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COVID-19 Update – 18th May 2020

Today we share our 24th Scottish Dental Sector Covid-19 update with you. We will continue to share any important news and advice for the Scottish Dental Sector, and will maintain contact at least once a week going forward.
We hope that you and your loved ones remain safe and well and have managed to take full advantage of the relaxation of the lock-down rules around unlimited outdoor exercise to get some fresh air over the weekend..

With another week elapsed you could be excused for questioning how much progress has been made towards a return to practice date, and clinical guidance at this stage is scant unfortunately. In line with my earlier guidance I would suggest that it is best to avoid being ‘dragged in’ to the potentially negative world of social media. Whilst it has undoubtedly been a great medium to ‘gel’ the profession together at this difficult time it is clear that anxieties can be raised without substance easily due to the unfiltered nature of content online. Please take care of your own physical and mental well-being at this time and ensure any decisions taken are made in a considered and educated manner going forward.
I hope you continue to find value and support in my digests, and as always if you need any bespoke and free advice at this time the whole team at Dental Accountants Scotland are here for you.

GENERAL & POLITICAL UPDATE

Our First Minister is anticipated to make announcements as early as Tuesday for her ‘road-map’ of returning to some form of normal in the weeks ahead. Like the announcements made last Sunday evening by the PM it seems very likely that these plans will need to be vague and subject to the ‘R factor’ and scientific advice as we move forward. Obviously as the whole country seeks clarity this can be frustrating, however, realistically it seems impossible that any absolutes could be delivered at this stage unfortunately.
The return of safe sports and pastimes will be a welcome return for the mood of the nation, and hopefully the economy can follow swiftly after. As a volunteer tennis coach/referee and treasurer of my local golf club I was particularly pleased to see their inclusion as first returns and look forward to seeing the junior members I coach getting back involved. The impact this lock-down has had on the schoolkids is very clear to see, and the health giving properties of social sporting activity for them will be great to see. 
Although the Northern Ireland recording systems fell over today (along with Zoom!) tonight’s press briefing brought the news that the UK deaths count reached 34,636 and this is a timely reminder of the seriousness of the decisions that need to be taken by the leadership of our country and the dental profession. Let us hope that this responsibility is dealt with in a sensible manner and no deaths occur which could have been avoided.

CLINICAL UPDATE

Over the last week more and more of our client base have been redeployed in to front line services and have undertaken a variety of roles within the efforts. It seems however that the central hub and AAA approach continues to fall well short of the demand and need for adequate treatment in the nation. With some significant geographical differences in the types of treatment accepted and the patient journey involved we are witnessing a great deal of frustration within the profession. Many would welcome the ability, if sufficient PPE can be sourced, to see their own patients within their practices. We are aware that this is being discussed as the next possible phase for re-open and it seems apparent that practices may be authorised to re-open shortly in an effort to allow them to see their own registered patients for acute and essential care needs. The understanding is that AGP’s will not be allowed in that phase and practices will be required to plan appointments to allow for physical distancing requirements. Once we receive more information on the requirements it seems likely that some financial modelling will be very important to assess the viability of these measures fully. We will keep a watching brief on matters on your behalf.
We are aware that SDCEP are working very hard on a detailed guide to support dental practices to prepare to re-open, and with this in mind they launched a 21 question survey on Friday inviting all Dental Professionals to influence their research. The survey takes the form of a number of open ended questions on the key considerations for re-open including matters of screening, appointment planning, infection control, PPE, health and safety, communication etc. Given the rapid need for progress the survey is not open for long and closes tomorrow (Monday 18th) at 12 noon. Please take the time to get involved if you can. The survey can be accessed here SURVEY LINK
In my last digest I shared with you the two documents (in the archive again below) which focused on the re-open phase, namely the BAPD Return to Practice Position Paper and the CoDER Working Group recommendations for the re-opening of dental service evidence review. I hope you found those to be of interest. A similarly focused paper from Pandora Dental/IndepenDent has also been released which if you have not seen it may be of interest. I share this below for reference.
Pandora Report

