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COVID-19 UPDATE #39 – 31st OCTOBER 2020

We hope that this reaches you and your loved ones in good health, and that you are enjoying your weekend. As lockdown rules prevents us all from trick or treating tonight we thought you might like another digest instead!….
We are sharing our 39th Covid-19 digest in relation to the Scottish Dental Sector tonight and hope that you find something of value within.
Some major elements to consider in this digest. As always if you have any specific queries arising we would be delighted to assist you with our ongoing free of charge advisory support.

CLINICAL & GENERAL UPDATE

On Monday we were in receipt of the latest PCA update regarding the remobilisation of NHS services, and alongside we received the revised Statement of Dental Remuneration (SDR 148). I share both of these documents for your information below;
Phase 4 remobilisation & SDR 148

SDR 148

These documents are most welcome in a number of ways, but as tends to be the case there are many unanswered questions which will require PSD input in the weeks and months ahead. Their latest FAQ document (version 10) is shared in this note below, and we can expect some significant additional responses to be added to this list in due course. We will continue to lobby for resolutions to key questions.
PSD FAQ Version 10

For the first time since March we now have an ability to look forward with a short term certainty of NHS support. We now know that the Covid-19 support scheme will continuefor as long as necessary and will be improved to 85% of average items of service from 1st November onwards. Up until 28th February 2021 this level of support will be provided regardless of activity levels. Clearly everyone in the profession would be happier to be back to full normality and activity levels but this transitional period for NHS performers to build up their clinical delivery throughput is most welcome and provides some breathing space for practices to adapt to the new SOP’s and fallow time requirements without fear of loss of support. From March 2021 onwards a requirement to achieve a level of registered patients along with activity levels of treatment will be introduced to deliver ongoing support at the following levels; 
– Raise Tier (85% Guarantee Top Up- Maintain Tier (80% Guarantee Top Up)- Reduce Tier (40% Guarantee Top Up)
These levels will be achieved via comparisons of activity levels and registered patient numbers achieved each month going forward. Although the methodology is yet to be announced on how activity will be compared it has been stated that this will be undertaken at a practice level. If that is interpreted literally we would expect that the accumulated measures will be used for all performers within the practice setting and will not be based solely on individual performance.This is perhaps helpful to smooth out the impact of holidays/absences but may well cause problems for practices who may have lost performers through retirement or free movement of workforce. As that is potentially out of the control of the other performers and Principals at each practice we hope that some protection will be included in the scheme to achieve fairness.The comparison periods which will be used shall be based on the period of 1 April 2019 to 31 March 2020 for activity and as at 1 March 2020 for the number of registered patients. To achieve each level of support you will be required to meet the following criteria; 
– Raise Tier – 20%+ Activity and 95% + registered patients – Maintain Tier – 10-20% Activity and 90% + registered patients– Reduce Tier – Less than 10% Activity or 90% registered patients
SOE users can extract the standard report of ‘Invoiced Treatments’ for the comparison period after setting the payor parameter as NHS. This will allow you to assess the basic target levels which will be required for full support as you move forward. I am sure other PM software will offer similar reports which may be helpful.

SDPO Webinar

My colleague James Wilson MAAT BDS will be presenting to Scottish Dental Principals as a guest speaker for the SDPO group. The webinar titled “Covid 19 – Where are we now and future insights” will be delivered online on November 11th at 7pm. It will aim to provide useful and timely input for practice Principals. Registration can be made via SDPO’s channels. If you are not currently subscribed to their channels and would like to attend – simply drop me an email and I will be happy to help you get involved and register.

Political Update

At the time of writing this tonight Boris Johnston is announcing the plans for another lockdown in the whole of England. With the ink still drying on Scotland’s strategic framework document it will be interesting to see how/if our National plans will be amended in the days and weeks ahead. The First Minister has advised no-one to cross the border to England at this time unless for ‘essential purposes.’ A statement I am sure, will have given the Nationalist in her, some political pleasure. She has also stated that she would “take account” of measures enforced in England but she felt the existing measures here were already showing signs of a positive impact. It is hoped that we can avoid any National lockdowns with the tiered approach being sufficient.

FINANCIAL UPDATE

Loans
As previously mentioned in my last note we recommend that, where appropriate, you avail yourself of the Bounceback Loan BBL or CBILs loan before they are removed at the end of November. The BBL in particular is a very low rate finance package which with no repayments for 12 months or penalty for early repayment would be a sensible contingency fund as a ‘safety net’ for your practice.

Job Retention Scheme (JRS)
JRS (furlough) comes to an end tonight. The PM announced an extension in England to account for their new lockdown, but it is assumed this will not be implemented in Scotland. All claims for the scheme must be made no later than 30th November to avoid missing any support. 
As a reminder you should write to your furloughed employees to formally cease their period of furlough. The template letter in my archive in the footer of documents below entitled ‘1-Notice of return to work from furlough’ can be used for this purpose. You should keep a copy of this letter with your furlough files for 5 years in case HMRC audit your usage of the support scheme.
As a reminder also, if you are to retain the services of any furloughed worked from November to January and pay them in excess of an average of £520 per month (calculated over the quarter ending January 2021) you will be entitled to a retention bonus of £1k per employee paid in February. This will not be automatic and is likely to involve a claim via the furlough portal in February.

Job Support Scheme (JSS Open)
The new JSS (Open) scheme (as revised) was launched with haste last week and we were promised some important additional guidance before the end of October. After waiting patiently for that additional guidance we were left wanting with only a small amount of clarification released late last night. In particular the promised guidance on how documentation of the implementation should look has now been delayed until 6th November. This is simply unacceptable as their own guidance states that employers must document the scheme usage in advance of implementation. As the scheme launches tomorrow (1st November) without that guidance it leaves employers without any certainty in an already complex employment law framework. Practice Principals might be left scratching their heads unsure how to act this week. I have therefore drafted a number of documents and tools today which may help you in the interim. With the caveat that we have no formal guidance, and that I am not an employment lawyer, I would hope that the following guidance is of help. My recommendation is that you plan for your use of the scheme if you wish to claim the support, agree the measures verbally with your employees without delay and put in place documentary backup either using my template (and amending if more guidance dictates) or issuing a letter once full guidance is received. The prior option is likely to be most prudent and would be my recommendation.
The following documents are shared. 
Firstly – my guide to the FAQ’s arising from the JSS(Open) Scheme 
JSS (Open) Scheme FAQs

Secondly I have developed a very simple spreadsheet which allows you to plug in your normal hours worked, hourly rate and proposed hours worked to illustrate whether it will be compliant with the scheme and to show the split of payments/grant for the wage payments during use of the scheme. 
JSS (Open) Calculator

And finally, with no guidance from the government about content, but the requirement to gain documentary proof of joint acceptance for the use of the scheme I have drafted a template letter you may wish to use for your impacted employees after discussing matters with them. 
Template Letter – Job Support Scheme

I hope you find these documents helpful for your practice. 
As the claims for JSS (open) are not able to be filed until 8th December at the earliest there is very little you can do at this stage. The key things to consider are ensuring you end the furlough period correctly/formally and that you agree and document JSS (Open) if you are planning to implement. 
I hope you find this content of value and interest. Enjoy the rest of your weekend!

And Finally

Once again love and best wishes to you at this time from the full Dental Accountants Scotland team. I hope you manage to stay safe and well. Have a restful and enjoyable weekend whatever you have planned.
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 feel free to 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 on 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 and have lovely weekend.

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