The Scottish Government currently has a consultation on the above.

087 and 09 numbers were banned in 2005 and they are belatedly getting round to banning 084 numbers.

Remember, GPs in Scotland using 084 numbers are mostly using 0845 numbers, not 0844.


The consultation has a number of items which reflect the muddled thinking that has gone on for years...


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NHS bodies were allowed to continue using 084 numbers as these were classed as local calls by the regulator and would be as cheap when calling from a landline telephone as a geographical number.

0845 numbers ceased to be 'local rate' calls in 2004. See http://tinyurl.com/asa0845cap
Calls to 084 numbers are generally are not as cheap as calling a geographic number and that will become very clear on 1 July 2015.
Most people call 01, 02 and 03 numbers as part of an inclusive allowance. Calls to 084 and 087 numbers rarely count towards those allowances.



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In February 2011 Scottish Ministers issued guidance to the profession and in July 2013 restated guidance designed to curtail the use of 084 numbers as calls from mobile operators were being charged at rates akin to that of the aforementioned "premium-rate" numbers.

The issue is not that mobile operators charge more to call 084 numbers than calling from a landline. The real issue is that calling an 084 number costs more than calling an 01, 02 or 03 number whether from a landline or from a mobile (except when calling from a BT landline without inclusive calls {i.e. likely using the wrong call plan for your needs} and where BT's retail call costs for 084 and 087 numbers are subject to a price cap {which ends on 1 July 2015}).



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In July 2005 the Scottish Government introduced a ban on premium rate telephone numbers (0870 or 09). This however did not include 084 numbers, which are not classed as "premium rate" numbers.

Although not "Premium Rate", the caller still pays a "premium" which subsidises practice telephony costs. Ofcom requires this premium to be declared from 1 July 2015 as the "Service Charge".



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These "translation" costs are generally higher for 084 than for other number ranges.

Translation costs exist only on non-geographic numbers, i.e those starting 03, 08 and 09 (and on "virtual" geographic numbers). Those costs are the same on all of those number ranges. The cost difference comes from the fact that there are no translation costs on calls to standard landline and mobile numbers.



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In addition, the cost of originating calls from a mobile network is higher than that from a fixed line.

While true, this is not relevant because those higher origination costs from mobiles exist on all calls made to any geographic, mobile or non-geographic number.



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Therefore the costs of allowing its customers to access 084 numbers is higher for mobile operators than it is for fixed operators.

The cost of calling any number is higher from a mobile than calling the same number from a landline, but that's not the problem. The real issue is that with 084, 087 and 09 numbers the additional non-geographic call handling costs are added to what the caller pays making the call more expensive that calling an 01, 02 or 03 number. With 03 and 080 numbers the call recipient covers these extra costs.



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Where mobile providers offer contracts with bundled call minutes, 084 numbers are often excluded from these packages.

This is correct and is one of the most important factors.



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This has resulted in an unintended difference in treatment of people contacting a practice with an 084 number by mobile telephone in comparison to a caller on a landline. In terms of call tariffs, the call rates which patients are charged to call a 084 number will depend on their mobile phone service provider.

Again an obsession with what mobile callers pay, rather than the fact that it is the initial choice of a number that imposes a Service Charge on callers that pushes up the call cost - for all callers.

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1. The Scottish Government’s policy is that no person should be financially disadvantaged when contacting their GP practice. Do you agree with this statement?

Yes. GPs should use telephone numbers which are charged the same as 01, 02 and 03 numbers by all providers.



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2. The Scottish Government considers that, given the above statement, no person should have to pay more than the standard cost of a local call when contacting their GP practice. Do you agree with this statement?

A distinct 'local rate' ceased to exist in 2004. Callers should pay the same to call their GP as calling an 01, 02 or 03 number and the call should count towards their inclusive allowance on their landline or their mobile.



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1. Calls made to GP practices who have a telephone number beginning 084 can be very expensive if called from a mobile phone as, unlike geographical numbers (those beginning 01 and 02), these are not included in many call plans. Given this, would you support an outright ban on 084 numbers?

Yes. There should be an outright ban on all number ranges which impose a Service Charge on callers.



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2. If a patient rings the GP Practice and the line is engaged or they are held in a queue, it can be frustrating and expensive for the patient. One option may be to have a “ring back” service, where the patient types in their phone number and once the line is available or they reach first in the queue they are called back by the practice. Would you agree with the introduction of this service?

