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Monday, 16 May 2011

Comments on my campaigning efforts

The thread of comments published below were originally added to "Resistance to the ban on use of 084 numbers by NHS GPs". As a discussion on much wider issues has developed they have been moved here - exactly as originally published.

Forward links to this item are being created.

Further contributions to the discussion or any comments relevant to this broadly focussed item, are warmly welcomed. All submitted comments are subject to moderation prior to publication.

This is a private blog, not a public forum, however I welcome public discussion of the issues. There is no easy way for me to prove this, as unsupportive comment that I choose not to publish here will not be published here! Furthermore, anyone who seeks to draw attention to any improper "censorship" should not expect such comments to be published here!

David Hickson

29 June 2011 (the date of the item to which the comments were originally added is preserved.)


  1. Good morning David

    I have been reading your views with interest and have a couple of questions, which I am sure you won't mind answering..

    1. Have you ever worked in the NHS, OFCOM or the Department of Health and, if so, over what time period and in what capacity?

    2. Have you ever held any face to face meetings or discussions with the relevant policy officials in the Department of Health? (not including e-mail correspondence?)

    Best regards

    Interested observer....

  2. In response to the request for information from "interested observer".

    All relevant personal interests (past and present) have been declared and relevant reportable contacts revealed. I claim no authority for any statements or opinions other than that implicit in the way that comments are presented. My only right to express these views is as a NHS Patient; a joint owner of "our NHS", along with all other citizens of the UK.

    I always invite any challenge to the underlying factual basis for my comments, and repeat that invitation again. They should stand alone in objective terms, regardless of any subjective authority that I may hold.

    I am prepared to engage in personal correspondence following contact by email.

  3. Thank you David. I take from your comments that you have never worked in the NHS, never worked in the Department of Health, never worked for Ofcom and never had any face to face meetings with any of the relevant policy officials responsible for this area of policy

    Given that you have no experience of the reality of working in the NHS nor development of the policy area, I think that people will find it difficult to understand why you claim to know more about this policy area than the Department of Health and the BMA, whom you frequently accuse of not understanding the principles of the NHS or how it works.

    I have no desire to enter into personal correspondence with you, but in the interests of clarity thought it might be useful for visitors to your website and blog to be aware of the limitations of your experience in this area.

    Interested observer

  4. Thanks to "interested observer" for confirming my point about whether "authority" is important in discussion of important issues in a democracy.

    For some of us the issues are more important than the identity of the individual expressing their views. Perhaps the implied challenge to my right to comment should have been preceded by a reference to just how an alleged failure to understand "the principles of the NHS or how it works" causes my remarks to be flawed.

    I will be happy to respond, as necessary, to any such challenge, even if this demands that my comments require further qualification. In particular, I would be delighted to comment on any exposition about how use of revenue sharing telephone numbers is seen by the DH and the BMA as being compatible with the principles of the NHS.

    (N.B. I refer to the UK NHS, not the English NHS as proposed as a "reformed" version. I do hope that for the sake of clarity this will be properly named as the EHS.)

  5. DEAR ALL,
    firstly i would like to say that what ever David is doing i call it a social work. Mr observer to know the facts of law and to comment on them is a big deal. i guess David has come across them because he is much committed to it. being a law student myself i didnt know what is going on in NHS and what is NHS policy on surgery. but i did not believe on a single word what ever david has said and observe but rather i have gone through all documents which david has mentioned and i have read them spending my whole 2 days and reading piece by piece.
    i came to conclusion that what David has put forward is an excellent work and does show his commitment and hard work. to be honest i would have never known if i wasnt aware of his blog.

    Dear observer can i ask you a question why do some one need experience in order to criticize their policies???? i would say if we all start reading the relative law, it will be quiet evident what is wrong and what is right.
    and also i would like to see a GP to come here and answer this.

    well done DAVID carry on.

  6. Dear Law Student

    Thank you for your comments. As you study, or indeed go on to practice, the law, I think you will find that there are frequently examples of different interpretations (in particular in the healthcare sphere) between those who make the law and try to plan for their reasonable interpretation (on behalf of those who will be required to implement the law) and single issue campaigners who seek to interpret the law on their own behalf with no specialist or practitioner knowledge of the complexities of the issues involved, but who provide easy fodder for journalists looking for an easy "NHS knocking" story.

    This is by no means confined to telephony...it has been a constant feature of the NHS for decades. For example, a classic technique is for big Pharma companies seeking to provoke local journalists into running stories to bully a local PCT or surgery into allowing their new miracle drug to be prescribed. I am sure, as you study the law in greater depth, you will learn the tried and tested techniques.

