bazzerfewi wrote on Nov 27
th, 2011 at 1:05pm:
... As usual the Government have only covered half the options and they did not legislate in regard to 03 numbers. If they stated all GPs must use numbers from the 03 range surely this would have closed all the loop holes because "Daisy Practice" only provides this service because it is profitable.
What can we do - there must be another agnle!!!!
You are correct, there is no good reason why there could not have been some agreement with NEG, at is was at the time, to only offer 03 numbers to GPs and migrate all of its existing GP customers onto 03. The bad reason is probably that NEG would not have been prepared to enter into such an agreement on terms that the BMA would have thought acceptable.
After making such a terrible mistake in 2004, by prohibiting specific number ranges, but getting it wrong, the DH was reluctant to be specific about what could, should and could not be done. The contract does however address migration to 03 in non-specific terms.
Those with non-geographic numbers in place on 1 April 2010 are required to "take all reasonable steps" including considering "varying the terms of their arrangement" so as to ensure that "persons will not pay any more to make relevant calls to the practice than they would to make equivalent calls to a geographical number". Without being specific, but noting that it is standard industry practice for telephone service providers to allow migration to 03 at any point during the term of an arrangement, without penalty, this amounts to saying that they must attempt to migrate to 03, if they require, or are obliged to use, a non-geographic number.
The problem is that, because this is so fiercely opposed by both the BMA GPC and NEG / Daisy, it has not been considered appropriate to make it clear that migration to 03 must be considered. If Daisy were to deviate from standard industry practice by refusing migration to 03 on reasonable terms, then there is nothing that could be done about the GPs under the terms of their NHS contract - because this cannot demand unreasonable costs to be incurred under the terms of pre-existing arrangements.
I am assuming that the BMA is opposed to migration, because this would cause its members to incur the absurdly high costs of the Surgery Line solution in full. Likewise I assume that Daisy is opposed because this would make its solution appear too expensive. In both cases, they think it better that callers / patients should subsidise the cost of the Surgery Line system. It is however fair to point out that they both argue that the telephone companies should not pass on the cost of the revenue share to callers; they even pretend that in some cases the cost is not passed on. I totally disagree - and so does Ofcom.
In the case of new Surgery Line customers, the situation is more straightforward - a 03 number would pass the test which practices have to make, a 084 number is bound to fail.
One reason for the confusion is that fact that when this was being done in 2009, Ofcom was considering what to do about 0845 numbers. One of the options being considered was treating them in the same way as 03 numbers - as it had recently (almost) done with 0870. If Ofcom had gone ahead in this way (in fact it has now specifically rejected this option) then 0845 numbers would have passed the test from the date when the changes came into effect.
I have some sympathy with the DH's reluctance to be specific in drafting contracts and regulations. The problem is that those who have to implement and enforce the terms need assistance in understanding what they mean in the world as it exists. When authoritative assistance is only offered by those who are opposed to the intentions of the contract revisions, then it can be of little surprise that implementation is ineffective.