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In the autumn statement, the government announced a consultation on creating a multi-sector Priority Service Register (PSR).
We applaud this ambition. In 10 years working as a caseworker looking after vulnerable customers, I saw first-hand the costs of the current PSR system.
Its fragmented nature, with each supplier running their own register, creates an additional impediment for vulnerable customers looking to change suppliers. These are the customers who most need to save costs by finding the best supplier and often they are the customers least able to cope with the additional hassle of also having to switch PSR.
The current, fragmented PSR system
We mapped PSR application forms for seven suppliers: Ovo Energy, British Gas, SSE*, Octopus, EDF, Shell and Utilita. Our first observation is that the application forms are extremely varied, and some have rather unusual questions.
Several vulnerabilities are only mentioned by one supplier. Only one asks about autism. Another is the only one to ask about breathing difficulties. Several preferred support options only show up on one suppliers’ form: ‘female presence preferred’, ‘longer time to answer the door’ and ‘bedridden’. Bedridden is a pretty archaic term.
Meanwhile some options appear very frequently: there is a question about ‘restricted hand movement’ in all but one form, despite the fact this is a very specific need and not a common vulnerability on the front line.
Some suppliers include options for accessible information provision in the same form (i.e. braille, large print letters, etc.) Others link to an additional form or do not reference it at all.
When temporary conditions are mentioned, only some suppliers allow the customer to select a date when they believe the condition will no longer apply.
Most of the forms are multiple choice, limiting to what the supplier chooses to ask about. Occasionally the supplier (e.g. EDF) gives the customer a larger space to talk about their conditions, equipment and needs in more detail.
Haphazard language
The language used across suppliers is inconsistent. This suggests a lack of real consideration for the needs of the most vulnerable.
SSE uses ‘hard of hearing’ and ‘deaf’ to describe hearing loss-related needs, while other suppliers employ terms such as ‘hearing impairment’. In fact, ‘hearing impairment’ and ‘deaf’ are combined in half the forms and the former is not asked at all in one. This may be contentious, as people with mild hearing loss typically have different needs to the profoundly deaf
Some options have multiple potential meanings: ‘carer’ could refer to the respondent either needing a carer or being a carer for someone else. It is unclear what is meant by the ‘life support’ option used by EDF. Often the phrase ‘life support machine’ refers to a ventilator, but EDF also has a separate option for ‘heart and lung ventilators’. It could mean life support as a condition or set of needs but that seems too broad for the PSR.
All suppliers ask about speech and language difficulties and broader language barriers. However there is no shared way of asking whether a customer speaks English. Variations include: ‘unable to communicate in English’, ‘language barrier’ and ‘foreign language speaker’.
‘Unable to communicate in English’ (used by Octopus and Ovo) is somewhat ambiguous. Customers might take it to mean having a different first language or having a speech condition. The requirements are quite different: with the former you could use an interpreter or multilingual support, with the latter you would need different support.
We’ve created some infographics to help better visualise these inconsistencies.
Pointers to a multi-sector PSR
Does a close examination of the current system offer any clues to how the multi-sector PSR should be designed?
Disparities in the data
With suppliers asking such disparate questions, it will be hard, perhaps impossible, to merge the data into one platform. This leads to a tricky question: is it better to start again and ask consumers to resubmit data from scratch, or is it better to attempt to merge multiple incompatible PSRs into one?
Focus on the needs, not the names
Experian runs a service called Support Hub, which is an interesting model for a universal PSR. One elegant aspect of Support Hub is that it doesn’t ask your conditions but rather it asks your needs. Example questions are things like: “Send in giant print (20-32 point)” or “I prefer to meet or wait in a quiet space (if available).”
Co-design from the start
One reason for Support Hub’s good design is they embraced co-design, ensuring that consumers with lived experience are at the heart of the design process. This shines through in the quality of the user experience. A universal PSR represents the chance to do the PSR once and do it well.
Have your say
The government is looking for responses to their consultation by 17 January 2024, so if you’ve got opinions, now is the time to have your say.
Harriet Owen is a data analyst and machine learning engineer at HelpFirst. She is an advocate for improved support systems for vulnerable customers in the energy sector.
* SSE was acquired by Ovo Energy in 2020. SEE hadn’t completed their move over when we started this research and were still registering people to their separate PSR. We’ve kept them in our analysis as their approach was interesting with many mental health and developmental condition-type questions.
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