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COVID-19 Update – 5th June 2020

Today we release our 27th update on the current salient issues arising in connection with the Scottish Dental Sector and Covid-19. 

Please do not overlook the update on furlough later in this article as it contains some key information and advice on time sensitive actions required.

WEBINAR PROGRAM

Firstly, a reminder of our free support forums for Dental Accountants Scotland clients (practice owners) and webinar program. The limited places are filling fast so I encourage you to enrol if you have not already done so at the following links.
(1) – Exclusive to Dental Accountants Scotland Principal/Practice Owner Clients only
All workshops on Friday Afternoons at 2.30pm

1. Friday 5th June at 2.30pm (Valuation matters with Paul Graham – Christie & Co) – please book at this link

2. Friday 12th June at 2.30pm (Employment law matters with Catriona Ramsay – Aberdein Considine) – please book at this link

3. Friday 19th June at 2.30pm – please book at this link

4. Friday 26th June at 2.30pm – please book at this link


(2) – Bounce-back Higher Webinars – For all Scottish Dental Professionals
1. Business planning for the phased return – Tuesday 9th June 7PM – Book here

2. How are practice valuations impacted by Covid-19 with Paul Christie, Head of Dental – Christie & Co – Tuesday 23rd June 7PM – Book here

3. Business planning for the ‘new normal’ – Tuesday 7th July 7PM – Book here

We are also considering offering an Associates Support Forum online clinic. If this might be of interest please complete the short survey at this link to indicate what format/topics might be of value and we will be happy to facilitate.
I invite you to keep up to date with information our blog and to like our Facebook page to stay in touch. 

POLITICAL & GENERAL UPDATES

Tonight’s statistic of 39,904 UK deaths in relation to Covid-19 is very nearly twice the original containment target of 20,000. Despite the fact that the daily statistic of 176 is the lowest working day level thus far, this is a stark reminder of the position we find ourselves in and the ongoing fight against the virus. 
We continue to move forward as a nation in phase 1 of the Scottish Government plans and the extra freedom allied to the warm weather appeared to raise the mood of the nation somewhat at the start of the week. Unfortunately, the ‘Scottish Summer’ appears to have returned once more so the ability to socially distance outdoors might be challenged in the days and weeks ahead!
There is ongoing pressure being placed on the CDO’s of each nation for the lack of guidance and clarity shown to the profession. We witnessed the somewhat embarrassing position of your England based colleagues learning of the apparent resumption of dental services on the 8th of June being announced by the BBC before the professionals involved had been notified themselves and this has done nothing to dampen down the unrest felt in that Nation. The BAPD have issued a follow up to their vote of no confidence in their CDO, which I share below for your general information. 
BAPD CDO Follow up

In Scotland we had anticipated some further guidance from the CDO early this week regarding resumption here, but it seems that some time to pause has been chosen perhaps to avoid any false dawns emerging here . We will watch with interest what flows in the days ahead, but it has been made clear that Scotland will not be mirroring the timetable of England and a re-opening will not take place on the 8th of June North of the Border.
The ongoing unintended ambiguity about who has responsibility over private dentistry continues this week, and we have found the purely private providers to be communicated to directly by Healthcare Improvement Scotland and the Scottish Government in an attempt to provide their guidance. Unfortunately, this doesn’t provide the clear direction which was hoped, but does at least set out some key considerations for the providers involved. The correspondence for your information is provided as follows.
HIS – Guidance 1st June

Scottish Government Guidance on re-open 1st June

The confusing times and direction being shown at this stage prompted a survey of Scottish Dental Practice owners on a number of questions. The results, whilst not entirely unexpected, make for interesting reading and can be found in the document shared below. 
Scottish Dental Practice Owners Poll

