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Tuesday, 15 February 2011

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

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

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

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

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

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

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

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

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

Calls from BT landlines - why they are different

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

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

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

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

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

The big mistake

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

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

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

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

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

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

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

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

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

My message to Mr Burns

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

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

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

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

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

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