It seems that the home nations are unable to agree at this stage how to deal with dentistry and it seems likely that we may end up with 4 different SOPs in place, which seems an inefficient and wasteful use of resources and is likely to cause difficulty for anyone operating in more than one territory. 
The lack of consistency is evidenced further by the return to practice in Ireland tomorrow. I share their guidance document for your reference below.
Guidance Managing Infection

We have had numerous conversations this week with Principals and the wider dental team about how the patient journey may look on re-open. With the fact that no two practices are the same this is likely to take a bespoke form for all and there is unlikely to be a blanket approach possible. Many tightly packed practice properties are likely to face challenge and will need careful thought over the ability to distance patients. The remote check in functionality from SOE which I covered in a prior digest (and is available f.o.c. until September) is likely to help with the payment and clinical logistics somewhat and many are considering the use of their car parks to suggest that patients are called in from their cars as opposed to the reception area. Whilst suitable this does only work where an on-site car park provision exists. Given the likelihood of making a waiting area off limits it may be that the consideration of this ‘dead space’ being used as a PPE donning or doffing space may become an option. The LDU also lends itself well potentially for similar uses. Any office space would likewise work as would the toilet areas given they are likely to be prohibited spaces for patients at this point. Those practices with more than one entrance/exit may be able to plan the pathway for patient traffic and avoidance of one another. It seems a bizarre concept but unfortunately until the virus is fully controlled these types of considerations alongside the financial planning will become very important.
All internal procedures will require to be updated to take account of new operating requirements and we would imagine that the dental team, furloughed or not, will require a level of on-boarding and training pre re-open and you might wish to give consideration to how and when that would be delivered once a clearer timetable emerges. 
All of these process re-designs take time, so you might wish to make progress on this planning as soon as practical. It may be a task you could involve the full team in and re-engage their input. I have stated before that this is a good time to revisit your processes with ‘fresh eyes’ and seek out efficiencies and improvements where you can. Given this downtime the opportunity to return with enhanced efficiency exists. In motor racing parlance this feels like you have hit a ‘tight bend’ in the road and this is often the best place to overtake the others in the race when you hit the straight again. It is not, in my opinion, a time to ‘coast’ and see the rest of the profession pull away from you when back to full speed.
I was also pleased to hear that many are ‘thinking out of the box’ at this time and have widened their perspective to attempt to review other professions/industries and their approaches. I have always felt that stepping out of the normal channels to learn from others is a very healthy approach and is often the way to really improve through the knowledge gained. I had an interesting conversation with one Principal this week who has moved to source chemicals direct from commerce to manufacture their own mouthwash and overcome supply chain shortages. They had also studied the use of water resistant gowns used in agriculture and veterinary environments. It was felt with strong policies on their usage and disinfecting that they may play a part in reducing the potentially crippling costs of PPE facing the profession. Retailing at around £50-60 if a suitable acceptance of their usage could be adopted this could save tens of thousands in PPE costs for a practice if the Dental Directory projections I shared previously were to come true. It should be said that at this stage the PPE guidelines have not been released and as such it would be prudent to avoid any ‘over buying’ until clarity emerges.

FUNDING UPDATE

BUSINESS SUPPORT GRANT PHASES 1 & 2

I don’t have any major updates in this scheme to share other than the fact that we still see that various local councils continue to refuse to pay out on the higher £25k grant support for those above £18k rateable value. We have sought clarification from City of Edinburgh Council on their interpretation of the rules. You may recall that they have paid out on all the applications, some of which under appeal admittedly. They have responded to state that (in theory) each council has a degree of autonomy to make a decision locally, and that they have used their judgement to consider that a dental practice does include a certain degree of ‘retail’ activity and therefore qualifies. This information has been passed to councils who have refused to approve payment to date, and also communicated to MSPs, MPs and the First Minister. In the interests of fairness and parity we hope to see a consistent approach emerge in due course.
If you have not claimed your £10k/25k for your first property and your 75% for each additional property yet then please do not hesitate. If you are unsure how to access just let me know and I will be happy to guide you.

