protection.
What are NHS Trusts being asked to do?
“Having regard to the arrangement as a whole
” at the very least requires them to have comprehensive knowledge of the general characteristics of the telephone tariffs to which all possible patient callers will have subscribed - I address this in the grouped table below.
A more measured consideration would require knowledge of the precise detail of the cost differentials for the respective tariffs, along with the average call durations for callers from each. This is made more ridiculous by the fact that all forthcoming changes would also need to be considered.
The whole concept is however simply wrong in principle. The idea of balancing out discounts obtained by some patients against costs incurred by others has no place in the NHS. This type of consumerist nonsense is totally unacceptable in the context of any public service.
Who pays less and who pays more?
For these purposes, callers may be broken into the following general groups:
A) BT customers outside the terms of an inclusive package
(some other landline providers copy this tariff).
For this group the rates for calling 084 numbers are set at a low level by regulation. Rates for calling geographic numbers are not regulated, and are subject to a “penalty” rate to encourage subscription to inclusive call plans (this rate is steadily increasing, at 30% per annum).
The current differences are 0.25 (0844) and 3.25 (0845) pence per minute against geographic numbers.
B) BT customers within the terms of an inclusive package
(some other landline providers copy this tariff).
Calls to 0845, but not 0844, numbers are treated as inclusive, i.e. at the same rate as calls to geographic numbers.
In the worst case the difference is 0 vs. 9p + 5p per minute.
C) Virginmedia customers
Whether or not an inclusive package is in effect only affects the degree of difference. In the worst case it is zero vs. 10p plus 10p per minute.
D) Most customers using mobile telephones
(PAYG or contract).
In the worst case it is zero vs. 40p per minute.
E) Subscribers to some selected mobile contracts
F) Users of public payphones
The determination of whether calls to a 084 number are more expensive than to a geographic number may be made for each group as follows:
It is important to note that BT (Group A) is the exception. It is common to quote BT rates with the qualification that others may vary. This table shows how this approach has things the wrong way around.
1. A list of 164 of the numbers covered by these directions is found here
on my NHS.Patient website
2. The NHS Direct NHS Trust is totally excluded from this requirement.
An exemption for the 0845 4647 Health Advice and Information Line had already been announced. There is however no good reason why 0345 4647 could not be used alongside as a lightly publicised alternative for the remaining life of this service.
The Choose and Book Appointments Line 0845 608 8888, as well as other 0845 numbers used by NHS Direct (68 of them) are also excluded from these directions.
3. There is no clarification of whether NHS Foundation Trusts are covered by these directions; one might fear that they are not.
4. GPs will be covered by forthcoming amendments to their respective contracts. It is likely that these will be expressed in similar terms. It must be noted that NEG Ltd provider of the “Surgery Line” system used by perhaps 1,000 GPs in England claims that calls to its 0844 telephone numbers are no more expensive than those to geographic numbers. Its GP clients are likely to rest on this advice.
5. There is no provision for other contracted providers of NHS services, e.g. dentists, pharmacists and ophthalmologists, to be covered by similar requirements.
6. The devolved national governments are likely to follow this lead, as the same situation exists in Scotland, Wales and Northern Ireland.
I will return to this issue in conjunction with MPs, PCTs and other NHS Trusts (and with formal confirmation of the charging information from Ofcom), once all relevant personnel have returned from the Christmas and New Year Holiday.