    What happens is that the local journalists file their stories, they go into the archives and they become received wisdom with no justification. The campaigner then points other journalists to the original articles as "proof" of what they say and the whole thing becomes a vicious circle. It gives spurious legitimacy to a core argument which is simply flawed and wrong.

    I am in no doubt that David is an assiduous and able internet campaigner who genuinely believes in his argument, but he simply has his facts wrong, has never been involved in the detailed policy debate on this issue, and has no track record or experience in delivering healthcare or devising and implementing healthcare policy.

    Meanwhile, David's activities mean that many hard-working and dedicated NHS practice managers who wish to spend their time organising their practices to deliver excellent service to patients are forced instead to spend their time dealing with repeated inaccurate enquiries from local journalists wound up by David or worries from patients on the basis of mainly Daily Mail articles also generated on the back of inaccurate claims made by David.

    If we ran the NHS on the basis of the claims of single issue campaigners and reports in the Daily Mail, the NHS would grind to a halt in a matter of days.

    In any other sphere of life, this would be considered to be bullying and the individual concerned would be asked to decease. But there is no legal sanction against an internet campaigner bullying local NHS employees other than an appeal to the campaigner's better judgement.

    I have not come across a single NHS Primary Care employee who regards David's arguments - and their repetition by journalists - with anything other than irritation (at the mildest) and outright anger, intimidation and bullying.

    I would invite David to consider this.

    Interested Observer

  7. For those who wish to comment without giving their full identity, adopting a nickname adds some degree of order to the process.

    The "help" on comments points out that the "Name/URL" option allows for this - the URL is optional. The "help" also states that 'Anonymous comments are unlikely to be published'. Adding a nickname as a "signature" to the text of the comment may allow publication.

    An anonymous comment has been withheld from publication.

  8. Interested Observer,

    Maybe you should identify where David is inaccurate.

    Try and be constructive.

  9. I notice that David has suddenly become more circumspect in allowing free comments on this space and that a comment (possibly non-supportive of David's views) from another commentator has been censored by David, whereas a supportive comment has been allowed through...

    Maybe this is David realising he is losing the argument?

    Interested Observer

  10. I am still waiting for a possible argument about matters which I am alleged to have got wrong! I would be delighted to host a discussion of the issues. Exchanges of personal opinions about my integrity and other qualities are not arguments.

    This is private blog not a public forum. I have always exercised complete editorial control over which submitted comments are published here - every comment is reviewed before publication, at my absolute discretion. Only those who submit comments that are not published can know what degree of circumspection I show.

    The term "censorship" implies intervention in the public sphere, and so cannot apply in this context, which, although publicly visible, is privately controlled. I do not seek to pretend that I have an "open house" policy.

    It is only generally known that a submitted comment was not published because I posted a comment to announce the fact and give the reason.

    We can only offer views on who is winning an argument after an argument has commenced. I await a challenge to any of my statements.

    (N.B. The foot of this particular blog item may not be the most suitable location for the extended discussion that may continue, as it addresses wider issues than the content of this single item. I am presently considering options for moving these exchanges, exactly as published, elsewhere. If such a move occurs, then a link will remain to ensure continuity.)

  11. Unfortunately the process used to transfer comments from one item to another misplaced a comment added by David Hickson timestamped as 28 June 2011 at 01:23. This was in response to that submitted by Anonymous timestamped as 27 June 2011 18:42, exactly as above.

    As there has been no direct response to my message, I see no problem in re-inserted it here slightly out of sequence. It follows ...

  12. Interested Observer

    I fully understand the general points you make and recognise the damage that can be done by ill considered media coverage of stories.

    If I were making inaccurate claims then I would indeed be guilty of behaviour that we both despise. I do not believe that any comment I make is inaccurate. I would indeed be delighted to consider any case where it is believed that I have mis-briefed journalists. My media releases are published in a separate blog - http://www.davidhicksonmedia.blogspot.com/.

    I will be happy to provide supportive evidence for any statement that is believed to be untrue. It could be that I am mistaken on some points and have made errors on points of fine detail. I am always grateful to those who can point these out to me. The essence of all I have to say on these matters is however solid.

    Bullying is the wrong word. We previously agreed that, unlike others who are engaged in these matters, I have no position of power or authority which I can exploit. My opinions stand purely by the weight of my arguments. I believe that they will withstand testing, but no specific challenge has yet been offered.

    There is a significant difference of political opinion on this matter. I wish that we could confine ourselves to discussion of that difference. There are some who believe that co-payment is a perfectly proper way of funding publicly-subsidised health services, whereas others wish to retain and uphold the principles of the NHS.

    The BMA GPC and other proponents of the use of revenue sharing telephone numbers for access to NHS services have declared their position in favour of co-payment openly, when invited to influence policy. After this position was not supported in the drafting of Directions and contract revisions, they returned to pretending that it is not happening.