JOB RETENTION SCHEME (FURLOUGH)

The furlough portal has now become reasonably well established and I have covered the intricacies in much detail in my prior updates. Our payroll colleagues have undertaken the majority of the ‘second wave’ of applications on behalf of our clients over this weekend and this should allow the funds to be in place prior to the end of month payroll requirements.
We await further guidance on the extension period rules and in particular the rules around the enhanced flexibility will be of real interest to Dental employers. It is unlikely that the scheme will be extended again beyond October or for Scotland to have a different cut off date to the rest of the UK so it is hoped that the virus can be contained in the existing timescale.

BOUCE BACK LOANS FOR SMALL BUSINESS

The Bounce Back Loans have been a very useful cash injection for our clients and contacts in the last week, and most have decided to drawdown on the loans as a contingency fund for the next stages of the recovery period. The view being to set it aside until needed, and if not required to use it for re-financing more expensive lending or simply to repay it to the bank involved at no cost after 12 months. If you have the self discipline to avoid using it frivolously then this is a very prudent and sound strategy as the fund will be removed in the Autumn if not before. 
I must, once again, applaud the banks for the support they have offered the dental community during this period. It has been exceptional.
We have been asked by a number of Associates this week if they are entitled to access this funding, even though they typically do not carry a great deal of direct or overhead costs. Our opinion is that there is no impediment to their access to the scheme and as long as the funding is not used for personal or fixed assets would not be in breach of the terms of the support. They must bear in mind that this is fully repayable debt (albeit at a low interest rate) but for any Associates with cashflow issues it would be prudent to apply. I would imagine any Associate in a private practice setting with a predominant fee per item setup may be particularly interested in this funding.

PIVOTAL ENTERPRISE RESILIENCE FUND

I have made mention of this funding support scheme in my last two digests. I remain unconvinced that this will be a positive source for the dental sector, but in theory it does qualify to apply and is worth making an application if you feel appropriate. The first phase of applications have not received any responses at yet and the second opening window of applications is set to close again tomorrow (Monday 18th) at 5pm for review. We anticipate that the applications will be reviewed together for both phases before any decisions are made. 
If you would like to apply you can do so here- Pivotal Resilience Fund. Don’t delay as your time is limited. 

SELF-EMPLOYED INCOME SUPPORT SCHEME

Many have successfully applied and been approved for the SEISS funding and will look forward to a receipt of the lump sum on or after 25th May. After a few initial bugs with the system the application process went relatively smoothly for most this week. If you have not checked your eligibility or applied you can do so here SEISS scheme home page
We have handled a large number of incoming queries this week from NHS supported Associates who have been unsure on their ability to make a claim on this scheme whilst receiving their NHS support.
In the interests of clarity – the only Associates who otherwise qualify for SEISS who cannot claim are those who undertake 100% NHS activity. This would be a highly unusual circumstance as most will have a small element of private treatment in their mix.
We have had extensive dialogue with PSD and HMRC this week to clarify this matter and are happy to advise that the majority of eligible Associates (<£50k income) are able to claim SEISS on the presumption of some private revenue. The guidance from PSD is that you cannot claim for NHS income. 
Many have questioned whether SEISS should therefore be pro-rated downwards rather than 80% of all profits. At this stage the ability to make an adjustment to your SEISS claim does not exist, therefore you cannot claim less than your full entitlement. It is our opinion that you should make the full claim, and consider that there is a small risk that PSD may re-visit it at a later stage for any clawback appropriate. You would be fully entitled to defend that a clawback is not appropriate and we would gladly support that defence. If you would like to adopt a risk averse stance you might seek to place a proportion on deposit to cover a clawback, but the only other option is not to submit a SEISS claim at this point – a position which cannot be amended at a later stage if desired. 
HMRC gave the following confirmation on the matter this week 
“The legal position is that you have to be adversely affected, it does not state the degree to which, the duration, the severity etc. Therefore I cannot see any legal standing for a charge arising based on this in the future”
Another common query this week has been around the entitlement for the wider team who are self employed but are not list holders with the NHS. This includes Assistants, Therapists, Hygienists etc, There is no question whatsoever that these dental team members are fully entitled to make a claim for SEISS. If the practice choses to pay a retainer to these team members it should be paid at a rate less that their normal earnings level to ensure they can prove an adverse impact from Covid-19.

