Research and analysis

Consumers navigating markets while living with mental health problems: summary of stakeholder roundtable

Updated 13 November 2018

On 26 June 2018, the Competition and Markets Authority (CMA) and the Money and Mental Health Policy Institute (Money and Mental Health) jointly hosted a roundtable discussion focused on consumers navigating markets while living with mental health problems.

The roundtable explored the challenges for consumers experiencing mental health problems and the potential solutions to these challenges. The roundtable was part of the CMA’s work on consumer vulnerability.

The roundtable comprised presentations by the CMA and Money and Mental Health and plenary discussions. Representatives of government departments, regulators, consumer groups, charities, think tanks and business attended (full list of organisations). The roundtable was held under Chatham House rules.

The remainder of this summary sets out key points from the presentations and some of the issues raised during the plenary discussions.

Understanding the challenges

Speakers’ presentations

The CMA and Money and Mental Health made opening remarks about their roles and relevant work. The CMA highlighted that some of its projects, such as the care homes market study, payday lending market investigation, and ongoing gambling consumer enforcement work, had covered markets where consumers could be experiencing mental health problems. Such cases provided useful insights into the challenges for these consumers but the CMA wants to develop its understanding of these challenges.

Money and Mental Health presented on the challenges for consumers with mental health problems. Some of the key points are set out below.

• Mental ill-health can be an issue for many people. One in four people experience a mental health problem each year and 50 per cent of people are expected to experience a mental health problem in their lifetime.

• There may be complex and interrelated issues if someone is experiencing financial difficulty and mental health problems. A cycle can occur whereby financial difficulty gives rise to stress, worry and disengagement leading to psychological harm, mental health problems, cognitive and psychological barriers, and reduced financial capability. In turn, this can exacerbate financial difficulty.

• Mental ill-health may impair attention span, memory, planning and problem solving, and/or lead to impulsivity which can then adversely affect how people choose, use and pay for services. For example, in relation to choosing services, consumers with mental health problems may find it hard to compare options. When experiencing a service issue, they may find it difficult to telephone their supplier to complain and, when paying, they may find it hard to deal with complex written bills.

• Consumers with mental health problems may not benefit from existing solutions to make markets work better. For example, they may be overwhelmed by remedies that provide more information to consumers. Technological/data remedies that rely on opting-in may be inaccessible.

• It may not be sufficient to rely on consumers with mental health problems to disclose their problems. Many may not disclose due to stigma or concern about how it may affect their access to goods and services.

Plenary discussion.

During the plenary discussion, the following points were raised about the challenges facing consumers with mental health problems.

• There is work within the energy market to address consumer vulnerability but there are issues with lengthy, complex bills and suppliers’ communications with customers. The recent increase in providers within this market has resulted in more varied approaches to bills and communications with customers.

• The scale of the mental health challenge should not be underestimated given the low rates of disclosure. It is likely many people will not disclose mental health problems on telephone calls to suppliers. Some of these consumers may prefer to communicate online.

• Firms can experience challenges when seeking to support consumers with mental ill-health. Some firms may provide services such as mobile apps to help consumers who do not want to telephone but consumers may not know about these tools. Firms can use data to help identify consumers who may have mental health problems and then market specific services to them.

• It is important that firms support consumers with mental-health problems and do not exploit them. Competition has potential to bring benefits for such consumers, with new entrants potentially offering services and products that better suit these consumers’ needs.

• There is scope for better sharing of data about vulnerable customers amongst sectors to avoid the need for multiple disclosures. Work is already taking place in this respect, with greater data sharing between water and energy providers due to be in place by 2020. However, some consumers may be concerned about such data sharing, reflecting the low rates of disclosure and fears about stigmatisation.

• There is a need for flexibility in the services provided to consumers with mental health problems. Service and product design should address their needs. For example, if such consumers find it difficult to pay at certain times, firms could provide different payment options and payment holidays.

• There could be merit in firms regularly checking up on vulnerable consumers such as those with mental health problems. Firms should develop ongoing relationships with such customers and offer early interventions. Consumers experiencing mental ill-health should expect to have good experiences across all markets.

Developing solutions and remedies

Speaker presentations

The CMA gave a presentation covering first-hand experiences of mental health problems and the CMA approach to potential solutions (or remedies). The CMA is open minded on remedies and keen to think creatively.

The CMA highlighted the following as possible themes to consider in respect of solutions for the challenges facing consumers with mental health problems.

• The target population. Is it one in eight, one in four, or everyone who may potentially be affected? Should solutions be targeted to certain individuals or apply to everyone?

