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Monday, 11 April 2011

084 calls more expensive than geographic calls for NHS patients

The following table (updated to reflect prices as at 28 April 2011) is intended to demonstrate why use of 0845 and 0844 (type 'g6') telephone numbers cannot possibly be compliant with the requirement not to use numbers that are more expensive than an equivalent call to a geographic number.

Any NHS GP or NHS body claiming that special (unpublished) terms apply to calls to their number, should be able to provide details of the binding arrangement they have negotiated with the 200 or so registered providers of telephone call services in the UK.

Anyone claiming to have received an "assurance" from some interested party that contradicts the information given below may wish to question the competence and motivation behind such an "assurance". (The Department of Health has shown itself to be highly incompetent in addressing the detail of telephone charges; but then it makes no claim to the contrary, and will not engage in such points of detail having clearly specified the principles which others must apply.)

The Table - showing 084 calls to be more expensive than geographic calls for NHS patients

The rates for weekday daytime calls are shown. Each published tariff table may be consulted by following the link indicated.

I have selected these well known examples of tariffs to represent the worst and best case scenarios; others from each class would tend to fall between those given. I will be happy to add any other examples deemed relevant, on request.

Most 0844 numbers in use (all of these) are of type 'g6'. The tariff links allow the rate applicable to any number to be found.

ProviderPublished Tariff TablePackageRates
(Weekday Daytime Call)
5 Minute call additional cost
Geographic Rate (01/02/03)08450844 (g6)08450844 (g6)
BTclick to viewAnytimeinclusiveinclusive12.5p + 5.105 ppm39p
Weekends12.5p + 7.6 ppm12.5p + 2.042 ppm12.5p + 5.105 ppm
Talk Talkclick to viewAnytimeinclusiveinclusive11.14p + 5.11 ppm37p
click to viewEvenings and Weekends11.14p + 6.54 ppm11.14p + 6.54 ppm11.14p + 5.11 ppm
Virgin Mediaclick to viewUnlimitedinclusive12.24p + 10.22 ppm12.24p + 10.41 ppm64p65p
Weekends12.24p + 8.68 ppm12.24p + 10.22 ppm12.24p + 10.41 ppm8p9p
Orangeclick to viewPay Monthlyinclusive20.4 ppm12.3 ppm£1.02£0.62
click to viewPAYG20 ppm40 ppm£1.00
Vodafoneclick to viewPay Monthlyinclusive21 ppm£1.05
click to viewPAYG21 ppm25 ppm£0.20
T-Mobileclick to viewPay Monthlyinclusive41 ppm£2.05
click to viewPAYG30 ppm40 ppm£0.50
BTclick to viewPublic Payphone40p + 20p per 30 minutes40p + 20p per 1 minute£0.80

(See notes on the highlighted exceptions)

The relevance of this information

NHS Bodies and GPs are now prohibited from using non-geographic numbers that cost callers more than the cost of an equivalent call to a geographic number.

The NHS is a universal service available to all on the same terms. Even if some pay a high price to call a geographic number (e.g. on a PAYG mobile) they are still entitled not to have to pay at an even higher rate to contact the NHS. If some may pay a "Penalty Charge" for calling a Geographic number outside the terms of their Call Plan, which is greater than the regulated charge for calling a 084 number, this does nothing to affect the status of that 084 number.

The only way that NHS GPs and NHS bodies can ensure that they are compliant is by using a geographic number. If the greater cost of having a non-geographic number is justified by the service benefits delivered, it must be from the 03 range, where these greater costs are met by the NHS service provider, not by callers, who pay no more than the cost of a call to a geographic number.

Patients do not meet the costs of providing NHS services, as they access them (notwithstanding regulated specific charges set by parliament, and subject to proper exemptions).

The Department of Health has suggested that if there were a 084 number that was not more expensive to call than a geographic number, then it could be used. This utterly foolish statement could be said to be true in theory, however there is no such 084 number.

Over recent years there has been speculation that Ofcom could have been intending to remove revenue sharing from 0845 numbers, so that users rather than callers would have to meet the additional costs involved. Ofcom has now clearly indicated that it has no longer has any intention of moving in that direction. It is therefore reasonable to say that not only is the Department of Health certainly out of step with current reality, it has little chance of being shown to have been ahead of the game.

(N.B. If anyone can provide evidence of a 084 number that is not more expensive for NHS patients to call than geographic numbers, then please contact me. I would be delighted to reconsider my position in the light of such evidence.)

Explanation of the anomalous cases

084 calls are more expensive because the originating telephone company has to pass on an additional fee to the telephone company with whom the call is terminated. This may be used to subsidise the cost of the telephone service provided to the recipient, or in addition to provide a "revenue share". The maximum amount permitted with 084 numbers was set some time ago at 5p per minute, including VAT at 17.5% - this is the rate which applies to 0844 type 'g6'.

I have included and highlighted some unusual and exceptional cases where geographic calls are not cheaper. If these are used as if they were representative of the general situation, a highly misleading impression may be created. I do not seek to deny that these odd cases exist, however they in situations where the geographic number is being called outside the period covered by the relevant Call Plan.

They arise from the unique regulation of BT, which is prohibited from adding its own charge to the rate for calls to 084 numbers. BT customers pay only the "Service Charge" that is passed on to the call recipient, whereas customers of all other telephone companies typically pay an "Access Charge" as well. (The BT call setup fee is another item which is neither one nor the other.) Some of those who originate residential calls over BT lines, e.g. Talk Talk, attempt to mirror the BT tariff structure.

Because BT makes no money on calls to 084 numbers it is able to include 0845 calls in packages without any severe impact on the cost of the packages. The much higher levels of "Service Charge" on 0844 calls makes it impossible for BT to offer a competitively priced package that would include these also.

To reflect a "Call Plan" based approach, and to encourage customers to subscribe to the most appropriate plan, BT imposes what can only be seen as "Penalty Charges" for calls to Geographic Rate numbers outside the period covered by the selected Call Plan. (These rates have been increasing at over 30% per annum for the last few years.)

BT cannot adjust its rates for calls to 084 numbers, only the associated call setup fee. The "Penalty Rate" for daytime geographic calls overtook the fixed rate for the most expensive 0844 calls in October 2009. It has now overtaken some of the rates for "Premium Rate Service" 0871/2/3 calls.

Same may suggest that the standard rate for a 5 minute daytime geographic call from BT is 12.5p + (5 x 7.6 ppm) = 51p, i.e. more than 10p per minute. My only response to such a suggestion would be to point out that the rate for a weekday daytime call for someone who has chosen the weekends only Call Plan cannot fairly be described as "standard".

The "standard" BT charge for a call to a Geographic number from a landline is ZERO. There are penalties for calls that exceed one hour, or if made outside the period covered by the selected Call Plan.

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