NHS SUPPORT PACKAGE

As the monthly schedules are due to arrive shortly for May it is clear to see that PSD have been incredibly busy attempting to deal with the ‘tsunami’ of queries (in excess of 1,000) arriving at their office over the last month. We must applaud the efforts expended by their team in attempting to stay on top of matters. Their team have been fielding calls and emails well in to the night and have done all they can to support. We submitted a number of queries on behalf of the dental community and received their official feedback late last week both directly and via an update of their FAQ document. I have pleasure in sharing the FAQ document and our specific feedback summary below;
PSD Responses to Bespoke Queries

PSD FAQ’s Vs 3.0

As stated in our document it is clear that PSD will do all they can to help with any specific queries so please do email Martin Morrison directly on martin.morrison@nhs.net if you remain unclear on your situation. 
Some highlights from the updated Q&A document include; 
– The recognition as we highlighted last month that the support package should be a superannuable income. It will now appear on line 7 not 13 in the schedule and will now be included in line 40 like normal income. Care should be taken by the practice to re-adjust the methodology to calculate splits this month after the amendments which took place last month. In addition you should note that the net income will reduce as a consequence of the superannuation contributions being based on the total income once more. This should be budgeted for going forward. It is anticipated that the support payment will still appear in the Allowances and superannuation e-schedule which should be downloaded for completeness and accuracy checking. We anticipate that the majority of schedules this month will be at the full guarantee level as the majority of closed treatment cases would have completed in the prior schedule prior to lock-down
– It is reaffirmed, in line with my prior contact to the CDO that any practitioner can elect to opt out of the support if it would be of financial benefit to do so (unlikely in many cases)
The document is useful and is likely to continue to be updated with recurring queries as time moves forward.
It is clear that some form of support package will be required for some time ahead, how/if it varies will become apparent in due course. The return to practice for fully private practices will need some careful planning without the benefit of this support package to them. 

OTHER FINANCE OPTIONS

In addition to the sterling efforts expended by the banks over the last few months we were in contact with Braemar this week and took the chance to query Gail Cormack on their position which I am happy to share as follows;
“Braemar have just been given the green light to provide CBILS, this should be available from end of May onwards. We also have an application in for the bounce back loan facility so hope to be in a position to offer both. Obviously our doors are fully open to all lending types, this is simply in addition too. We appreciate our clients may not want to go down this route and therefore our message is very much we are open for business and looking to help our clients in any way we can.”
We are also aware that there are a number of Research & Development (R&D) claims companies undertaking a heavy duty direct mail campaign to Scottish Dentists at present and offering to submit claims on their behalf to HMRC. These claims, where appropriate, are a perfectly legitimate option for practices to utilise to claim enhanced tax credit for research activities. The key requirement for eligibility is to be solving a scientific or technical uncertainty of some kind. Successful claims in the past have been in areas such as material trials, implant testing or scanning/milling processes. The risk inherent in engaging with these claim ‘specialists’ is that they are of variable quality and may mis-represent your position in their self interest to inflate the fee involved leaving you vulnerable to future HMRC challenge. It is important you engage with a reputable and genuine expert firm. We would be happy to review any providers you are considering working with or refer a UK provider with a Scottish footprint. We have worked with ABJI (Formerly Jumpstart) for a number of years and would gladly introduce you to one of their Edinburgh based team if you would like to review your own activities. Given the evidence of profiteering which seems to be emerging in this crisis accross the full supply chain I strongly recommend you undertake diligence on any supplier before submitting any claims via them.
Once again love and best wishes to you at this time from myself and the full Dental Accountants Scotland team. I hope you manage to stay safe and well.
As a recurring reminder – our full team are now working remotely but ready and willing to continue to do all we can to support you in any way possible. Please accept my ongoing apology for any delayed reply to your emails while we work harder than ever to support you during this crisis. The level of correspondence required has severely tested my words per minute typing skills! For any urgent queries you may have please continue to call my mobile 07375 700468 (day or night) or book a zoom online consultation here and I will be glad to support you in anyway. Our no fee advice is available to you at this time and we will do all we can as part of your team.
I invite you to keep up to date with information our blog and to like our Facebook page to stay in touch. 

Stay safe and look after yourself and all around you at this difficult time.

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