    I would much prefer to have the straightforward argument about co-payment out in the open - that is the complete basis for my interest in this issue. If my statements of fact are disputed, then please can I know what corrections I need to make. If there is a good reason to remain anonymous and not to claim the authority on these matters which is implied to be greater than mine, then I can accept that. I would however wish for myself and others who may read this blog to have the benefit of knowing where the alleged flaws in my points lie and how they should be corrected.

    On the closing points, I understand how annoying it must be for those who have been passing out information received in good faith to be told that it is false. Even the Department of Health, which referred to 084 numbers as offering a "guaranteed low call rate" on 24 February 2005, could not bring itself to admit that this was wholly incorrect when launching or responding to the public consultation on the topic in 2008/9. Indeed it almost repeated its error on 21 December 2009 by referring to the possibility of there being 084 numbers, to call which "patients are not charged more than the equivalent cost of calling a geographic number", when there are no such numbers (given that the Directions in question demand "having regard to the arrangement as a whole").

    I can well imagine some GP managers being subjected to bullying and intimidation over this issue. Those who argue earnestly for co-payment in the NHS may be passionate in their desire for NHS patients to pay for excellent NHS services that practices themselves cannot afford, however for this to be achieved under current regulations they have to ensure that a deceit is maintained.

    I can also understand how PMs to some NHS contracted practices are inconvenienced by having to deal with the fact that they are now in breach of their GMS contract, or the Directions to NHS bodies in the case of NHS Primary Care employees.

    As stated above, I will be happy to address any claim of inaccuracy with regard to the above, or anything else I have written.

    (N.B. An earlier draft of this comment, which was published briefly, has been extended)

  13. "unsupportive comment that I choose not to publish here will not be published here"

    I think that anyone who now reads this site - if this comment is indeed published by David - will realise that it is not a fair or balanced presentation of the true picture, but a vehicle for partial and repeatedly challenged views of a single campaigner with no access or credibility with any of the organisations or policy makers directly involved in the policy area, and to also act as a tool to try to hoodwink journalists, patients and others working in the NHS but not familiar with the subject area into thinking there is some legitimacy or authority for David's views.

    I fully expect this comment not to be published by David, but perhaps he will surprise me by having the integrity to do so.

    Interested Observer

    (BTW, David...unlike you, I have worked in and around the NHS and its constituent bodies for over 2 decades) 

  14. Of course my blog is partial - who on earth could think otherwise.

    The BMA GPC and others presented a partial view in favour of co-payment for access to NHS services in response to the DH consultation. It was rejected.

    Some believe that telephone companies should not pass on the cost incurred in providing subsidy to users of revenue sharing numbers to their callers. Ofcom disagrees, proposing that the status quo should continue, but with the "Service Charge" element openly declared.

    My primary focus at present is to encourage PCTs to consult the contract terms approved by parliament alongside published telephone tariffs when assessing claimed compliance with GMS 29B. I specifically invite them to dismiss opinions expressed by those with no accountability or authority and a strong partial interest, in favour of objective sources of information. (I include myself, as well as others, in the category of those who can only provide guidance, rather than accountable authoritative comment.)

    I understand that some do not agree with me and wish for compliance to be achieved on the basis of a wholly subjective view; they are entitled to their opinions. They can even state their subjective belief that the Department of Health supports this view. We are all entitled to our partial opinions and may wish to take whatever opportunities are open to us to express them.

    When it comes to matters of objective fact the situation changes. This is where those who may be seen to have some kind of authority have to take their responsibilities very seriously, as their subjective opinion may readily be mistaken for fact if it is not expressed with sufficient care.

    I feel that it is reasonable to invite someone who claims that I am misrepresenting facts to specify at least some of the items covered by this accusation, and the basis for the dispute. Some may wonder at the seriousness of their challenge if they choose not to respond. I am content to let unsubstantiated claims stand for what there are.

    BTW, my decision to publish the preceding comment had little to do with integrity; it provides me with a further opportunity to promote my partial views in response. I really am far more concerned about facts and principles than personalities when dealing with this issue.

  15. Interested Observer,

    As per earlier post - Can you point out where David is inaccurate in his facts. Let us argue on facts and not get personal.


  16. David is simply wrong when he says 084 numbers are always more expensive to call than 01, 02 and 03

    An OCFOM Report as recently as December 2010 stated “calls to geographic numbers can be as high as 8.5pm with a call set up fee of up to 11p (fixed) and up to 25 ppm (mobile), and 084 numbers can be as low as 0.5ppm with a call set up fee of 3p (fixed) and 20ppm mobile".