• Hidden in plain sight. Many people may experience mental health problems but not disclose. While consumer detriment is usually defined and measured in terms of prices, it could be broader and encompass mental health. Existing consumer surveys to help measure detriment could be extended so they collect data on mental health.

• Diversity and personalisation. Various approaches are needed because there are many people experiencing mental ill-health and many different mental health conditions.

• Major life events. Often mental health problems can be triggered by events such as divorce, job loss or bereavement.

• Triggers, friction and inertia. It is important to design remedies that connect with people emotionally. For example, insurance companies sending renewal reminders that set out what the customer previously paid alongside the new price.

• Penalty fares. Often penalties are designed based on consumers behaving rationally but those experiencing mental ill-health may behave impulsively.

• Resilience. There is benefit in building people’s capacity to withstand shocks such as financial difficulties.

• Advice versus therapy. Advice is useful but often practical in focus and may not address wider issues experienced by consumers with mental health problems.

Money and Mental Health presented on potential solutions. Drawing a parallel with the introduction of dropped kerbs on pavements, Money and Mental Health suggested it was important to find interventions that could be universally beneficial rather than just targeted to certain groups of consumers. Such an approach reflects the transient nature of mental ill-health and that the people needing support will vary.

Money and Mental Health suggested the following as practical solutions to the challenges, which could also have wider benefits for all consumers.

• Simplify bills. There was scope to cut content and test language with users.

• Firms provide alternative ways for customers to communicate eg via web chats, email and WhatsApp.

• Improve mechanisms for delegation to third parties. When consumers are experiencing mental health problems and cannot engage, they may rely on risky options such as sharing passwords or PINs with carers such as family members and friends. It may be better to create more formal structures to permit carers access for certain time periods or purposes.

• Minimum standards. Firms’ support for vulnerable consumers varies across markets, which creates complexity and confusion for these consumers. There should not be uniformity of approach but there is a need for a minimum set of standards so people experiencing mental health problems can be reassured about how they will be treated by firms.

Money and Mental Health said there was a potential role for using data in helping consumers with mental health problems. Data provided scope for automated switching processes, smarter account management and more personalised support. There was also potential for greater sharing of data amongst providers about certain customers (eg benefits recipients) to avoid the need for consumers to make multiple disclosures. However, there were also potential risks with data such as suppliers discriminating against certain consumers and scams.

Plenary discussion

During the plenary discussion, the following points were raised about potential solutions for the challenges facing consumers with mental health problems.

• Sometimes firms see vulnerable consumers as expensive. However, the costs to serve these customers need not be higher with better service design. There can also be a competitive advantage if firms support them. Firms should be encouraged to understand the wider societal benefits of helping consumers with mental health problems and have performance targets that capture such support.

• Consumers should be supported to build resilience and put in place strategies for when they may experience mental ill-health. For example, they could set up direct debits so they do not have to engage with suppliers when they are unwell.

• A range of mechanisms may be needed to improve outcomes for consumers with mental ill-health. In some cases, there may be such serious detriment that legal requirements are necessary to make services accessible. In other areas, sharing good practice may work. The recent wider recognition in society and broader developments in relation to mental health, such as employers focusing more on employees’ mental health, may help to foster change.

• Reputational regulation can play a role. For example, the CAA reporting on the accessibility of each airport helped publicise this issue and generate impetus for improvements. Firms can be encouraged to show their commitment to providing good services for consumers with mental ill-health eg at Board level. Regulatory signals may help to change firms’ behaviour.

• Some big firms may now be offering more support to consumers with mental health problems but smaller firms may not. The introduction of minimum standards for firms could help to address this. Such standards have already started to be developed for some sectors such as financial services. Minimum standards could be cross-sector and cover all types of consumer vulnerability.

Organisations which attended the roundtable

• Age UK
• Alzheimer’s Society
• Advertising Standards Authority (ASA)
• Banking Standards Board
• Barclays
• Barrow Cadbury Foundation
• Behavioural Insights Team
• Department for Business, Energy and Industrial Strategy
• Citizens Advice
• CMA
• Disabilities Rights UK
• Energy UK
• Financial Conduct Authority (FCA)
• Gambling Commission
• Legal Services Board
• Money and Mental Health Policy Institute
• Ofcom
• Ofgem
• Ofwat
• Ombudsman Services
• Scope
• StepChange
• UK Finance
• UK Regulators Network (UKRN)
• Utility regulator Norther Ireland (uregni)
• Which?