03 is the way forward - says the BBC

After being subjected to much campaigning, the BBC has now started using 03xx numbers for viewers and listeners to make contact. 03xx numbers are charged at no greater rate than that for calling a "geographic" (01/02) number. This applies (by regulation and as seen in practice) to all types of telephone service and all tariffs, including the terms of inclusive packages.

BBC 0870 numbers have been changed to their 0370 equivalent, although it still has many 0845 numbers that need to be changed to 0345.

A major breakthrough was seen yesterday with "Question Time" as shown below:

Thursday 22 July 2010

Thursday 16 September 2010

THIS MUST SERVE AS AN EXCELLANT EXAMPLE TO ALL OTHER PUBLIC SERVICE PROVIDERS

(A new 0330 number had to be chosen in this case, because it is only 0870 and 0845 that have the direct equivalent 03xx numbers available.)

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(N.B. See the UPDATE to the points which follow - 22 Jan 2012)

Some more work to do

The explanatory text in the new caption may be factually correct, but it is seriously misleading.

1. "Standard geographic charges apply"

That is sufficient.

2. "... and calls may not be included in your telecom provider's call package."

If geographic calls are included in a call package then calls to 03 numbers must be also. Obviously geographic calls may not be included, in which case 03 calls will not be. The statement is true, but is it relevant?

3. "Calls from mobiles may be higher."

The rule that the charge for a call to a 03 number can be no greater than that for a standard geographic number ("geographic charges apply") applies to all telephone services, including mobiles. Charges for calls from mobiles are known to generally be higher than those from landlines. The statement is true, but is it relevant?

The second and third statements are true for both 03 and geographic numbers. Presented as they are, it would not be immediately obvious that they apply equally to geographic numbers. Viewers may well be led to believe that these statements qualify the initial statement, rather than simply adding general information. For this reason they are seriously misleading.

I have proposed the following alternative to the BBC:

"standard geographic charges apply to all tariffs and types of telephone service".

If it wishes to add "call charges vary", then it could.

0845 telephone numbers - JobCentre Plus, the DWP and other public bodies

This extended briefing addresses confusion and uncertainty at the DWP. It also pre-announces the launch of a specific campaign to restore equity to the cost of accessing public services, which is adapted to the demands of the present financial situation. (See My Proposal.)

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Following its recent excellent action in making 0800 numbers free to call from mobiles, it is most disappointing to find the DWP agencies still unable to resolve the situation with their expensive 0845 numbers, by recognising that they must switch to 03xx numbers. Calls to 03xx numbers are charged at the same rate as calls to geographic numbers.

A written ministerial answer provided to Caroline Lucas MP fudges the issue with misleading and false information. I am amazed that the DWP still either does not understand the truth of the situation, or deliberately seeks to mislead.

In response to this written answer, I have provided a full briefing to Dr Lucas, Mr Webb and Mr Singh, which is published at this link.

I have also added an annotation to the published record.

Answering the "impossible" question

I provide answers to what is said to be an "impossible" question - "what does it cost claimants to call 0845 numbers used by the DWP?"

£	On average they pay £1.24 per call. For a 03xx (or geographic) number, this would be £0.51, less than half the cost.

(Details of the basis for this calculation of a weighted average cost based on the likely usage of particular tariffs are given in my full briefing.)

It is straightforward to provide figures taken directly from published tariffs, using the DWP assumption of an average call being of 10 minutes. The cost of calling a 0845 number is compared with that for a 03xx (or geographic) number.

£	If calling from a public payphone - £2.40 (vs. £0.60)
£	From a typical PAYG mobile - £4.15 (vs. £1.65)
£	From a typical contract mobile with inclusive landline calls - £2.00 (vs. 0)
£	Those who are at home all day with a Virgin Media landline - £1.12 (vs. 0)

These same figures obviously apply to a 10-minute call to NHS Direct, HMRC enquiry lines or any other 0845 number.

What the DWP (and other public bodies) must now do

"Virtual telephony networks", such as those used by DWP, can be accessed using 03xx or 08xx numbers.

With 0845 numbers, surcharges are levied on callers because part of the call price is used to subsidise the cost of the "virtual telephone network", through "revenue sharing" between the originating and terminating telephone companies. When calling a 0845 number, you are not only paying whilst you wait to be answered by an agent you are also paying extra for the provision of the facilities that route your call, allow you to queue and provide management information.

