COVID-19 UPDATE #48 – 29th March 2021
This week we passed the first anniversary of the Covid-19 lockdown. When the pandemic arrived on UK shores in early 2021 I don’t think many of us imagined the impact it would have on the nation and the Scottish Dental Sector as a whole. 12 months on, the impact is still being felt, and time will tell if there will be a permanent change on the face of dentistry as a result. It has been a year of challenge, loss, and stress but has also provided some much-needed collegiate unity in the profession and prompted action and support at a level unseen previously. I sincerely hope that I am not writing to you in another year’s time and still discussing how to navigate through the labyrinthine Covid landscape. Let us hope that we can leave the challenges behind soon and build the sector for a high-performance ‘normal’ together. I hope you are still safe, sane, and well after the last 12 months, and wish you all the very best indeed for the year ahead.
I am now sharing my 48th Covid-19 digest in relation to the Scottish Dental Sector. I hope you find this digest of value. As always – if you have any specific concerns or questions we will be delighted to hear from you.
The Scottish Government has now moved in to the pre-election period in advance of the polling date of 6th May. In essence this stalls any major decisions/changes on NHS dentistry until after the new government is formed due to the fact any changes can be considered as potential canvassing. As a result we anticipate that the ongoing support and SDR matters will remain in place for the short term as they stand. We were informed that measurement would potentially emerge in June, but as yet no confirmation of the mechanism of measurement has been released and it seems more likely that a continuation of the current system will be required. One matter which the CDO did manage to ‘squeeze in’, as promised, before the pre-election period was the announcement that the SDR will be updated in regard to Determination V (maternity, paternity, and adoptive leave payments) and VI (long term sickness payments) to account for the fact that the basis period used for leave allowances could be negatively impacted by the Covid income levels and potentially raise discrimination issues. This is good news potentially for those impacted and the fact that the announcement was made allows it to be implemented during the pre-election period and avoid delays. Our understanding is that the amendment to the SDR is being reviewed by the legal advisors and will follow in a PCA in due course. The CDO’s letter can be read at the link below.
CDO ‘holding letter’ re leave – 23 March 2021
With the electioneering moving in to ‘first gear’, and the political ‘sideshow’ of the former First Minister’s new political party launch we have a difficult to call election ahead. With proportional representation providing a balanced parliament it seems unlikely that dentistry will face any radical departures from current policy but we will await the new government’s approach to emerge in the months ahead with interest. The CDO was quoted that he did not envisage that NHS dentistry would be likely to gravitate towards a ‘core service’ as that would be a negatively viewed political matter in the current government’s left leaning composition. He further expanded on the point that consultation will be required to assess the best way forward for NHS dentistry. Some interesting times ahead, but in all probability unlikely to be a rapid review or short term change in my opinion.
As the roll out of vaccines continues at great pace there appears to be a slow improvement emerging in public confidence levels and we are hearing that chair utilisation and occupancy levels are bouncing back strongly, subject to the fallow restrictions. We continue to see a high demand for dentistry and in particular a significant increase in the uptake of private dentistry. The much reduced caseload and ‘R number’ measures can only be good news for the recovery of dentistry in the months ahead.
It is good to see that the dental teams have played their part in the vaccine sessions. It is also a good source of income for the team who may have been less clinically committed due to adoption of ‘care bubbles’ and chair rotation in the practices. It is however an unfortunate bi-product that the press coverage of the wide gap in rates of sessional pay between the team members has created a little friction.
We were asked how to deal with the team members attending vaccination sessions this week, and specifically how to deal with the nursing team and performer input being diverted away from practice activities. Unfortunately, like so many things during the pandemic, the guidance is far from explicit and as a result our advice is that the practice needs should be prioritised first and that any deviation from the contractual position (employee or Associate) would only be by mutual negotiation. To avoid conflict it is recommended that any vaccination sessions undertaken be scheduled for times where they are not rostered on at the practice if possible.
SDA Summit – The Future of the NHS GDS
I would like to congratulate the SDA on their recent first Summit, held on the 16th March. The event, entitled ‘SDA Summit – The Future of the NHS GDS’, included the following speakers;
– Tom Ferris, CDO Scotland- Professor Philip Taylor, Dean of Dental Surgery RCS Edinburgh- Professor Cynthia Pine CBE, Emerita Professor Dental Public Health QMUL
I am grateful to the SDA for allowing me to attend, despite the lack of a GDC number (unlike my colleague James who is a Dentist turned Accountant) and I watched with interest to the topics covered.
I think it is a testament to the SDA and their efforts that I was engaged for the full 2.5 hours and could have continued well beyond the scheduled timings had it been allowed to continue. I thought in particular Professor Taylor’s presentation was particularly engaging and he was not afraid to dissent and suggest some thought provoking routes forward at times. I hope he can be included in future events diary permitting.
