Since I commented on “Surgery Line - Statement of Compliance with NHS Regulations”, published by Daisy Group in February 2012, two new versions have been released.
The latest version, now entitled “Surgery Line - NHS Regulations – Supporting GPs with Compliance - Effective April 2012” has been circulated. An intermediate, March 2012, version is published here.
Daisy offers its interpretation of the requirements imposed on NHS GPs with effect from 1 April 2010, covering use of non-geographic telephone numbers. As the leading provider of non-geographic numbers for use by NHS GPs, Daisy cannot but reflect its own strong commercial interest in this matter.
I have no personal interest in this matter to declare. I am a campaigning citizen, concerned for the lasting principles of ‘our NHS’ and their preservation.
My response on the topic of “Supporting Surgery Line”
I have now responded with my own “Supporting Surgery Line” document, (follow the link below).
Its full title is - “Supporting NHS GPs using Surgery Line in compliance with the contractual requirements for non-geographic telephone numbers”.
I invite those who are keen to see Daisy's inevitably ‘interested’ comments placed in a broad context, and to see its claims and interpretations judged critically, to read my comments. I have no issue with the Surgery Line system as such. If used as a means of accessing NHS services however, it must be paid for properly, not subsidised by patients. All use of 084 telephone numbers provides subsidy to the user, at the expense of callers.
Links
My “Supporting Surgery Line” document refers (with direct hyperlinks to the relevant section) of:
→ an annotated copy of the Daisy document
→ the text of the contractual requirements.
Readers may either open (and perhaps print) these cited documents for continual parallel reference using the above links, or use the hyperlinks in my text to switch back and forth as required.
My comments
I quote below some extracts from my document, (with links for them to be seen in context).
For those already using non-geographic numbers on 1 April 2010, the action required depends on the determination of: “whether, having regard to the arrangement as a whole, persons pay more to make relevant calls than they would to make equivalent calls to a geographical number”.
If they do not pay more, then no further action is required. If they do pay more, then contractors must take “reasonable” steps to ensure that this situation ceases.
Those not using non-geographic numbers on 1 April 2010 are simply prohibited from entering into an arrangement whereby callers pay more.
Adding a concurrent Daisy local rate line
If the original number being used is not more expensive to call, then compliance is not in question.
If the original number is retained, offering the benefit of a better service alternative at higher cost, this would represent an additional breach of the fundamental principles of the NHS - offering what is known as a ‘two-tier’ service.
Migration to 03 - the reasonable step available
For those seeking to, or contractually obliged to, retain the features of a non-geographic number (sometimes referred to as “enhanced telephony”), the only way of achieving compliance is by migrating to a 03 number.
Surgery Line is offered on the 034 range of 03 numbers. Migration to 03 is therefore a step that is available to Surgery Line customers. Whether or not it is a “reasonable step” depends on whether Daisy follows standard industry practice, or if it seeks to exploit or penalise those wishing to follow this obvious path to compliance.
The approach to compliance suggested by Daisy
The “arrangement as a whole” does indeed refer to “the surgery as a whole”, including each and every patient that it serves. By suggesting an approach that is incompatible with the NHS Constitution from the start, it would seem that Daisy either does not understand the NHS, or seeks to change or undermine it.
Since 2004, Surgery Line has been promoted on the basis that it costs callers no more to call a 0844 number than to call a geographic number, even though this has never been true. Having been required to cease considering only BT and then to cease considering only landlines, it is quite remarkable to see attempts to maintain this fiction continue.
This latest effort is characterised by considering only Out of Plan and Out of Bundle penalty charges for calls to geographic numbers, even though they only represent a small proportion of calls made. In the case of Mobile Phones it has also been necessary to use aggregated figures, including numbers that are cheaper to call than those used for Surgery Line.
I believe that every practice will have a significant number of patients and other callers who subscribe to BT Unlimited Anytime - the most widely used residential landline tariff, … or a mobile contract call bundle that they do not exceed. These persons pay more to make relevant calls than for an equivalent call to a geographic number, so a “reasonable” step that is available must be taken to ensure that this ceases.
