http://www.ofcom.org.uk/consult/condocs/three_number_non_emergency/summary/

Executive Summary

1.1 Ofcom (The Office of Communications) is undertaking this consultation in order to meet a request from the Department of Health ("DH") in England for the designation of a three-digit telephone number to access NHS non-emergency healthcare services in England. The aim of the service to be provided via the number is to act an entry point for patients seeking NHS services: trained call-handlers will respond to requests for health or service information (whether urgent of not) and assess the medical needs of callers to identify which NHS services are best place to meet those needs.

1.2 The three-digit telephone number will initially be piloted in a number of Strategic Health Authority ("SHA") areas in England from spring 2010 but the intention is for the service to be fully rolled out across England in the long-term, subject to a positive evaluation of those pilots. The DH has decided on the underlying policy behind the service and this consultation relates only to the communications issues, for which Ofcom has responsibility.

1.3 The devolved administrations may also consider whether to introduce the three-digit number with a similar or comparable service in Wales, Scotland and Northern Ireland respectively. However, given that this consultation is based on a DH initiative, we have focussed on the proposed service as envisaged in England and have referred to the devolved administrations where appropriate.

1.4 As the regulator responsible for communications matters in the UK, including the administration of the UKs numbering resource, we have been asked by the DH to make a three-digit telephone number available for the delivery of its proposed non-emergency healthcare service. In order to make such number available for use by all communications providers, we would need to add it to the list of numbers in General Condition 17 of the General Conditions of Entitlement, which covers the allocation, adoption and use of telephone numbers (the "Numbering Condition").

1.5 The DH has chosen 111 as its preferred number for the service. We advised the DH on available number options, including full length numbers from existing ranges in the National Telephone Numbering Plan (the "Numbering Plan"). The DH considered these options and decided that a three-digit number (similar to the 999 and 112 numbers used by the emergency services, and the 101 non-emergency number initiated by the Home Office) would be the most suitable choice. It concluded that, of the possible three-digit numbers available, 111 was its preferred option.

1.6 While the DH is committed to the provision of the proposed service on a three-digit number, other options are available. The purpose of this document, therefore, is to seek stakeholders views on the DHs preferred and alternative numbering options, and to set out why the DH has chosen the three-digit number 111 for its proposed service.

1.7 As regards to the tariff for the number, three-digit numbers have no inherent tariff structure. The DH plans to implement the tariff for the number through negotiation with the selected service provider and communications providers. The DH has drawn up potential tariff options and we have set out these options on behalf of the DH. We do not propose to intervene in setting the tariff for the number and this consultation does not therefore propose regulatory measures on the matter of call charges. As the tariff will not be regulated, each tariff option could vary depending on the operator, and the price will depend on the commercial arrangements of each operator. The DH has pointed out that experience with 101 (the three-digit number initiated by the Home Office) showed that negotiation with telecoms providers can result in the same call charge across virtually all operators. Nevertheless, as the call charge will be a commercial decision by each provider, we will keep open the option to revisit the tariff issue at a later stage if it proves appropriate. If it is necessary for us to consider regulatory measures on the tariff in the future, we would need to carry out a further consultation on the specific issues and proposals.

1.8 The main body of this document sets out the background of the proposed service and a discussion on the options for the number and tariff. Section 4 also contains an impact assessment which evaluates the different options for the number. In addition, Annex 8 contains a draft notification of the necessary modification to the Numbering Condition in order to designate 111 for "Access to NHS Non-Emergency Healthcare Services" (Type A Access Code).

1.9 We invite comments on the draft notification, the specific consultation questions we have set out, as well as on the issues raised generally in this consultation document, by 20 August 2009.

http://www.ofcom.org.uk/consult/condocs/three_number_non_emergency/main.pdf

irrelevant wrote on Jul 9^th, 2009 at 3:31pm:

Although most residential call packages currently offer the same rate for both, the distinction does still exist. Nothing is being misrepresented here - it is misrepresntations (e.g. of 084 as "local") that we must attack.

Comments on the proposal are found in the media.

It is now seen that the NHS Direct service will definitely continue as it is on 0845 4647, if only for a few years before 111 replaces it. A complete number change to 0345 4647 would therefore not be appropriate. For the benefit of those who incur premium rates in calling 0845 numbers, 0345 4647 must therefore be switched on immediately as an alternative.

The issue of what rate will be applied can be covered in the Ofcom consultation, however it will come down to the DH negotiating terms with the telephone service providers.

I understand "free at the point of need" to refer to the delivery of the health care, not to the absence of any incidental costs e.g. the bus fare to the doctor's surgery. If the service is being delivered, rather than accessed, by telephone then this becomes more difficult, as the cost of the telephone call ceases to be incidental. There could be an argument for the NHS (i.e. the taxpayer) bearing the full cost of the service, with zero call charges for all, however this is not the way that the DH is thinking.

The problem with the "standard (i.e. 01/02/03) rate" approach, which is the best available for ordinary telephone numbers (i.e. those starting with 0), is that it reflects the particular tariff applicable to the caller's telephone service. The 101 model, which is being used as a base point, disregards whether one is on an inclusive package, a landline or a mobile etc, and simply charges 10p for any call of any duration. This is agreed, by negotiation, to represent the level at which telephone companies recover their costs overall, as no other money changes hands in relation to their delivery of the service as originators. The fixed fee is seen as being the fairest way to distribute the costs amongst callers.