It was quite admirable that the group managed to include the CDO and indeed he is to be respected for presenting and for providing the Scottish Dental Sector with the chance to quiz him on the direction of travel. With the majority of questions tabled in the Q&A section being submitted live or in advance he had to give a response to some challenging queries and where they were non political he covered them very well in my opinion. There is some niggling concern that the main thrust of the future includes more consultation rather than having any ‘oven ready’ solution to offer, but given the novel times of the last 12 months that is to be understood I feel.
If you did not attend, and have not engaged with the SDA then I would encourage you to get involved. Although there is some work to do to have the group seen as an official voice for the Scottish Profession there is some indication that the opportunity does exist for the SDA to shape the future landscape.
Tom Ferris’s presentation included a number of salient points for me. These included, but were not limited to;
- The Oral Health Improvements Reform that was underway pre Covid felt like a “different era, and almost historic now”. He feels that a new reform will emerge as a hybrid of the learnings during Covid and the original plans
- That a new contract for delivery of NHS dentistry is required going forward
- That “nothing is off the table” as to how that contract may look, and that a consultation with the public and the stakeholders will be required to design (In our opinion this is effectively setting the scene for a medium term timetable and no rapid reform is anticipated)
- The public does not understand the patient charge system. This was then somewhat contradicted by stating that the public should be asked to design a replacement, which seems a highly ambitious desire and quite how that would be achieved is unknown
- Whatever route is taken it seems likely it will have a bias towards a preventative care pathway rather than restorative. This is in line with the prior Oral Health Reform project plans.
- Alongside there is a desire to ‘simplify the restorative toolbox’ a little. Perhaps by reducing the types of treatment offered or gravitating towards an UDA or salaried commitment service in the future.
- Without undertaking a ‘post mortem’ of the way Covid governance was led there was an acknowledgement of some key issues to be addressed. These included
- Ventilation in the Primary Care Estate and the use of AGPs
- Fallow time and PPE
- How dentistry is funded by the taxpayer
- Unregistered patients
- Delivery of a stable interim support package (which had not been anticipated to go on longer than 3 months originally and is now clearly failing at the margins for some performers)
- Maternity/other leave and the recognition that the standard basis period does not work at present
- Mobility of performers between practices is creating many challenges
- How to define ‘NHS Committed’ requires consideration
- Clarification of the Practice and Performer’s roles is required
- If the patient charge fit for purpose
- Who might be best to govern varying levels of NHS activity – NHS/HIS/Other
- What part do the corporates play in the future of the NHS
- Is there a justification to attempt to have access to specialists on the high street
- How can the Associates’ voice be heard more
Quite a wide ranging topic list, and demonstration of the challenges faced. As there are self employed or business interests in the way that dentistry is delivered alongside the clinical drivers it does seem unlikely that there will ever be a perfect solution achieved for all. Quite a behemoth of a project, but a key mantra of mine is that to earn the right to criticise you need to step up and volunteer or get involved. Right now you could argue the profession and the NHS might well be at an important crossroads and I would encourage everyone to use the opportunity to have an input to the future of dentistry in Scotland going forward by getting involved in any way you can.
Well done to our friends at the SDA once again for all they are doing in addition to the efforts of the SDPO, BDA, BAPD, LDCs, SDPC, etc – together you are stronger and do keep up the good work.
In what many have described as a ‘little slow’ to support the profession, the GDC have announced that the ARF renewals this year can, where being paid personally, be spread over 4 interest free quarterly instalments rather than in full.
The full ARF will be optionally split in to four installments of £170 under the new arrangements and collected via Direct Debit. With the adverse PR impact and massive outcry of criticism last year at the peak of the pandemic resulting from their refusal to allow instalments or discount the ARF while furloughing many of their team this is clearly demonstrating that they have listened. We also see this as a potentially helpful concession to new entrants to the profession too and allow them to pay their ARF alongside their first earnings period.
CJRS/Furlough/ NHS Bonus
The flexible furlough scheme will continue in its present form now until 30th September. Flexible furlough therefore remains an option for Scottish Dental Practices while adopting ‘care bubbles’ and where perhaps unable to utilise the full team.
The claim deadlines remain tight and must be submitted by the 15th of the month following to be eligible. Worth noting if you intend to use the scheme.
The receipt of the NHS bonus of £500 (pro rata) is expected in the next few days. It will be paid to the practice and be available to distribute when/how is deemed appropriate locally. There is no absolute requirement to show as taxable income on employees in the month of March 2021, and the most pragmatic approach would be to include the payment in the April salary to allow you sufficient time to accurately calculate the net payment required after statutory deductions. Should you wish to pay the net bonus to your team members swiftly that could be achieved as an ‘advance’ of their April salary if desired. If you require any advice on the administration of the funds do let us know.
The previously covered SEISS 4th grant details have still to be fully released, but we are receiving minor clarification as time moves forward. We will update this when the final scheme rules are released as law under royal assent.