    Out of bundle calls for users of BT Evening and Weekends pay 7p per minute to call an 01, 02 or 03 number during the day - which is when 97 per cent of calls to GP surgeries are made - but 5p to call 084

    In the announcement of its conclusions at the end of its consultation on 084 numbers in the NHS, Department of Health stated in 2009 that 084 numbers are not always significantly more expensive for patients to call. The Government recognised that some telecoms providers “have chosen to charge no more for an 084 call than a call to a geographic number when dialing from a fixed line" The Government said it wished to see a marketplace evolve in the NHS in which 084 numbers compete alongside 01, 02 and 03 numbers.

    Contributor to the debate

  17. David has never intended to say that 084 numbers are "always" more expensive to call. (If such a slip could be found - please point it out to me and I will withdraw and correct it). He has said that ALL 084 numbers are more expensive to call. It is the latter which means that 084 numbers cannot be used by NHS bodies or GMS contractors.

    The NHS is a universal service, which means that the circumstances of all patients have to be considered. The relevant directions and contract revisions require regard to be shown to "the arrangement as a whole". As Ofcom says: "Only 03 is charged precisely the same as 01 and 02 numbers by all telephone companies ..." (see my original blog posting for the full quote.)

    Because BT is prevented from making money on calls to 084/087/09 numbers it can only charge what is passed on to the other end - typically 5p per minute on the 0844 numbers used by GPs.

    For those who select a Call Plan that does not cover weekday daytime calls, BT imposes a (unregulated) "penalty charge" for calls to geographic numbers. This is currently 7.6p per minute, which means that the "penalty charge" is greater than the charge for calling a 0844 number - agreed. (All such calls are subject to a 12.5p call setup fee).

    Anyone at home during the day and making telephone calls using BT, e.g. the retired, the long term sick and those with children, should be subscribed to the Anytime call plan, where the cost of a call of up to one hour to a 01/02/03 number is zero.

    All mobile callers and public payphone users pay more to call all 084 numbers.

    The latter groups are covered by the terms of the NHS Constitution and the relevant regulations; neither is limited to those who incur BT penalty charges.

    The fact that "some telecom providers charge no more for a 084 call" (in some circumstances) is of little significance, unless it can be shown that all patients who call a particular 084 number have their service from that provider and call under the relevant circumstances. I cannot dispute the essential truth of the quoted statement, but it makes no difference to the points that I make.

    I understand that a major provider of telephone service to GPs (or to be a precise, a re-seller) has given such an undertaking about what it charges. This may be of comfort to those who call from the practice to 084 numbers, but it makes no difference to those who call to the practice.

    The desire for a "marketplace" within the terms of the NHS presents an interesting challenge to providers, as does the statement that 084 numbers may be used so long as they do not cost callers more than the cost of an equivalent call to a geographic number.

    Had Ofcom proceeded, as some thought that it would, to remove revenue sharing from 0845 and enforce call charge regulations similar to those applying to 03, then this could perhaps have been realised. Ofcom actually moved in the opposite direction, so there can be no prospect of such a marketplace coming about.

    Those who offer systems requiring the features of non-geographic numbers have to compete on a level playing field using 03 numbers, with those who offer systems that can be effective without this additional cost to the practice. The opportunity to gain subsidy through revenue sharing is not permitted, because this cost is inevitably passed on to callers.

  18. Can David confirm that if a Surgery replaced an 084 number with an 03 number, there would be no difference in the service received by the patient (and he has already admitted that in some cases patients would pay more to call the surgery to receive the same level of service as an 084 number) but that rather than receiving a proportion of profits from the telephony company providing the call, it would have to pay out a sum for each call received to BT or the Originating Call Provider?

    Can David explain where in the principles of the NHS it is set out that the service should be organised as to provide a hidden subsidy to large scale telecommunications providers with the patient seeing no added benefit?

    By urging people to move to BT Anytime and urging surgeries to adopt 03 numbers, isn't David (inadvertantly or otherwise) acting as an unpaid recruiting seargent for BT to receive payments and make profits from every call made to every surgery in the UK by every patient?

    Contributor to the debate

  19. It would greatly help the readability of these comments if each contributor would select a nickname to use (assuming that they do not wish to use a registered identity), rather than adding a "signature" in the text of the contribution.

    We now have two contributors both being titled as "anonymous", although using different "signatures". I am reluctant to ask for a lengthy contribution to be re-typed, as I have previously with a brief contribution, and so once again I will publish an "anonymous" contribution. My policy of being unlikely to accept such contributions is clearly stated. (A nickname is all that is required.)

    I respond, in the following comment, to the points made by "Contributor to the debate".

    Some of my figures are rough and are shown as VAT inclusive for the sake of simplicity. I would be delighted to respond to any suggestions of significant error.

