Contribution to a Which? conversation

In a Which? "conversation" "GPs – stop using expensive phone numbers", I have been asked to provide statements confirming that

"0344 provides the same functionality for the surgery as 0844"

I regret that I cannot provide a link to the specific comment to which I reply, nor has it been possible to add the comments that follow to the "conversation".

I can offer the following (hyperlinks are supported by page references where necessary):

1. From Daisy Group / NEG

This may be the most suitable, although I cannot confirm this. It is from a company called NEG, now part of The Daisy Group. It claims to be "the market leader in the provision of enhanced telephony services to NHS Primary Care".

Identical functionality can be provided to organisations
through 084 and 03 numbers

This is found on page 10/75, labelled "Page 4" of this pdf document, authored by NEG and published by Ofcom.

There is much else in this document, on which I comment in this blog posting.

It is likely, but not confirmed, that the Daisy Surgery Line system is used by the only GP in Hadleigh shown on this map.

2. Ofcom

Some basic information about 03 is published by Ofcom in this press release.

3. The Department of Health

The Department of Health Consultation document - The use of 084 telephone numbers in the NHS included (on page 5/16) the following statement:

03 numbers offer the same extra functions as 084 numbers
but are charged at the same rate as a call to a local number

General Comment

It is taken as given that all non-geographic numbers provide the same potential for use of "Enhanced Telephony" features because, unlike geographic numbers, they terminate at the same type of equipment - an "intelligent switch" - from where calls are distributed as appropriate.

Similar facilities may be provided on some (or perhaps all) geographic numbers, however this is said to be less convenient and may cause greater costs to be incurred.

References to comments made in the conversation

There can be no instruction more specific than the terms of the contract between the practice and the PCT. This was approved by parliament, and the Department of Health cannot vary these terms by issuing its own instructions.

Ministers of the Department have commented that the requirement to consider call costs applies to all types of telephone service and tariff. This only draws attention back to the terms themselves, and away from misleading guidance issued by certain parties.

If the practice believes that "having regard to the arrangement as a whole", persons do not pay more to call its 0844 number than for an equivalent call to a geographic number then it is shutting its eyes to obvious facts.

It is perhaps relying on guidance based on the situation as it relates to a selected group of potential callers, who incur penalty charges for calling geographic numbers outside the terms of their chosen call plan. Unlike all others, this select group may not pay more.

No matter how convincing and reassuring that guidance may be, it is partial in two senses. Firstly, it comes from a pair of organisations working together and known to be opposed to the objective of prohibiting use of numbers that cost more than the cost of a geographic call. Secondly it admittedly addresses only some callers, rather than "the arrangement as a whole".

The NHS is universal, the rights and principles outlined in its Constitution apply to everybody, arrangements relating to the provision of NHS services cannot be made with regard only to a group which conveniently allows the objective of GPs continuing to benefit from revenue sharing at the expense of patients to be achieved.

References to published comments from the practice

The benefit from revenue sharing is used to subsidise the cost of the GP's chosen telephone system. The full cost should be carried by the practice. "The practice profits" by using a revenue sharing telephone number, not by "providing an advanced telephone system".

The term "local rate", when applied to a 0844 telephone number, represents a "serious factual inaccuracy".