At present what we know is;
- The online claim system will be open in late April until May 31st
- The government will issue guidance “in due course”
- Those eligible will be invited to apply and certify their own eligibility
- The 2019/20 tax return will now be included in the calculation and will assist the newly self employed to gain access. It also means however that there may be a change in your defined average earnings resulting in increased/decreased payment. What is not known at this stage is wherer 2019/20 exceeded £50k of self employed earnings whether a claimant eligible previously will now be ruled out or not
- You must either be currently trading but impacted due to COVID-19, or previously trading and temporarily unable to do so due to the pandemic. The definition of ‘impacted’ is not released but seems likely to be set around a ‘material level’ of 30% drop in income or profits or a severe restriction on ability to trade. The third element is the most likely to apply in the Scottish Dental Sector given the ongoing fallow restrictions but we must seek clarity in due course and will report further on receipt
- Claimants must also declare that they continue to trade or will attempt to do so
The 5th and final grant will be opened in late July and paid at variable levels depending on the quantified impact on the trade.
Bounceback Loan Scheme/CBILS/Recovery Loan Scheme
NB URGENT ACTION REQUIRED IF RELEVANT;
Bounceback loans (BBL) and CBILs loan application deadlines fall on the 31st of March. The BBL scheme is a low cost finance option with fully flexible repayment. If you have not yet applied and borrowed it is my strong recommendation that you consider applying as a contingency fund or re-financing opportunity. The loan is interest free for 12 months and can be used to settle higher interest rate funding (HP, loans, etc) to reduce your costs. It can also be used for working capital and help to release other funds to invest in new equipment for practice usage. Even if you do not anticipate an immediate need for the loan it may be in your best interest to secure the loan in the next day or so and set aside the funds while you consider your options. You should seek advice on use of any loan finance from your advisors and if you would like to discuss with us we will gladly help you to decide on optimal usage. CBILs finance also concludes on the 31st but you are unlikely to have sufficient time to apply for it given the extra complexity involved.
From 6 April the new ‘Recovery Loan Scheme’ will launch. It is not clear how easy this will be to access, but it has the feel of the EFG or SFLGS predecessor schemes which were also underwritten by government security but administered locally by the banks. On that basis the banks are likely to be forced to exhaust ‘traditional’ loans and security before being authorised to use this new scheme. It does however help with practice growth/establishment where security is short and in the example of a new squat practice launch might be a useful scheme worth keeping a watching brief on in the meantime.
The new scheme highlights are
- Loans of 25,000 and £10 million
- The government will provide lenders with a guarantee of 80% on eligible loans
- Open to all businesses, including those who have already received support under the existing COVID-19 guaranteed loan schemes
Super-deduction (Capital Allowances)
For the two years from 1 April 2021 until 31 March 2023, companies (not sole trade or partnerships) investing in qualifying new plant and machinery assets will benefit from a 130% first-year capital allowance.
This upfront ‘super-deduction’ will allow companies to cut their tax bill by up to 25p for every £1 they invest, a 6p enhancement over the current rates.
There are a number of anti avoidance rules emerging around the benefit. What has been announced is that only assets that become ‘contracted’ after the 1st of April will qualify. Therefore any practices who have paid deposits to secure equipment delivery in April or later would be advised to liaise with the suppliers to avoid early trigger of a contract if possible and ensure that the deposit is not seen as the purification of a contract. Ideally the supporting documents for the order, delivery, invoice and installation of the equipment will all be after 1st April to ensure you are in a position to make a full claim of this useful leverage of capital investment in the practice assets.
The guidance at this stage is that the assets which shall qualify are ‘plant and machinery’ only. In a typical dental practice this is likely to include (but not limited to);
- Surgical equipment – chairs, delivery units, scanners, LDU, handpieces, compressors and all electrical. engineering and plumbing services required to install
- All furniture – reception or office desks, staff welfare areas, carpeting etc
- Lighting, wiring, plumbing, heating and ventilation systems and installation including boilers
- Integral features like carpets/flooring, alarm systems, entrance matting, handrails, automated doors, racking/cupboards/cabinetry, sanitary ware, showers, TVs/AV equipment, doorbells, induction loops, panic alarms, emergency lighting, thermal insulation, etc.
In general building work is excluded as are electric vehicles but where building work is being undertaken it is well worthwhile extracting the above elements in the contractor’s detailed summary of works to leverage the additional allowances.
In addition to those investing in a new practice the increased wear and tear on equipment during the pandemic may force early replacement investment so this additional benefit is helpful for the next two years.
OTHER MATTERS – SECTOR INFORMATION
Our friends at Christie & Co released their latest Dental Review recently, which provides a useful summary of the sector observations and is well worth reading. We are grateful to Paul Graham and his team for the work undertaken in compiling their report and for the early sight of its content on release. I am happy to share the report here for your information;
Christies 2020-21 Dental Review Report
Hope you find it of interest and value.
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 continue to work remotely but are 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.