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Tuesday, 5 January 2010

Advice to NHS Bodies 1 - Introduction and Summary

Advice to NHS Bodies concerning the cost of telephone calls

1 - Introduction and Summary

In support of the Directions to NHS bodies concerning the cost of telephone calls issued by the Department of Health on 21 December 2009, I offer some supportive advice.

The "Dear Colleague" letter accompanying the Directions makes it clear that these directions do not explicitly represent a prohibition on use of 084x numbers. Each NHS body is left to draw its own conclusions about which "contact telephone numbers have the effect of the patient paying a premium above the cost of a call to a geographical number". Given that telephone tariffs are set nationally, this means that the same work has to be done time and time again.

To perhaps help avoid some unnecessary effort and possible error I offer this advice to all NHS bodies. My authority to do so derives from many months of engagement in the issue and appropriate research and study. I must urge verification of all that I say with Ofcom and, as necessary, with all of the 200 or so registered providers of telephone service in the UK.

PLEASE ADVISE ME OF ANY ERRORS in the general comments I make or the detailed information I provide, as I seek to be wholly objective and would wish to immediately correct any false or misleading information.

The advice offered

Apart from the comments made below, I present this advice in two separate publications.

Firstly, I offer some general comments on a number of relevant issues.

These are intended to help correct some common false assumptions and misunderstandings.

Secondly, I address what is demanded of NHS bodies by the Directions.

The determination demanded by the DoH Directions requires knowledge of which telephone tariffs apply to patients who may call numbers used in the delivery of NHS services. Most tariffs pass on the cost of the revenue sharing associated with all 084x numbers to callers, thereby making these calls more expensive. There are however cases where calls to geographic numbers are subject to a greater premium charge (e.g. the penalty charge imposed for calling outside the time period during which an inclusive package is in effect), thereby exceptionally making an equivalent geographic call more expensive.

To comply with the Directions it would only be possible to use a 084x number if it could be established that the only tariffs applying to patients likely to call it were those which had this perverse effect in place.

To help with this determination, I therefore present lists of published current residential telephone tariffs classified according to the relative cost of weekday daytime calls to relevant types of number. If any patient could perhaps call under the terms of a tariff on the first of these lists then 084x numbers may not be used in the delivery of NHS services.


It may be noted that this first list list includes the tariff for BT Public Payphones, all tariffs offered by Virgin Media and all the Contract and PAYG tariffs offered by the major mobile providers.

As the inevitable conclusion would therefore appear to be that 084x numbers cannot be used in the provision of NHS services, it is perhaps strange that the Department of Health was unable to come to this conclusion itself and act accordingly, thereby saving a lot of possibly unnecessary work.

I must therefore urge anyone who can offer an alternative conclusion to contact me and point out the possible flaws in my information and thinking. Given the amount of time that the DoH has dedicated to this issue and the amount of good advice that it has received in the process, it is difficult to believe that it could have got things so wrong.

I would be delighted to hear of a situation where a NHS body has found that it can comply with the Directions and continue to use a 084x number.

(I have advised of this publication in a message published here)

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