    I regret having to address only one small and irrelevant part of the picture, however many have applied a disproportionate focus to this selective and perverse aspect of the situation and suggested or implied that it is representative of the totality and relevant.

    If, in our debate, we can get this irrelevant, exceptional and anomalous bit of the picture sorted out, then we can perhaps move on to look at the important and relevant issues in similar detail.

  20. The issue of the switch from 084 to 03 raises interesting points about the flows of money. There are some errors in the comments to which I respond. I address these specifically. I will respond to the points made.

    A switch from 084 to 03 shows up an anomaly in respect of BT callers who incur penalty charges for breaching the terms of their Call Plan. This is but one of many cases, representing less than 25% of callers (according to Ofcom figures). I am happy to address it, but must caution that the profitability of the telephone companies is very different in other cases. The financial model outlined is flawed both in detail and in not being fully representative.

    If a surgery replaced a 084 number with a 03 number the patient would no longer be providing subsidy to the practice. I cannot say what effect that may have on the service delivered. Having chosen an expensive telephone system, a practice may suffer financial difficulty if, like all other NHS providers, it has to meet the full cost.

    BT customers who breach the terms of their selected Call Plan incur a "penalty charge" on calling 01/02/03 numbers during the working day. Because BT is currently prohibited from added an "Access Charge" on calls to "Business Rate" 084 numbers, these are currently cheaper than the penalty charge.

    There is no arrangement for profit sharing between telephone companies and any service user; the level of the termination fee is fixed (not related to profit) and invariably reflected in the charge to the caller (albeit banded in some cases).

    All charges paid by a user of 03 numbers are to the sole benefit of its own network telephone service provider (not BT or the call originator).

    The core principles of the NHS do not cover third party costs incurred by patients, nor costs incurred by NHS providers. They cover the relationship between the patient and the NHS provider . This cannot include any payment in respect of NHS services, regardless of the quality.

    There may be issues of value for money in respect of the patient's choice of telephone provider and tariff and the GP's choice of telephone system, but these are not directly relevant to the principles of the NHS.

    My primary concern in respect of BT is for the situation to be normalised with respect to other telephone companies. I hope that when it is allowed to take a proper margin on NTS calls this may enable other charges to be reduced a little.

    For BT customers, I only wish for those who make a significant number of weekday daytime calls to recognise that they would be far better off by selecting BT Anytime.

    There are disagreements over whether a customer moving onto Anytime would be to BT's advantage or disadvantage. "Contributor" appears to have missed the point by suggesting that a disadvantage of such a move (loss of penalty charge income) would not occur.

    I recognise that those who thereby breach the terms of their Call Plan, will currently incur a 2.6p per minute additional cost if paying the charge for calling 03, as against that for 0844 (g6). Other BT customers will save 5p per minute plus a 12.5p call set up fee.

    BT accounts for only around 25% of UK non-business calls currently. The savings for the remainder of callers are generally much greater on a switch from 084 to 03. I quote the extreme case of those with T-Mobile contracts who save 41p per minute.

    We cannot allow an issue of solid principle to be sacrificed for the sake of a short-lived anomaly with BT which only applies to those who breach the terms of their Call Plan. No such provision was included in the relevant contract revisions and Directions, which demand regard to "the arrangement AS A WHOLE".

    It is indeed deeply regrettable that taking proper action will cause BT to earn income of 7.6p per minute on some calls, as against a margin of zero. I do not shy away from the reality of this anomaly, I simply ask for it to be properly understood, placed in proportion and not allowed to distort wider issues.

  21. NHS supporter but realist1 July 2011 at 07:34

    David says "The core principles of the NHS do not cover third party costs incurred by patients, nor costs incurred by NHS providers. They cover the relationship between the patient and the NHS provider . This cannot include any payment in respect of NHS services, regardless of the quality."

    So what about

    Prescription charges
    Dental treatment
    Car parking charges at hospitals
    Bedside TV charges for in-patients

    All of these are charged by an NHS provider to the patient and cost a patient far more than any tiny marginal cost on a phone call to the GP surgery - pounds rather than pence.

    Is David saying that every hospital, every dentist, every GP is operating against the core principles of the NHS and has been doing so for over 40 years?

    If David wants to campaign for a purist and undeliverable model of NHS financing where everything is free, he should be campaigning about these items, instead of spending his time targeting surgeries and PCTs about the marginal item of phone calls to the GP.

    Or is it the other way around, that David is more concerned with his telephony argument than concern about the NHS and has simply alighted on NHS Primary Care as a "soft target" for his telephony arguments which is easily picked up by journalists?