For the health number, I would be happy with a "standard" approach, a universal rate per minute or a universal fixed fee (whichever is thought fairest). Before hearing the arguments and considering the implications, I have not formed a view. I would however strongly suggest that call inclusive packages be adapted to include calls to this number.

Immediate responses to the news reflect Ofcom's concern about the suitability of 111. It is the numbering issue that is likely to dominate discussion in the present consultation, pricing comes later.

I have little fear that this matter will get into the issue of "revenue sharing", as I believe that the point made in this forum and elsewhere about NHS Direct has been accepted.

I want to see this matter used to put pressure on the need to do something with NHS Direct immediately (see my previous posting). It can also be helpful in relation to GPs and others with 084 numbers. The argument must be that they need to change to avoid those who refuse to contribute to a revenue share invariably trying to contact them via 111, and refusing to re-dial.

SilentCallsVictim wrote on Jul 10^th, 2009 at 11:07am:



Brilliant. Sums it up well.

Having now reviewed the complete consultation document to pick out key points, it may be helpful for me to share some of these. I focus on matters relevant to the forum.

I quote directly from Ofcom (commenting in italics and placing textual additions / alterations in brackets) – I suggest using a word search to locate the extracts in context.

• [The only three digit] Codes still available for service designation are: 102 103 104 105 106 107 108 109 110 111 113 114 115 117 119
• We advised the DH on available number options ... 111 was its preferred option ... other options are available – no change (i.e. maintain existing NHS Direct 0845 4647 number), number from the Numbering Plan (e.g. 030), Harmonised European six digit number starting with 116.
• During the pilot stage, anyone ringing the NHS Direct number from the pilot areas would be re-routed through to the new 111 service. Similarly any calls made to 111 from non-participating areas will be routed to NHS Direct. In the long term 0845 4647 could be switched off. All services currently provided by NHS Direct would be accessible through 111.
  
  This statement, from the DH in the annex, appears to contradict the statement in the DH news release “111 will not replace existing local telephone services or NHS Direct”. My argument that 0345 4647 should now be turned on as an alternative however still stands. Indeed, if so, that would provide a bulwark against 111 being more expensive to call.
• If the DH were to [retain the] existing [NHS Direct] number they may, nevertheless, need to consider changing the number to 0345 4647 or another 03 number in the light of its recent consultation.
  
  Interesting that Ofcom appears to think that something will, or should, come of the DH consultation.
• [The DH] recently issued a consultation to gather views on how valuable the extra functions provided by 084 numbers are and how they might otherwise be provided without patients having to pay more than the cost of a local call rate for them, for example by using 03 numbers instead.
  
  Ofcom expresses its view on what the outcome of the DH consultation might be. A possible return to geographic numbers with the same features specially deployed is not precluded by use of “for example”.
• The DH’s initial assumption is that callers should contribute to the cost of the telecommunications element of calling the proposed service.
• Three-digit numbers have no inherent tariff structure ... We do not propose to intervene in setting the tariff for the number
• Our position is that it is inappropriate for public bodies to rely on chargeable 08 numbers exclusively (i.e. without, at a minimum, giving equal prominence to a geographic number alternative)
  
  Ofcom goes on to say that, although it holds this position, it does not however believe that it has the powers or the duty to impose this view over that of other (more directly accountable!) public bodies.
• The DH has considered the possible tariff arrangements and has selected the following potential options for specific consideration by stakeholders: free to caller, 10 pence per call, 3 pence per minute or genuine local or national rate (i.e. charged the same as a landline call or a call to an 03 number).
  
  We know that local and national rate are commonly the same on residential packages.

The three research reports referred to are available at http://www.dh.gov.uk/en/Healthcare/Urgentcare/3DN/index.htm (one level below the URL given).

Although not a matter for Ofcom, the DH has asked it to invite comments on the pricing options. This is a little difficult, as if the telecommunications element of the service is to be self-funding, respondents have to assume that their proposals would be found acceptable by all the telcos. We must accept that this will have to be something of a fudge and the emphasis is presently on the same approach as used with 101. I believe that the only way it could work would be to demand use of the same call pricing model as 03, with the DH negotiating with each operator over a supplementary payment if they feel that this does not adequately cover their costs.

101 has failed as a national scheme and therefore does not provide a good model, as it relied on central funding which was withdrawn. It will be the government that will emerge from the next parliament (of whatever party or parties) which will have to implement this. Is it likely to be in favour of greater central control and public spending on the NHS, or more devolution of decision making to local bodies, with choice about spending exercised at the lowest possible level?

If a discussion develops here I will offer further comments.

So far as I can see the whole of this disgusting latest so called "consultation" is simply a bid to play for about another two to three years delay while New Labour assures its telecoms buddies that the revenue share gravy train that it allowed to be set up will not be stopped by it but only by any successor political party who will not have been subject to the same need to keep their friends in the call centre industry happy as New Labour has.

Only the abolition of New Labour and its creature Ofcom offers any hope that the continued scamming of the telecoms consumer by the state will finally be brought to an end.

loddon wrote on Jul 18^th, 2009 at 3:15pm:


Surely we already know the answer from the new ludicrous consultation on a useless single three digit health service number even though these numbers have already been proven to be a failure and unworkable from the experiences in trialling them by the Police.

Clearly the only point of this consultation is to play for time thereby ensuring that a New Labour government is not responsible for derailing the health service revenue sharing gravy train.

If SCV can offer us a version of his above comments in his last post translated in to plain English then I for one would certainly be interested to read them.