Although this may cut down the cost of calling the practice, the huge disadvantage is that having signalled the need for a callback, the caller then has to hang around by the phone, potentially for hours, waiting for that call back. The temptation would be to ask to be called back on a mobile number, rather than a landline, and this would significantly increase the practice telephone bill.



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3. One option may be to look into whether a call handling system could viably be introduced.  This system, similar to that of the NHS 24 111 system, would see calls routed through a switchboard operator who would direct the call to the local practice. Do you agree with this proposal?

This sounds like it would introduce additional costs without any clear benefit to the patient. Where a caller is in a queue for their practice, this could be alongside dozens of other callers. On the other hand, a queue on a centralised line could have thousands or tens of thousands of callers waiting. Additionally, confusion and additional delay could arise where patients' calls are initially routed to the wrong practice.



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4. Each practice would obtain an 030 number, Ofcom introduced the 030 number range exclusively for public sector and not for profit bodies. 030 numbers offer the same extra functions as 084 numbers. All mobile operators have to charge 030 numbers in the same way as they would geographical numbers, ie included within a customer’s bundle in their tariff. Although for the caller an 030 call is charged at the same as a local call, a charge is levied on the person or organisation receiving the call to cover the cost of the extra functions. Would you agree with the introduction of these numbers?

Calls to 03 numbers are charged the same as a call to an 01 or 02 number. This applies to all operators, not just mobiles. The easiest migration path from an 084 number is to the matching 034 number entailing the change of a single digit. This option has been available since 2007. Either 030 or 034 numbers could be used. Practices should make that choice for themselves.

The extra cost for the practice is the one that practices have denied for years that callers have been paying. Ofcom's forthcoming requirement for all users of 084, 087 and 09 numbers to declare their Service Charge will reveal the truth.



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5. All GP practices would be required to use geographical numbers.  There would be a grace period for each practice which had to change to enable current contracts to end without incurring unnecessary financial penalty to the practice. Do you agree with this proposal?

In order to retain the same call handling facilities, the practice would have to use a "virtual" geographic number. There would be no cost difference for the practice with this option than using an 03 number.

If the practice opts for a "virtual" geographic number or an 03 number, no grace period will be needed. All providers of these numbers allow a change of telephone number without penalty within the terms of the telephony contract. The change of number would alter the funding arrangements. Callers would no longer subsidise practice telephony costs, these would have to be appropriately funded from practice budgets.


Although welcome, this consultation comes very late, closing just days before Ofcom's requirement to declare a Service Charge kicks in.
See also: http://www.fairtelecoms.org.uk/blog/scots-gps-to-be-banned-from-using-084-numbers

Given Ofcom's requirement for all users of 084, 087 and 09 numbers to declare their Service Charge from 1 July 2015, all usage of those numbers within the NHS must cease by that date. See http://ukcalling.info/

There must be no temptation to introduce cheaper numbers alongside expensive 084 numbers in the name of "choice". The NHS is "free at the point of need" and does not offer alternatives based on ability or willingness to pay.

Phasing out 084 numbers can be as simple as swapping each number to the matching 034 number with an appropriate adjustment to the funding arrangements. The replacement 03 numbers have been available since 2007.

Regulation banning the use of high rate numbers within the NHS is patchy.