  22. NHS Prescription charges, NHS Dental charges and NHS Ophthalmic charges are set by parliament and applied with exemptions and limits loosely associated with need and ability to pay. They are not determined by the contracted provider, are not varied according to quality and are not intended to be judged on the basis of value for money, as if in a market.

    Bedside TV and telephone services in hospitals are not NHS services. The scheme is a disaster in almost every respect. I have seen cases where it is wrongly administered, by being made to appear to be a NHS service.

    Car parking is more tricky. There are cases where I see car parking charges levied by (or on behalf of) NHS providers as breaching the principles of the NHS. I cannot however say that this applies to every car parking charge levied for parking on NHS land.

    I also have concern about some of the arrangements under which retail concessions are granted by NHS bodies, where non-standard prices are used to fund the concession fee.

    There must be solid principles, however they must be applied with care and discretion.

    David says that we have to be very careful to protect the delicate creature that is "our NHS". It risks being destroyed by consumerism, rather than the professionals who work within it.

    The history of my involvement in this specific campaign is about concern for the NHS. The necessary learning about revenue sharing telephone numbers has led me to expand to cover the same points in respect of all those public services for which it is inappropriate to levy charges on service users. I also engage in the wider aspects of the issue.

    I have no shame in saying that the NHS provides the clearest (softest) target for any campaign against misuse of revenue sharing telephone numbers. The principle of "free at the point of need" is not quite so well established in respect of enquiring about pensions or tax credits by telephone.

    If a bank or retailer wishes to levy a charge for phoning up to complain, that is essentially a matter between them and their customers - although they should declare their charge openly. Most customers would think such a charge to be wholly inappropriate and so it is likely that transparency would (as in the other cases) cause use of the revenue sharing number to cease.

  23. "Contributor to the debate" said "The Government said it wished to see (in the NHS) 084 numbers compete alongside 01, 02 and 03 numbers." If that is so then why not insist that all bodies and GPs who wish to use 084 numbers must publish an alternative geo number at the same time. This would allow the competition to occur and evolve and the public would be able to choose whichever number they prefer. That would be fair competition unlike the current situation where some GPs and bodies impose 084 numbers which many people object to and cannot avoid.

  24. The issue is simple. The DH has decided that patients "as a whole" should pay no more than the price of a geographic call.

    PCTs do your job (as DH has decided to pass responsibility to you) and see that surgeries using 084 numbers replace them with 03 or geographic (01/02) numbers.

  25. I have been told that "Interest Observer" has received "complaints from NHS practice managers working hard to deliver services to local patients that they felt unfairly targeted, harrassed and bullied by your activities". (I hope this quote is seen as an appropriate response to a comment submitted against another blog entry.)

    I can fully understand that if any single one of over a thousand practices in breach of their contracts is identified, then they may feel that they are being unfairly targeted. I can also understand that many of their patients do not have a sufficient understanding of the relevant regulations to press them to comply with their duties as NHS providers.

    Because relatively small amounts of money are involved, a patient may also feel that it would be disproportionate to raise the issue if they are generally happy with their GP. I do not believe that it is right for this reluctance to complain, or a willingness to engage in co-payment, to be exploited to undermine "our NHS".

    I can only draw attention to the issues, I have no position of authority from which to bully any practice manager. If those in breach of their NHS contracts are being harassed from any quarter, then they should respond by looking properly at the terms of their contract, establish the relative call cost incurred by patients in an objective manner and take the action demanded by changing their telephone number.

    I am still awaiting a specific challenge to the factual basis for my comments.

  26. David, please ignore these anonymous people who seek to discredit you.

    They are practice managers and GPs whose only interest is to line their own pockets at the expense of NHS patients.

    They are the same people who fitted the premium rate telephones in hospitals and then tell patients they cannot use their mobiles!

  27. Agile, I have published your comment, but I do not share your views.

  28. Anonymous "Contributor to the debate" said (30 June 2011 22:53):
    "Can David explain where in the principles of the NHS it is set out that the service should be organised as to provide a hidden subsidy to large scale telecommunications providers with the patient seeing no added benefit?"

    The "subsidy" referred to is presently paid for by patients through their telephone companies. Moving these 084 surgeries over to 03 numbers would leave them paying it themselves.

    It is important to understand why it is likely that such charges exist. I say "likely" because exact charges are down to commercial decisions.

    During a 'normal' call, there are two telephone companies involved; the caller's and the receiver's.

    A GP's solution usually uses three telephone companies; the caller's (patient's), the 084 number provider and the provider of the landline to the surgery (with a geographic number).

    It stands to reason that the 084 provider incurs termination charges to pass the call to the surgery's local number and it should be the surgery that pays as it decided on this solution.

