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Wednesday, 26 August 2009

Tax credits boss orders: Keep callers on the line

My involvement in the issue of revenue sharing telephone numbers is not restricted to the NHS. I offer the following observations on a closely related issue. These words are derived from the text of an email message to relevant parties.

I was very disappointed to read this article - Tax credits boss orders: Keep callers on the line, from the Mail on Sunday.

The source for the story probably fails to appreciate that HMRC does not gain proportionately from the charges incurred by callers if call durations increase. Whether a caller is paying nothing extra (e.g. on a BT call plan) or at the 40p per minute rate applied by some mobile companies makes no difference. The revenue share that is received by its telephone service provider does increase at a relatively flat rate.

When looking at the overall cost / benefit implications of any procedural change, I would imagine that whatever benefit is achieved on account of the use of revenue sharing numbers would be relatively insignificant when set against, for example, personnel costs per minute. I am not therefore drawn to accept the conspiracy “profit” theory suggested by the article.

The point about the impact on callers is however sound. If any change in policy has increased the duration of calls (especially if this is time when there is no conversation taking place), then the cost to the caller must be a major factor in consideration of whether it is appropriate.

I note that Linda Maslen, who is quoted in the article, has worked with the Contact Council of the Cabinet Office on guidance for Contact Centre Accreditation. Not only would this lead one to assume that the demands of the “public mandate” requirement for accreditation would preclude introducing wasted “air-time” for the caller, but also that she was fully in touch with the activities of the Council, through Chris Hopson, its HMRC representative.

For this reason it is astonishing, as well as deeply disappointing to hear her quoted, or permitting a colleague, to say “HMRC do not receive any payments from any service provider in respect of 0845 numbers.” Whatever the degree of factual accuracy of the careful wording of this statement, the briefing from the Contact Council - Clarification Statement on Telephone Number Ranges - should have put an end to this type of misleading nonsense being put about.

The Contact Council briefing makes it clear that "For 0845 numbers, the charge made to the caller is either retained by the TCP or shared with the department receiving the call. All departments are required to know who retains this additional revenue and to ensure transparency to the public." (I sincerely hope that the HMRC statement is misleading, because if HMRC receives no benefit then this is even worse; see below.)

A well briefed reporter followed up on the initial statement by inviting comment on what HMRC allowed Cable and Wireless to do with the additional revenue that results from the decision to use revenue sharing, rather than 03, numbers. (This decision has been in effect for the last two years, since 03 numbers came into use.) Whereas NHS Direct has confirmed that the extra revenue is all retained by its provider and the DWP confirms that it is offset against other charges, HMRC pleads commercial confidentiality – a plea which would presumably cover any form of impropriety.

It may be fair to conclude that if direct payments were being received then commercial confidentiality would have prevented this from being admitted. If considerations of commercial confidentiality do not prevent HMRC from confirming no direct receipt of payments, one may assume that indirect receipt of benefit would also have been denied if it were not occurring.

By demanding transparency, the Contact Council is working to ensure that every case where a) public sector bodies take subsidy from telephone callers is properly explained and justified. It follows that the situation must be promptly corrected where no adequate justification can be offered. Those who use revenue sharing numbers with the consequent additional expense to callers, whilst b) allowing telephone companies to retain all the benefit must be immediately called to account for this gross abuse and neglect of duty. The Contact Council is currently collecting evidence from all departments and has a duty to ensure that any serious evidence of the latter is dealt with appropriately.

I note the strongly worded comments of John Mann MP, "This is a way of sneakily milking the poorest at a time when they are at their most vulnerable." Mr Mann reminds us that parliament and Ministers have a role in this matter. Whilst the former cases (a) may have to be considered by the relevant Departmental Select Committee (The Treasury Select Committee in the case) and the Public Administration Select Committee (in general), the latter (b) must be referred immediately to the NAO and the Committee of Public Accounts. None can be allowed to sit in limbo between the two.

We must end the double-speak on this issue. If use of revenue sharing telephone numbers is justifiable, then let it be justified. If not, then let it cease, as swiftly as is possible. (Referring to the perverse and wholly atypical BT tariffs and saying “we receive no income” is not a justification.)

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