With a 03xx number, callers pay no more than they would to call an ordinary "geographic" number (01/02). This is by regulation, which applies to all companies providing landlines, mobiles and payphones, including the terms of unlimited packages and bundles. Revenue sharing is prohibited on 03xx numbers.

There is currently no regulation on the extent of the premium charge that may be levied for calling a 0845 number. The examples given above are typical, however there are over 200 registered providers of telephone service in the UK and each of them has many different tariffs. They all incur greater costs in originating calls to 0845 and other revenue sharing numbers.

All public service providers that require the facilities available with “non-geographic” numbers must switch to 03xx numbers.

These provide equity and an assurance that callers are paying no more than the cost of an ordinary call, whatever that may be. Most importantly, with a 03 number it can be stated that the recipient is not benefitting in any way from any surcharge.

(If choosing to retain 0845 numbers public bodies must acknowledge and justify the imposition of service charges, at levels outside their control, on callers.)

BT Landlines - the exception

BT alone is subject to legacy regulation of its charges for landline calls to 0845 (and other "NTS") numbers; it is prevented from making any money on originating these calls. This unique special status and the consequent perverse low charges mean that BT should never be used as an example of the cost of calling 0845 numbers.

The level of BT's charges for geographic calls (including that for 03xx numbers) is not regulated. As these calls are included in unlimited Call Plans, its standard charge is zero. The penalty charge which BT imposes for making these calls outside the terms of a Call Plan continues to increase at an annual rate of 30% with the latest announced revisions.

Contrary to what is implied in the written answer, BT only originates 42.2% of residential landline calls, 31.4% of residential calls from either mobiles or landlines.

28% of socio-economic group DE households do not have a landline from any provider.

It can no longer be assumed that telephone calls from BT are the "norm" and that other rates can be disregarded.

Fair and equitable charges for accessing public services

Whilst some private companies are happy to receive money from customers who call them on revenue sharing numbers, I have always argued that it is not acceptable for public service users to have to meet the costs of a public body as they use its services. With some exceptions, I see it as generally acceptable for service users to themselves incur the expense (if any) of a normal call using their chosen telephone service provider, rather than having this expense reimbursed by the taxpayer.

For this reason it is vital that public bodies currently using 0845 numbers move over to 03xx numbers as quickly as possible.

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My proposal

To avoid the cost and disruption involved with a complete number change, there is a simple solution.

The 0345 equivalent of every 0845 number is reserved for use as a replacement or alternative. This feature could be used to enable equity to be re-established without the disruption and expense of lots of individual number changes.

The 0345 alternative for every 0845 number used by a public body should be immediately switched on.

Every public body that accepts the principle of equity and wishes to cease charging for access to its services could make a simple arrangement with its existing telephone service provider and issue a simple statement:

"All telephone services can be accessed by replacing the 0845 code with 0345 and dialling the remaining digits as stated".

This statement (perhaps better worded) must be made widely, however I do not see it as being essential that every number be printed twice wherever it appears. No existing publication would need to be changed. It would be for those of us who believe in equity to play a part in helping to spread the word.

My targets

There are three public bodies which are major users of 0845 numbers. They have all been thinking about this for a long time:

·       The DWP and its agencies. To its credit, DWP has already dealt with the problem of 0800 calls from mobiles. It now needs to finish the job by dealing with its 0845 numbers.

·       HMRC. Under attack for its problem with miscoding, HMRC angers people further by inviting enquiries about this to be made by calling one of its many 0845 numbers. The general issue of its use of 0845 numbers is already under formal review. Other users of 0845 and 0844 numbers are however representing the public interest in this exercise.

·       The NHS. Directions to NHS bodies and changes to the GP contract require cessation of the use of expensive telephone numbers by 19 December 2010 and 31 March 2011 respectively. Most of those with 0845 and 0844 numbers have not yet changed and will now need to move swiftly to comply with these requirements. (The equivalent 0344 alternative is available for GPs and hospitals that use the even more expensive 0844 numbers.)

Saving money

Although the benefit of subsidy towards the cost of advanced telephony would be lost - quite rightly as this is totally improper - those who make this move would find that they save themselves money overall. They all currently have a policy of calling back to those who cannot afford (or do not wish to incur) the premium charge which most callers suffer on 0845 numbers.

