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Tuesday, 8 November 2011

Daisy Surgery Line and "Enhanced Telephony"

There is keen public debate over the still unresolved issue of NHS GPs using 084 telephone numbers to gain subsidy of their costs at the expense of patients. As a contribution to this debate, Daisy Group, the provider of the Surgery Line system used by many NHS GPs, has issued a helpful leaflet -

•    Enhanced Telephony - THE FACTS

Noting this useful contribution to the debate, I have published two documents:

•    Daisy Surgery Line - The Facts

This addresses some omissions from the Daisy Group document in an attempt to further public understanding of the issues.

In particular, it highlights the fact that no NHS GP using a 084 number can be assured of compliance with the principles of the NHS and the specific terms of their NHS contract. In truth, it is only under inconceivable circumstances that a 084 number could be used.

•    How to use Enhanced Telephony as a NHS GP

This refers to the specific options available to NHS GPs who wish to use Enhanced Telephony whilst remaining in compliance with their NHS contract.

In particular, it refers to the option for existing and committed users of non-geographic numbers to migrate to 03 numbers so as to be assured of compliance with the principles of the NHS and the specific terms of their NHS contract. It highlights the need for identification of the telephone service providers who are alleged to be deviating from the standard industry practice by preventing such migration.

Whilst there are many opinions about the way in which the NHS should develop, it is vital that public discussion is conducted on the basis of truth. I will be pleased to engage in debate on the former, but must urge any alleged inaccuracies in any of my comments to be brought to my attention immediately.


For the sake of simplicity, neither of my documents contains detailed references to relevant materials. I list the specific materials referred to, and from which quotations are taken, along with other relevant items.

Key documents

→    Calling costs
A summary from the most commonly used tariffs giving the costs of calling 084 and geographic numbers. This document provides links to the relevant published tariffs, which can be the only relevant source of information for those wishing to be assured about the costs that will actually be incurred by callers.

→    Statements from Ofcom
This series of formal statements issued by Ofcom covering relevant issues should be of interest to those who wish to review an objective presentation of the relevant facts. This key document is also presented embedded below.

→    The 03 alternative
A media release from Ofcom confirming the benefits of use of 03 numbers as an alternative to "the service provider generating revenue from those making the calls to offset the cost of equipment to the organisation".

Department of Health material

→    Revisions to the NHS GP contracts
the Statutory Instrument passed by parliament to provide the revised terms of the GP contracts.

→    The use of 084 Numbers
a letter from Nick Hall of the Department of Health confirming the basis for possible continuing use of 084 numbers - "… providing that patients are not charged more than the equivalent cost of calling a geographical number to do so".

→    Hutton rings the changes
an announcement by the Department of Health in February 2005 including the false advice that 084 numbers "offer patients a guaranteed low rate call". There never was any such "guarantee", Mr Hutton was mistaken or misinformed.

→    Clarification of the terms of the requirements placed on GPs
an exchange in parliament on 12 July 2011 providing clarification of the meaning of the terms of the contractual terms, including "It is absolutely clear that there is no distinction between landlines, mobiles or payphones".

Other material

→    Surgery Line is "co-funded"
Confirmation that a key feature of Daisy Surgery Line is the fact that users benefit from revenue sharing - "The revolutionary co-funded enhanced telephony service, designed specifically for GP surgeries. "

→    BMA Guidance vn 1
Indicating a clear position of continuing opposition to the objectives of the contract revisions - "calls to NHS services should incur as low a charge as possible, but that this must be balanced by the quality of communications service that the patients are accessing". It is use of numbers on which a premium charge is applied to achieve the "balance" which is now explicitly prohibited for the NHS.

→    BMA Guidance vn 2
This alleges that some telephone services providers are not allowing GPs to vary their arrangements by migrating to 03 numbers, so as to retain the benefits of Enhanced Telephony whilst complying with the principles of the NHS and the terms of their NHS contracts - "many GP practices have signed multi-year contracts with telephone services providers which cannot be varied, renegotiated or terminated without substantial financial penalty". Any company which is preventing migration to 03 by imposing unreasonable penalties, contrary to Standard Industry Practice, needs to explain the reasons for this unusual conduct.

→    Example of call cost statement
This is a typical example of a practice indicating that the "5p per minute" revenue share charge (as levied by BT) is used to pay for the enhanced telephony it uses, not to provide income to the practice. Despite being proud to "offer NHS Services", the practice appears to forget that the payments it receives for providing these services are intended to be used to cover the costs of telephony. "lo-call" means that the premium rates charged for calling revenue sharing 084 numbers are generally lower than those for calling numbers used for "Premium Rate Services", which can attract much higher premiums.

→    Example of surgery letter to patients
This example shows how a practice and its patients are benefitting from the use of "Enhanced Telephony". Unfortunately this practice has failed to "have regard to the arrangement as a whole" by only considering a claim about rates charged by their "own phone supplier". I have no evidence, but I suspect that the company in question does not provide telephone service to even one of the practice's patients, and so the "written guarantee" about the charges it makes is worthless. (The reference to "guidance of The Department of Health" is utterly spurious. There is no "OFCOM regulated rate for, or related to that for, "local geographic calls", other than the regulation covering 03 numbers, which applies to all providers. I have no idea of what could possibly be meant by "a standard BT tariff", it is certainly not that most commonly used by BT residential customers.)

Under the terms of the most commonly used BT residential tariff (the "Unlimited Anytime" Call Plan), a geographic call costs zero whereas a call to a 0844 "g11" or "g6" number, as used by Surgery Line users, costs 4p or 5p per minute to the benefit of the practice, plus a call setup fee to the benefit of BT.

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