CLINICAL UPDATES

Thoughts continue to turn towards the clinical, financial and team considerations for the phased return to practice. We await the clarity on any financial support available to enable the completion of our modelling to assess the impact of matters fully.
In the meantime the reading of the various SOP’s issued and the consideration of your own protocols continues and further to SDCEP’s guidance issued last week two key reports have been issued this week from the BDA (in relation to England’s return) shared below 
BDA (England) Return to work toolkit

plus the practical guide from FGDP shared below; 
FGDP practical guide 1st June

Both of these documents are very comprehensive, and as a non-clinician I would have appreciated an executive summary, but are clearly quite helpful in navigating best practice advice at this time. Some discussion about why the BDA needed to issue their own document when they had also participated in the FGDP project has emerged. This is a result of the fact that they provide indemnity cover to their members and felt it appropriate to issue their own guidance directly to ensure members follow their protocol and do not invalidate the cover in place. 
Should you still have the energy to digest a further SOP the English CDO has today issued the NHS SOP for the phased transition towards full resumption south of the border and I share this below for your interest.
OCDO SOP – Transition to recovery 4 June 2020 vs1

These documents, whilst broadly agreeing in the key areas do vary in some others, and it seems like unless a single authority emerges with prescriptive guidance that professional judgement will be required in some respects.

FUNDING UPDATES

As I anticipated in my digest last week, we were treated to the appearance of the Chancellor at Friday’s press briefing. I do look forward to his appearance as it normally coincides with the release of some further financial support or clarity which makes our role as an advisor much easier. 
Rishi Sunak announced some key details in relation to the Self Employed Income Support Scheme and the Job Retention Support Scheme and I set out the key facts on each below.
****** Do not overlook this section – action may be required*******

Job Retention Scheme – Phase 2
It is hard to believe that the majority of the nation were unaware of the ‘F Word’ that is furlough less than 3 months ago. It has now become a core element of ongoing life in the country and continues to provide vital support for UK businesses. The Chancellor outlined the new ‘Flexible Furlough Scheme, or FFS (not sure that abbreviation was thought through in detail by the think tank involved!). FFS will now be implemented a month earlier than originally trailed and will become effective from the 1st of July onwards.
The key, and most helpful, element of the FFS is that employees can be furloughed on a part time basis from the 1st July.
This will operate on the basis that any days worked shall be paid by the employer at normal 100% rates, but on the remaining days furlough will be claimable at the current rates. The support will be tapered off towards full removal in November.
We anticipate that the part time attendance might be helpful for a number of reasons during a phased return to practice. The need to have someone on an unbroken 3 week absence to be supported will no longer be in the scheme rules. However, there is a very important point which should not be overlooked and that is that no new employees can be added to the grant submission from the 1st of July onwards. This means that for anyone to be eligible for the grant funding beyond the 1st of July and up to the end of October they must have been previously furloughed for 3 weeks ending no later than 1st July With this in mind if you anticipate you may wish to furlough an employee in the FFS stage then you must ensure they are furloughed effective 10th June otherwise you run the risk of missing out on this valuable support. Please do not miss this key requirement and regret it later
There are many practices who may not have furloughed some of the team previously due to the NHS funding in place, and if this is the case you might wish to ensure you have furloughed every team member before the end of the month to protect your ability to furlough them flexibly if required later. This may be particularly helpful to you if;
– You wish to operate a rota system with the team during a period of reduced activity.

– You need to vary the team if any have been forced to self isolate during the track and trace phase

– You wish to avoid having the team ‘disjointed’ with sharing workload 

– You have retained team members at this stage who have not been furloughed but would not be the right/first choice for the return to work period- Etc 
At this stage if you wish to protect your ongoing flexibility and have not furloughed 100% of the team you therefore have the following choices;

– Add the un-furloughed employees on to Furlough and have the full team furloughed from the 10th June to 1st July; or

– Add the un-furloughed employees on to Furlough from the 10th and remove other team members from furlough to compensate and keep your % in line with your efforts to comply with the CDO guidance levels