UK Legislation	Ban on the use of 087 and 09 numbers	Ban on the use of 084 numbers
GP practices	E: The National Health Service (Primary Medical Services) (Miscellaneous Amendments) Regulations 2005 (SI2005/893) W: The National Health Service (Primary Medical Services) (Miscellaneous Amendments) (Wales) Regulations 2006 (SI2006/358) S: The National Health Service (Primary Medical Services Section 17C Agreements) (Scotland) Amendment Regulations 2005 (SI2005/336) S: The National Health Service (General Medical Services Contracts) (Scotland) Amendment Regulations (SI2005/337) NI: The Health and Personal Social Services (Primary Medical Services) (Miscellaneous Amendments) Regulations (Northern Ireland) 2005 (SI2005/368)	E: The National Health Service (Primary Medical Services)(Miscellaneous Amendments) Regulations 2010 (SI2010/578) W: The National Health Service (Primary Medical Services) (Miscellaneous Amendments) (Wales) Regulations 2010 (SI2010/729) S: New regulations proposed for summer 2015 S: - NI: -
Dental practices	E: The National Health Service (General Dental Services Contracts) Regulations 2005 (SI2005/3361) E: The National Health Service (Personal Dental Services Agreements) Regulations 2005 (SI2005/3373) W: The National Health Service (Personal Dental Services Agreements) (Wales) Regulations 2006 (SI2006/489) W: The National Health Service (General Dental Services Contracts) (Wales) Regulations 2006 (SI2006/490) S: - NI: The General Dental Services (Amendment) Regulations (Northern Ireland) 2005 (SI2005/311)	E: - E: - W: - W: - S: - NI: -
Opticians	E: The National Health Service (General Ophthalmic Services etc.) Amendment Regulations 2006 (SI2006/1550) E: The General Ophthalmic Services Contracts Regulations 2008 (SI2008/1185) W: - S: - NI: General Ophthalmic Services Regulations (Northern Ireland) 2007 (SI2007/436)	E: - E: - W: - S: - NI: -
Pharmacys	E: - W: - S: - NI: -	E: - W: - S: - NI: -
		E: England. W: Wales. S: Scotland. NI: Northern Ireland.

A report summarising the responses to the above consultation has now been published.
http://www.gov.scot/Publications/2015/09/6616

The muddled thinking, highlighted earlier, continues.



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The National Health Service (General Medical Services Contracts) (Scotland) Amendment Regulations (SSI 2005/337) and the National Health Service (Primary Medical Services Section 17C Agreements) (Scotland) Amendment Regulations (2005/226) amended legislation to ensure that "premium-rate" numbers couldn't be used by GP practices.

The regulations banned the use of 087 and 09 numbers and failed to understand that 084 numbers were also premium rate. Note "2005/226" is a typo for "2005/336".



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NHS bodies were allowed to continue using 084 numbers as these were classed as local calls by the regulator and would be as cheap when calling from a landline telephone as a geographical number.

0845 numbers ceased to be 'local rate' calls in 2004. See http://tinyurl.com/asa0845cap
Calls to 084 numbers are not as cheap as calling a geographic number, whether called from a landline or from a mobile. The changes made on 1 July 2015 have made that very clear.
Most people call 01, 02 and 03 numbers as part of an inclusive allowance. Calls to 084 and 087 numbers rarely count towards those allowances.



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In February 2011 Scottish Ministers issued guidance to the profession and in July 2013 restated guidance designed to curtail the use of 084 numbers as calls from mobile operators were being charged at rates akin to that of the aforementioned "premium-rate" numbers.

The issue is not that mobile operators charge more to call 084 numbers than calling from a landline. The real issue is that calling an 084 number costs more than calling an 01, 02 or 03 number whether from a landline or from a mobile because the caller pays an additional Service Charge to the benefit of the called party and their telecoms provider. Gaining subsidy from patients goes against the NHS "free at the point of need" principles.



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As independent contractors, decisions on the type of telephone system used in their practices are generally the responsibility of the practice partners. The principal purpose of this consultation was to ensure that the regulatory framework regarding the use of telephone numbers by GP practices remains fit for purpose.

While practices must remain free to choose what type of telephone system they use, this must not involve getting patients to provide additional funding. There must therefore be limits set on the type of telephone number that can be used: 01, 02, 03 or 080. Usage of numbers where callers pay a Service Charge, e.g. 084, 087 and 09, must be banned.



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Most respondents didn't think that introducing a 030 number in every GP practice would be beneficial

Noting the limitations expressed above, practices should be free to choose their number. They can migrate their existing 084 number to the matching 034 number, to a new 030 number or to a 'virtual' 01 or 02 number and retain all the call-handling features that comes with a non-geographic number or they can migrate to a standard 01 or 02 number without any enhanced features. In all cases, usage of enhanced features must be funded by the practice not by callers.



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Onus should be on mobile phone companies not GPs to change their policies

Given the changes made by Ofcom on 1 July 2015, we now have the clarity of a declared Service Charge for calls to 084, 087 and 09 numbers and practices should be banned from using any such number.