    Presently, with 084 numbers, an 084 number provider pick ups an enhanced termination fee from originating (call) providers which allows it to pay for the onward termination to the surgery's local number and in many cases there is some excess which is paid out as revenue for the lease of the phone system.

    There are providers of 03 numbers that allow delivery of calls using VoIP where there are no charges for receipt of calls, so it is not a given that number users (call receivers) must be charged. However, such providers do charge where the number user wishes calls to be delivered to a 01/02 number, which makes sense as they incur costs to do so.

  29. In a separate blog, Dave Lindsay states

    "Call Set-up Fees (or sometimes called "Call Connection Fees"), whole minute billing and rounding each individual call charge up to the next whole penny means that we actually pay more for every minute of a chargeable call than the published "per minute" rate would have us believe.

    If a butcher were to round up the weight of meat to the next 500g interval, Trading Standards would be down on him or her like a tonne of bricks. But Ofcom sits idly by and allows calls of 1 minute and 1 second to be rounded up to 2 minutes. That's 59 seconds of call that are billed for but are never made!"

    Can David or Dave Lindsay confirm that 01, 02 and 03 calls to doctor's surgeries are rounded up, whereas 084 numbers are not?

  30. David

    Can you confirm the following?

    With an 084 number, you argue that the person calling the surgery "subsidises" the GP.

    You have argued that this amounts to "co-payment".

    The thread above confirms that in certain circumstances, the person making the call would pay at least as much and in some circumstances more, to call the surgery on an 03 number, with no added service or technical benefits compared with an 084 number.

    But you have confirmed that with an 03 number, the surgery makes a payment TO the telephone industry, rather than receiving a rebate FROM the telephone industry. Even though the patient pays the same amount to call the surgery or sometimes more.

    Therefore, logically and to be consistent, shouldn't you be calling 03 numbers "co-subsidy" numbers, if you are going to call 084 number "co-payment" numbers?


  31. There are over two hundred registered providers of telephone service in the UK. Each has many different tariffs. It is therefore rarely possible to provide a simple Yes or No answer to a question such as that posed by "Peter".

    In general, all telephone call charges are based on whole minute durations (rounded up). There are however exceptions. For example, BT rounds up the duration of calls to NTS numbers (084 / 087 / 090 etc.) to the nearest second. Others do not, and BT rounds durations of other calls differently. This exceptional rule could be applied because this is the basis on which termination fee payments between telephone companies are calculated. Because BT is (currently) prohibited from making any margin on calls to NTS numbers, it could be that BT is not allowed to apply the normal duration rounding rules to these calls, as this could be seen to be providing it with a margin. (I can think of no other explanation for this difference.)

    Looking at the issue of rounding more widely. It is easier to check, and perhaps dispute, your bill by applying integer multiples of the pence per minute rate. If required to round telephone call charges down, or to the second, companies would need to increase the unregulated rates to produce the same revenue.

    One hopes that Trading Standards officers would have regard to the relevant issues in each case. This would include tolerances on the accuracy of the butcher's scales and the degree of precision required in any measurement and the calculation of price. I have no idea as to how many parts of a gram a butcher has to consider!

    The other significant point is that the telephone industry is currently moving away from per call billing for normal calls. All standard offerings (landline and mobile) are now for normal calls (to 01/02/03 numbers) to be inclusive in a monthly charge. It is only where money has to be paid on to third party, on a per call basis, that call charges are now seen. The other case is where one goes beyond the terms of the package and incurs a penalty charge. (I know that some tried to get ahead of Ofcom by assuming that 0845 would join 0870 and are now perhaps disappointed that this did not happen, as they have to recover the cost of this mistake by inflating package charges for longer than they imagined.)

    The rates for the exceptional calls on which one pays call charges are quite high enough to be an issue in themselves. Whether the standard or non-standard rounding method is used is but a supplementary issue. Where call charges do apply to 01/02/03, as well as 084, calls, the rates for the latter are higher in the vast majority of cases. I am not aware of any case where the rate is the same, but the rounding method is different.

  32. Peter said (4 July 2011 07:30):
    Can David or Dave Lindsay confirm that 01, 02 and 03 calls to doctor's surgeries are rounded up, whereas 084 numbers are not?

    That is correct. BT's whole-minute rounding (up) policy is different for 01/02/03 calls than 0844 (and other 08/09 calls).

    The relevant page in the BT Price List is here:


  33. Paul B is wrong to suggest that the rebate on 084 numbers is provided by the telephone industry. In every case it is reflected in the call charge paid by the caller. This even applies in cases where a penalty charge would otherwise be incurred on calling a 01/02/03 number. Where 0845 calls are included in packages, it is reflected in the fee for the package.