Either way is deemed to be acceptable. The first option would potentially leave you exposed to a claw-back from NHS/HMRC downstream, however if the guidance which is due to be released on the 12th June provides contradictory advice then you are able to amend your position prior to making the furlough claim (deadline is 31st July) so you may like to follow that route in the meantime. I would be happy to brainstorm your own strategies on this approach, but wished to flag up the action required at this stage tonight to ensure nothing is lost at a later stage for you. 
The FFS will now involve a slow tapering off process where the responsibility to pay the 80% payment to the employee will be shared between the government and the employer. In summary the phase 2 looks like the following
July – Flexible Furlough Scheme launches August – Government pays 80% of wage/Employer pays NIC and pension contribution only (plus any discretionary top up)September – Government pays 70% of wage/Employer pays 10% minimum October – Government pays 60% of wage/Employer pays 20% minimum November – Employer pays full employment costs/employment ceases 
As an aside, please bear in mind that we would anticipate that some team training will be required before the return to practice date. You remain able to undertake training whilst on furlough therefore there is no need to un-furlough your team for these training days. You can (although are not obliged) top up pay rates on any training days to supplement the 80% support if you choose to do so.
Suzie and the payroll team will undertake your instructions on the above implementation where we act for you in a payroll capacity. The FFS implementation will further raise the workload involved exponentially for the payroll team. We are happy to continue to provide this service free of charge as part of our ongoing Covid-19 support package rather than levy charges during a period of cashflow challenge for the sector and we hope you find this helpful. As a courtesy request can we please ask for your payroll information to be supplied to Suzie at least 72 hours in advance. This will allow the payroll team the time to undertake the detailed calculations and applications accurately on your behalf. Thank you for your co-operation in that regard.
For anyone undertaking their own payroll who would value a second opinion or has queries on the FFS implementation please do not hesitate to get in touch and we will be happy to deliver free advice and support.

Self Employed Income Support Scheme

The Chancellor set out an extension to the support scheme for the self-employed. Unfortunately, he made it clear that the £50k ceiling will not be removed and that this will be the final extension to the scheme.
As previously covered in my earlier digests this scheme is mostly relevant to any self employed therapists/hygienists or part time Associates. Most full time Associates in Scotland exceed the £50k threshold.
Anyone who has been notified eligible for the first phase of this support scheme must file their application no later than the 13th July – don’t miss that deadline if eligible.
The newly announced phase 2 (final phase) is now based on 70% (versus the original 80%) of the monthly average historic profits, and most of the eligibility factors for the phase 2 replicate those of phase 1. The maximum grant this time is therefore £6,570 and will be paid out in one instalment like phase 1. 
Importantly you do not need to have applied for phase 1 to apply for phase 2, which may be helpful to anyone whose position which has worsened in the interim period and was not able to claim they had been adversely impacted during phase 1.
Applications for Phase 2 will not open until August and we expect full guidance to be provided on the 12th June along with the FFS detail.
In advance of the government release of the full scheme rules for both of these extensions they have issued a useful guide on Friday’s announcements and it can be read here;
SEISS & CRS Factsheet

Given these amendments we have taken the opportunity to update our summary of support available guide and I share this below. I have removed the previous version (Vs5.0) from the archived documents.
Summary of Support Available Vs 6.0

OTHER MATTERS

FCA Test Case – Business Interruption Insurance

We are aware that very few insurers have paid out on their policies at present. For the lost revenue (sharply felt in private and FPI streams) an insurance payout would be a welcome support. I would like to highlight that the FCA have commenced court proceedings to test the wording of the policies involved and have entered in to a framework agreement with various insurers who would be bound by the findings. A representative sample has been taken and is to be tested in court. You can find a summary of the process on the FCA’s website at this page. Fingers crossed that some good news may emerge from that process at a later stage. The case is hoped to be heard in court in late July and take 5-10 days. My assumption would be that if the case went against the insurers that a series of appeals would follow and I would not imagine a pay-out if it were deemed to be appropriate would follow in a short time frame. Therefore, it would be prudent to assume that the likelihood of any recompense seems remote.

GDC Update

Debate over the GDC’s refusal to bend in anyway on the ARF during Covid-19 has inflamed once more after it was found that some of their staff have been furloughed at this time. One of the key defences to the stance adopted on the ARF was that the subscription fees represented the majority of the Council’s income and would need to be maintained to continue their efforts. We have been made aware of growing unrest on this matter and a request for further information has been submitted.

NHS CPD Allowance Reinstated 

After the recent withdrawal of the NHS CPDA we are delighted to report that the decision to withhold payment has been reversed and all claims submitted after 23rd March will now be paid in the June paid July schedules.
Anyone who was denied their payment for the Climate Survey submission should also receive their payment in due course.

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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