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Many respondents think that due to people these days using mobile phones rather than a landline that these numbers have to be free from all telephones

It is unclear whether they realise that calls to 03 numbers are effectively "free" from landlines and from mobile phones as most people call these numbers using their inclusive allowance.


On the proposal to ban the use of 084 numbers...


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Many respondents think that due to people these days using mobile phones rather than a landline that these numbers have to be free from all telephones

Most people have inclusive calls to 01, 02 and 03 numbers. These are the numbers that practices should be using.



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Some practices are tied into contracts and should be given time to let these come to a natural end

The suppliers of these numbers have confirmed, long ago, that 084 numbers can be migrated to other ranges such as 034 or 030 without charge and at any point within the lifetime of a telephone services contract.



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RCGP in agreement so long as the ban was prospective and didn't require those GP practices under contract for a 084 number to incur early termination penalties.

As above. The need to invoke early termination penalties is a myth.

On the proposal to introduce an 030 number for each practice...


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Vast majority of respondents would not agree with the introduction of these (030) numbers

Practices must be left to make their own choice of number from a selection of standard 01/02, 'virtual' 01/02, 'non-geographic' 03 or 'non-geographic freephone' 080. The 'virtual' and various 'non-geographic' options come with additional costs which must be met by the practice.



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Many respondents said the cost would be too high for what would be an unnecessary change

It is interesting that GPs using 084 numbers were happy for callers to pay these fees, but not so happy when they are asked to pay them.



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Patients have benefitted from the additional services that 084 numbers bring and therefore why should the practice bear the brunt of the cost?

It is for the practice to pay for the additional features it purchases, not saddle the caller with a Service Charge to pay for them. Such an arrangement also exposes callers to an Access Charge of up to 45p per minute.



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This would be a partial solution, it gets round the high cost of traditional non-geographical numbers but stops short of being as low as possible for all patients

Here is a failure to understand that, other than freephone 080 numbers, using an 03 number represents the lowest possible call price for patients. Calls to 03 numbers cost the same as calling 01 and 02 numbers and count towards inclusive allowances on landlines and on mobiles.



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This proposal might be supported on the proviso that the public were told up front about the costs of calling the number; this was mentioned a few times, including an advertising campaign.

The call cost is the same as whatever the caller pays for calls to 01 and 02 numbers. Most calls to 01, 02 and 03 numbers are made as part of an inclusive allowance and therefore attract no further call charge beyond the monthly package price.



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One respondent thought it was a good idea as long as the cost was shared jointly with mobile phone providers.

That's the current arrangement, where callers (from landlines and mobiles) pay a Service Charge on calls to 084 numbers. The proposal is to ban the collection of a Service Charge by moving away from any such number.


On the proposal to introduce a geographic number for each practice...


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All GP practices would be required to use geographical numbers. There would be a grace period for each practice which had to change to enable current contracts to end without incurring unnecessary financial penalty to the practice. Do you agree with this proposal?

Practices should be free to choose an 01, 02, 03 or 080 number, but must fund any enhanced call features themselves. There should be no grace period as a migration from 084 to another number range can be arranged at any time and without penalty within the lifetime of a telephone services contract. As such, there will be no early termination fees to contend with.



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Any grace period should be kept to a minimum as it is free to migrate from 084 to 034 numbers now

The same is true for a migration to an 01, 02, 03 or 080 number.



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Geographical numbers now have all the facilities that previously only used to be available to 084 so therefore there is no reason not to change back.

It is these facilities, not the actual number, that incur the additional running costs. The cost to the practice will be the same irrespective of whether a 'virtual' 01 or 02 number or a 'non-geographic' 030 or 034 number is used.


Summary section...


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Several respondents across the stakeholder groups felt that a blanket ban on 084 numbers would be the best course of action as it would ensure fairness of pricing for all members of society, however caveated with allowing a grace period to allow those practices who are in contracts to expire naturally rather than pay compensation for early termination.

No grace period is necessary, as noted above.



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The majority of people thought that the most obvious and sensible solution would be to have every GP surgery with a local geographical number (01). Several reasons were cited for this including local identity, cost of calling kept at its lowest and that it would also be easier for the elderly or infirm to type the number as the area code could be omitted if calling locally.

If the local (01) number comes with enhanced telephony facilities, the cost to the practice will be the same as for an 030 or 034 number. Moving from 084 to 034 represents the simplest possible change of number.