    I have confirmed that some callers pay a "penalty charge" to BT when calling 01/02/03 numbers outside the terms of their selected Call Plan. Due to legacy regulations, which are due to be lifted shortly, this exceeds the value of the revenue share from which users of revenue sharing and some Premium Rate Service numbers benefit, which is the rate that BT must currently charge for these calls.
    To suggest that this very particular and anomalous situation applies as the norm, or universally, is to misrepresent reality.

    Although, originating around 25% of non-business telephone calls, BT is the largest single provider, not all of its customers breach the terms of their Call Plan when calling 01/02/03 numbers. BT cannot be ignored, however the fact that it alone is (currently) subject to regulation of its charges for calls to 084 numbers means that its charges cannot be taken as a fair illustration of the general position.

    It is quite false and absurd to pretend that no telephone company is allowed to make a margin on calls to 084 numbers and that everyone calls 01/02/03 numbers outside the terms of their Call Plan, thereby incurring penalty charges. That is however the scenario on which the so- called "logical" and "consistent" conclusion depends.

    I hope that we have dealt adequately with the anomalous position concerning BT and some of its customers. I do not seek to deny it, however we must place it in proportion and note that the anomaly is in the course of being addressed. We may not be far from the situation where all users of 084 numbers will have to declare the "Service Charge", which is the part of the call charge from which they benefit. This is currently in the range between (roughly) 2p and 5p per minute.

    The whole point of 03 numbers is that there is no exchange of monies between the caller and the called. That is why they are suitable for use by a NHS provider. For the caller, they are charged at no greater level than calls to 01/02 numbers. For the person called, they enable them to meet the full costs of their chosen telephone arrangement themselves if the require the features of a non-geographic number.

    The benefit of revenue sharing on 084 numbers enables telephone system providers to conceal the true cost of their system. It is quite natural for them to be unwilling for this to exposed to their customers, as would be the case on migration to 03.

    03 offers a perfectly straightforward approach to use of the facilities available on non-geographic numbers, as an alternative to other methods of handling call queuing that may be deployed by GPs on geographic numbers. In both cases the practice meets the cost of the telephone system, whilst patients pay the cost of a normal call (whatever that may be) to call the surgery. Other than the reason given above, I cannot see why anyone could object to use of 03 numbers.

  34. Clearly call pricing is a complicated issue with many suppliers and packages and as a consequence there can be anomalies. It is however possible to keep this simple:

    Firstly everyone is free to pick a call provider and package that as near as possible meets their requirements in a free (but regulated) market and they pay for their calls either per call or by purchasing an inclusive package of some sort.

    In addition there are some types of calls where a transfer is made from the caller to the person being called. This either takes the form of money or a subsidy on services/products provided to the person being called. Whatever from an accounting point of view this is the same thing.

    There is nothing wrong with these types of calls provided the caller is aware of the type of call and has a free choice as to whether to use it. I (my family) have positively made such calls on numerous occasions.

    My understanding is that 0844 numbers involve a transfer of such funds.

    Clearly someone has to pay for that transfer. Although there may be some anomalies where a 0844 call is no more expensive than a 01/02/03 call clearly the net situation must be that the callers are paying for those transfers. These funds do not appear by magic.

    In particular with call packages (which a huge number of people have and more are moving to) there is no way that the transfer charge is not paid for by the caller as otherwise his/her telephone company will make a loss on every call.

    In summary:

    As a group callers to 0844 numbers pay (and must pay) a premium over 01/02/03 calls and a transfer is made to the called as either funds or a subsidy.

  35. There are a couple of points to add to the comments made by "Supporter".

    • Call packages are not an additional option, there are the standard basis for the sale of call services. All customers have to subscribe to a package of some sort with BT and the majority of providers. There are very few line rental only deals, and these are generally used when subscribing to a package from an alternative calls provider.

    • There are exceptional cases where the calls provider does not make any money on 084 calls. This does nothing to alter the fact that funds are being transferred between the caller and the person called.

    With reference to the summary, the principles of the NHS, as a universal service "free at the point of need", do not permit consideration of some sort of averaged situation, looking at a group. EVERY individual patient has the same rights under the NHS constitution - a charge to one patient cannot be offset against a cost saving by another. The assertion may well be true, but there is no need to make any general calculation, the regulations demand regard to "the arrangement as a whole".

  36. I have received a reply from my MP whom I asked to support Stop GP 0844 numbers - he enclosed reply from West Kent PCT which said they had told offending GPs to "Display a poster in Recp. area as a means of providing assurance to all Patients " of what I dont understand, also that GPs using 0844 that Patients should be charged at local rate on BT Standard Tariff (which I dont think exists now)- and that if Patient is not on this 'Standard Tariff' to change Provider to one that does - which would mean ditching Patients Phone Bundle to suit their GP


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