The level of the subsidy received (around 2p per call minute) is not only far less than the surcharge incurred by callers, it is also modest when compared to the cost of making a return call. By avoiding unnecessary callbacks, which are also very inconvenient and far more costly in agents' time, those who adopt this approach will save money, rather than incurring additional cost.

Fully planned rationalisation and changes of number is what should be done. In the current financial environment however, this will perhaps have to be deferred, as it can be a very costly exercise.

With household and public sector budgets under pressure and the vital need to ensure that the impact of cutbacks is distributed fairly - now must be the time to follow this simple and cost saving solution to a longstanding problem.

Ministerial briefing - Fees for access to public services by telephone (in particular HMRC, also DWP agencies)

I quote below a briefing message sent to Ministers in the Treasury with responsibility for HMRC and Tax Credits.

Sent: 07 June 2010 06:54
To: Justine Greening MP - Economic Secretary – HM Treasury; David Gauke MP - Exchequer Secretary – HM Treasury

Ms Greening
Mr Gauke

Briefing from: David Hickson - Public Services Campaigner

I am perhaps best known for my work on seeking to expose and expunge the scandal of charging for access to NHS services through use of expensive telephone numbers. My focus on this issue does however extend across the public sector. The NHS Constitution prohibits charging fees for access to NHS services, by statute. I understand that no such constraint applies to HMRC services such as Tax Credits, or to the services provided by DWP agencies.

This briefing is intended to draw your attention to the fact that HMRC deliberately charges users for access to its services by telephone. Exactly the same situation applies across many DWP agencies, so all of my comments may be taken as being generally, if not specifically, relevant to them also.

I understand that you hold ministerial responsibility for development and implementation of government policy in relation to, respectively, Tax Credits and the activities of HMRC. I copy your ministerial colleagues holding equivalent responsibilities for the DWP agencies.

0845 numbers

Most HMRC (and DWP agency) telephone services are provided using 0845 telephone numbers. These numbers are all subject to "revenue sharing", whereby the call originating telephone company pays over an amount of additional money to the "terminating" telephone company, i.e. that serving HMRC, at an agreed rate per minute with each call.

Whether the telephone company serving HMRC pays on this benefit in cash, or reflects it in a discount, or a waiver of charges that would otherwise be levied, on services provided, is immaterial. If HMRC is allowing its telephone company to retain this money or if it is being directed elsewhere, then this is an even greater scandal. One therefore hopes that receipt of this financial benefit would not be denied.

Most originating telephone companies reflect this additional cost to them in surcharged rates for 0845 calls. As the largest provider (originating nearly 25% of telephone calls) BT is uniquely regulated to prevent it from doing so. To evade this regulation, BT now offers 0845 calls as inclusive in its packages. This enables a value equivalent to the surcharge to be reflected in its calculation of the bundled price charged for the package. This can be seen from the fact that the price of BT packages was increased a few weeks after 0845 calls were made inclusive in 2009.

Wherever a 0845 number is used, callers are subsidising the costs of the organisation called through surcharges on their telephone bill. This subsidy is obtained indirectly and the cost is generally part of an aggregate call charge, although it may be further hidden within a bundled package fee. Furthermore, the benefit received may be concealed by a discounted, or waived, charge for services, rather than in a potentially embarrassing “cashback”. (DWP made the switch from the latter to the former some years ago; the COI formally recommends this concealment of the benefit.)

This is nonetheless a service fee and should be clearly declared as such. It applies regardless of the total call cost incurred, which will of course vary as a result of the caller's choice of telephone service provider and tariff. It is important to understand that, put simply, the actual cost of calling any 084 number invariably includes two components representing: the amount retained by the originating telephone company itself, and the surcharge which is passed on to the benefit of the recipient of the call. Under current regulations there is no requirement to show these separately.

Alternative geographic numbers

There may have been doubt about whether HMRC is collecting this service fee deliberately. I must report having now discovered that that it is.

HMRC publishes some "geographic" numbers for use by callers from overseas, e.g. 01355 359007 as an alternative to 0845 300 3900. Those who try to access the services from the UK using these numbers are told to re-dial using the 0845 number.

I had, perhaps naively, assumed that this could be because these numbers offer some service features properly reserved for the exclusive benefit of overseas callers, e.g. shorter waiting times or specialist advisers. I have now confirmed that this is not the case. These numbers place callers in exactly the same queue to be answered by the same agents as those calling the 0845 number. The only reason for requiring UK callers to redial therefore is so that HMRC (through its telephone service provider) may benefit from the "revenue share", with the consequence that callers incur a higher charge.

