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Risks to clinically vulnerable people

Letter of response sent 14 September to Samantha Allen, from the Director of Retail at the Office of Gas and Electricity Markets (OFGEM). Note: Letter sent to OFGEM is below this.


Samantha Allen
Chief Executive
NHS North East and North Cumbria                 

Dear Samantha,

Letter regarding support for vulnerable consumers and disconnection prevention

Thank you for your letter dated 2 September regarding vulnerable consumers and hospital admissions this winter. We recognise your concern for the difficulties faced by consumers now and into this coming winter.

I speak to consumers and consumer groups on a regular basis and understand the deep pressure and anxiety this cost-of-living crisis is inflicting. With wholesale energy prices at over ten times what we would expect during a normal year, this is causing intense pressure across the breadth of society. However, this pressure is particularly acute for those who are clinically vulnerable. Our paramount concern is to protect consumers and to ensure they are treated fairly, and we are doing everything within our remit to address this. We are working around the clock with the Government, energy suppliers, non-governmental organisations and consumer groups to make sure consumers pay no more than is necessary and are supported in any way possible. Given the recent appointment of our new Prime Minister, we welcome the announcements for significant and unprecedented support for energy consumers and we look forward to continuing to work with government to provide this much needed help to consumers.

We understand your concern on disconnection, and particularly the implications this would have on those who rely on electrical medical equipment. We have licence conditions protecting consumers from improper disconnection, and as a result it is very rare for a supplier to disconnect a customer for debt. Between January to December 2021 there were 21 electricity disconnections and 0 disconnections for gas. We have investigated these disconnections and are satisfied in this instance that there were no consumers in vulnerable circumstances residing at the properties. We continue to monitor disconnection data and support. Further data, incorporating up to, and including, Q2 22 data, will be published at the end of September in our latest Social Obligations Reporting update. 

Regarding pre-payment meters, we have strict rules in place which depict the processes to ensure that all adequate measures are taken before placing a consumer on a prepayment meter as a last resort, ensuring that a PPM is safe and reasonably practicable for customers prior to installation and where already in use and the supplier becomes aware or has reason to believe that it is no longer safe and reasonably practicable for the customer to do so, suppliers must offer alternatives. We expect suppliers to treat consumers on a case-by-case basis, and to reach out where they think they may need support. Our rules also include supplier provision of emergency, friendly and additional support credit. In addition, some energy suppliers (covering around 80% of the domestic market) are also signatories of the Energy UK Vulnerability Commitments which further protects vulnerable consumers through mitigating improper service. Alongside supporting consumer groups to assist consumer resolutions, we will continue to closely monitor disconnection data and supplier behaviour to ensure consumers are adequately protected.

We recognise that self-disconnection is also an issue, alongside energy rationing which may exacerbate or result in health conditions deriving from cold and damp living conditions. Given the unprecedented prices, we anticipate that rates of self-disconnection will likely increase as we head into this difficult winter. As such, we are increasing communication efforts, and encouraging suppliers to do the same, to make consumers aware of their rights and the support available this winter. I encourage you to build upon this by ensuring staff are aware of, and have an ability to signpost patients to, the upcoming Energy Bill Support Scheme, commencing in October, and to range of support available for those struggling to pay their bills, including:

In addition to the above support and our existing licence conditions and commitments, we are running a series of Market Compliance Reviews. These reviews are invasive and assess supplier control frameworks and the outcomes for customers. They cover a range of issues including customers in payment difficulty and the identification and support of customers in vulnerable circumstances. We intervene where suppliers fall short of expectations using our  compliance and enforcement powers, to ensure the fair treatment of customers.

On your point regarding supplier clinically vulnerable patients list, we strongly recommend that vulnerable consumers reach out to their energy supplier to make them aware of their circumstances and to register for the Priority Services Register. This provides valuable support for vulnerable consumers or for those with additional needs, including advanced notice of scheduled power cuts and priority support in an emergency. Suppliers should be advising and recommending that eligible consumers are added to the register. We will continue monitoring to ensure that suppliers are doing so efficiently and are protecting consumers in line with our expectations.

Thank you again for your engagement and for raising your concerns. If you have any further detail of the suppliers causing particular concern for patients, please do let us know so we can further investigate these claims. We also encourage impacted citizens to contact us directly at consumeraffairs@ofgem.gov.uk so we can best resolve any problems.

I would like to extend my support to yourself and your colleagues as we enter a challenging winter that is felt across the breadth of society and its sectors, and I do hope the above has provided some clarity on your concerns.

Yours sincerely,

Neil Lawrence
Director of Retail

Letter sent 2 September 2022 to the chief executive of the Office of Gas and Electricity Markets (OFGEM) from the North East and North Cumbria Integrated Care Board.


Mr Brearley
Chief Executive

Dear Mr Brearley,

I am writing to you in my capacity as Chief Executive of NHS North East and North Cumbria Integrated Care Board about the serious concerns I have that clinically vulnerable people, in our community, may have their electricity or gas services disconnected as a result of non-payment.

We serve a population of 3.2 million people covering some extremely rural and deprived communities. Whilst I appreciate the ongoing national and international context companies are operating within, it is not my role to comment on or be drawn into a debate regarding this. However, it is my duty to ensure we do all we can to reduce the health inequalities those across our communities' experience, improve their health outcomes and ensure the safety of our patients. It has come to light that we are starting to see examples where clinically vulnerable people have been disconnected from their home energy supply which has then led to a hospital admission. This is impacting on people who live independently at home, with the support from our community health services team and are reliant on using electric devices for survival. An example of this is oxygen; there will be many other examples. There is also a similar concern for clinically vulnerable people with mental health needs who may find themselves without energy supply. 

It is my understanding that those people deemed clinically vulnerable cannot have their energy supply disconnected. Based on some examples, along with the contact we are having with many clinically vulnerable people, it is clear that significant concern exists across our communities.

Put simply, the impact of having their energy supply terminated will be life-threatening for some people. All of this will place additional demands on already stretched health and social care services.

This increased demand not only limits the NHS ability to provide treatment to those who need help most but there is also evidence that unnecessary admission to hospital can negatively affect a person's quality of life and health outcomes.

I, therefore, call upon you the Regulator to work urgently with the energy companies to:

1. Ensure the clinically vulnerable patient lists they hold are fully updated frequently and checked before considering terminating supply.
2. Develop a fail-safe system to ensure new patients being added to a clinically vulnerable patient list are covered (have energy supply) immediately.
3. Embark on a proactive communications campaign to ensure the public are aware of their rights regarding this.
4. Supply the NHS with the information it needs to be able to advise patients if they are at risk of being disconnected.
5. Have a senior responsible officer in each energy company who will act as a lead for the NHS and social care to discuss concerns regarding clinically vulnerable people and their energy supply.

I am sure you will appreciate the importance of this work and the need to have a systematic approach to ensuring clinically vulnerable patients are never disconnected.

We need to do all in our collective power to support people to maintain their independence safely in their own homes and this should not be jeopardised by having their energy supply terminated.

Finally, as energy prices rise, we are all conscious of the impact this will have on those people who cannot afford to pay for their energy. This is of grave concern to everyone, I am sure, especially given the evidence relating to excess winter deaths and serious illnesses as a result of cold weather. I, therefore, ask you to reconsider the disconnection policy for all energy companies and mirror that which is in place within the Water Industry where domestic supplies cannot be disconnected. In doing so, I am confident that this will save lives.

I look forward to your urgent response.

Yours sincerely

Samantha Allen

Chief Executive

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