I understand that the geographic numbers are provided because it is not possible to dial +44 845 from all international locations. They give exactly the same access as the 0845 numbers, but specific measures are in place to prevent UK callers from using them. This same revenue protection technique is used by many private companies with premium rate service numbers.

Deliberate imposition of a fee to access public services

Having been rather gentle in my representations on this matter in the past, I am now absolutely furious to learn that HMRC is deliberately levying a fee for access to the services it provides by telephone. I now know that there is no other reason for denying access to UK callers through the geographic numbers.

The service referred to above is the "Tax Credits Helpline", only one example, but perhaps the most disturbing in the context of HMRC. Whilst many benefit claimants may complain about paying their own telephone service provider whilst waiting in a lengthy queue for their enquiry to be handled, they may see it as a scandal that they are also required to pay at a premium rate to the benefit of HMRC (and similarly DWP agencies) for whatever may be the entire duration of the call. At the very least, the fact that this fee is imposed on benefit claimants must be openly declared.

Under present regulations it is not possible to specify the amount of the surcharge incurred, as this is seen to vary between providers. Furthermore, the extent to which some providers profiteer on the back of those who directly benefit from revenue sharing may be seen to be commercially confidential. Some might comment how convenient it is that the scale of this Stealth Tax has to be kept secret! Others would say that the only valid taxation is that which is open and transparent and it should not be subject to profiteering by those who collect it indirectly!

Is this government policy?

This matter was brought to the attention of the previous government in respect of both HMRC and the DWP agencies, which operate in very similar ways. The issue was under some type of formal departmental review in both cases when the previous government resigned.

By copy of this message, I bring my discovery of the deliberate nature of what is being done to the attention of officials in both Departments and (by blind copy) to many MPs with constituents who are known to have relevant concerns. With principles of equity and fairness underlying all that the present government is seeking to do, I am sure that this matter will receive the most urgent possible attention, according to the importance which is attached to it.

I also copy the Chairman of the Contact Council, a body within the Cabinet Office, and to the relevant CO officials and the Minister. This body started work on addressing this issue for the public sector as a whole over twelve months ago. After benefitting from my active engagement and support, that work has apparently been abandoned with no outcome whatsoever. Information from Departments that was due to be provided to it by last July has apparently still not been received.

The Contact Council is charged to ensure that Departments (and all other public bodies) are aware of the fact that 03 numbers should now be used where the benefits of a non-geographic number are required and a service charge on service users is not appropriate. 03 numbers are cost-neutral in respect of the relationship between the caller and the called and are therefore suitable for use where no fee is to be charged for access to a service provided by telephone. By regulation, revenue sharing is prohibited on 03 numbers and the cost of calling cannot be any greater than that of calling a geographic number. The latter requirement applies to all types of telephone service and covers the terms of call-inclusive packages.

The essential facts are now well known and recognised – I do not believe the work that has already been done yielded no information whatsoever. I believe that the new government must immediately establish a position of principle on whether these service fees are to be allowed to continue. Detailed points about the level at which they set, to which service users they are to apply and the when and how of them perhaps being withdrawn, can be addressed in due course for each particular case.

If the fiscal situation demands that benefit claimants and other users of public services accessed by telephone must continue to pay service fees to the provider agency, then let us at least be able to discuss this openly and honestly. One is led to understand that the political gimmick of Stealth Taxation has had its day.

Perhaps the forthcoming budget statement would provide a good opportunity for the government to announce that this Stealth Tax on benefit claimants and those who question their taxes is now to be brought out of the shadows and confirmed as one of the measures being used to address the deficit. Its recognition may help the programme of deficit reduction further, by providing an open disincentive to claim benefits or challenge tax demands.

If one change to our way of life will be accepting that we must pay fees to access public services, when this has previously been done in secret, then that is for the government to propose to parliament and perhaps debate with the people.

To help encourage and inform such public debate, I copy this message with a statement to the media.

I will be delighted to help anyone with further information and comment on this matter. I also remain happy to assist in any way I can to ensure a proper and sensible resolution of this issue.

The story so far

This blog has been started to cover wider issues that have been followed for some time and covered elsewhere.

See the full list of noted items:



These items can also be viewed as Campaign events