Pandemic Recovery Guide

FAQs

Below are the most common questions we’re hearing from practices like yours.

Vaccines

Our partner CEDR regularly updates their answers to these questions and more.

What can I do if I have lost my vaccination record?

Unfortunately, there is no national organization that maintains vaccination records. You can find your vaccine record by state. Here are a handful of direct state links.

 

Can I require employees to be vaccinated against COVID-19?

The EEOC has now released guidance about mandating the COVID-19 vaccine, which falls in line with their flu vaccine guidance. Employers can administer vaccines at the workplace, ask for proof of vaccination, and even mandate vaccines. However, there is substantial risk in making a vaccine mandatory, and it is unlikely an employer could let someone go for not getting vaccinated. CEDR, our HR support partner, shared, “you should consider simply encouraging employees to get the flu and COVID vaccines rather than requiring them to get vaccinated.”

One of the best ways to encourage employees to be vaccinated is to make it as convenient as possible. The CDC has guidance on how to host a vaccination clinic and how to administer vaccines. Dentists should educate their teams on the importance of being vaccinated during meetings, providing information about the flu vaccine and the COVID vaccine. They should also provide employees with information on exactly where they can go in their community to get the vaccine. The CDC also has a vaccine declination form for healthcare workers.

Do I need to pay for my team’s vaccinations?

If the vaccine is mandated by an employer, the employer may be required to cover the cost of the vaccine and pay an employee for time spent getting the vaccine. Under the Fair Labor Standards Act, an employer must cover any work-related expenses for an employee if the cost of the expense would drop the employee below minimum wage. Your individual state laws may also require payment. Keep in mind, an employer is obligated to pay an employee for time spent seeking medical attention when it’s required by the employer and occurs during work hours.

Can I terminate an employee who refuses to be vaccinated?

Without a medical or religious exemption from a mandatory vaccination requirement, an employer may be able to make COVID-19 vaccination a condition of employment and terminate employees who do not comply. However, employers should consult legal counsel prior to making termination decisions.

Can I ask about my patient’s vaccine status?

The CDC recommends dental practices encourage vaccinations with their patients. They offer resources for conversation starters, downloadable posters, and FAQs.

A COVID-19 Diagnosis (Team/Patients)

California Dental Association addresses the top five related questions about COVID-19 exposure.

I suspect I may have COVID-19, what do I do?
I’ve tested positive for COVID-19. Now what do I do?

Decisions about return to work for dental team members or dentists with confirmed or suspected COVID-19 should be made in the context of local circumstances. Options include a symptom-based (i.e., time-since-illness-onset and time-since-recovery strategy) or time-based strategy, or a test-based strategy. The CDC provides guidance.

Please note: Return to work time frames are determined by your individual state’s Occupational Health or Public Health Offices. See individual state sites for details.

What steps are needed when a patient calls in post-treatment to report they were diagnosed with COVID-19?

The CDC has updated their quarantine guidance for dental healthcare professionals (DHCP) who have had extended contact (defined as 15 minutes or more) with the COVID patient, taking into account the use of personal protective equipment (PPE) by the DHCP and whether the individual with SARS-CoV-2 and/or the DHCP is up to date with all recommended COVID-19 vaccine doses.

Last updated 1/24/22

How can we be proactive regarding Contact Tracing?

Local Pubic Healthy Authorities, the ADA, and the CDC are advising practices to implement contact tracing to stop the spread of COVID-19 and prevent future business closures due to a resurgence of the virus. The COVID-19 virus can shed, infecting others, before the onset of symptoms. Contact tracing is a means of notifying people who may have been exposed to the virus, allowing them an opportunity to be tested and self-isolate. There is no clear timeframe as to how many days prior to symptoms the virus can be transmitted. The ADA recommends notifying people who were exposed to the virus based on a 3-day window of time, whereas the CDC recommends a 2-day window. In other words, once a person has developed symptoms, anyone they had been in contact with over the previous three days (ADA recommendation) would need to be notified of potential exposure.

The CDC defines exposure as a contact lasting for a cumulative total of 15 minutes in a 24-hour time period, within six feet of an infected person, starting from two days before illness onset (or, for asymptomatic patients, two days prior to a test specimen collection) until the time the patient is isolated.

Dental practices can be proactive:

  • Implement policies to reduce patient contact whenever possible, such as scheduling and collecting via technology instead of face-to-face contact.
  • Patients can wait in their vehicles until the operatory and provider are ready.
  • Maintain a six-foot distance in the reception area and lunchroom by reducing and moving chairs.
  • Dental healthcare professionals, who are not in full PPE, should make a note of anyone they had a potential cumulative 15-minute exposure to within a 24-hour window, based on the updated CDC definition (updated 10/19/21).
  • Ask patients to notify the practice if they develop symptoms or have a confirmed COVID-19 diagnosis within 3 days of their dental visit.
  • When the practice receives a notification, any staff member or other patient, who had a prolonged exposure, without full PPE in place, should self-isolate.

Additional information including HIPAA compliance regulations can be found in the Infection Control section.

Can I require my employees get a COVID-19 antigen or antibody test?
How do you determine when it’s safe to return to work? How do you determine when it’s safe for your employee to return to work? It’s a good question and one that will vary person-to-person.
 
The ADA has put together a PDF on “Testing Dental Employees for Antibodies and Antigens” with recommendations on steps you can take and what you can legally test.

Infection Control

Do patients need to wear masks when visiting the dental office?

While people who are fully vaccinated can stop wearing masks in most places, according to the CDC, people (staff, patients, and visitors) still need to wear masks in dental and medical offices.

Which guidelines do I follow; there are discrepancies among the ADA, CDC, my local public health, and state dental board?

The ADA and CDC provide recommendations, but do not have authority to write regulations. Your local authorities who write regulations, that are enforceable, are your state dental board and public health authority.

What additional infection prevention and control practices should we be implementing?

The CDC and ADA are aligned on infection prevention and control recommendations for all patients, without or with a suspected or confirmed COVID-19 diagnosis.

The ADA originally supported a 15 minute wait following completion of clinical care and exit of each patient before beginning to clean and disinfect room surfaces. Their recommendation now aligns with the CDC. 

Do OSHA regulations require the use of N95 masks during aerosol generating procedures?

According to the OSHA Guidance released on May 1st, aerosol-generating procedures performed on all patients are considered high-risk procedures, and the Guidance recommends, but does not require, that the dental healthcare professional wear N95 masks when performing those procedures.

Please be aware, any state run OSHA guidance trumps Federal OSHA guidelines, if the state run guidelines are more restrictive.

What do I need to do to comply with the Hazard Assessment recommendations contained in the May 1st Guidance released from OSHA?

OSHA recommends that employers assess the hazards their workers may face; evaluate any risks; and select, implement, and ensure employees use the controls their employer has implemented, to minimize identified risks. The assessment involves several action items dentists should consider. These include collecting existing information about COVID-19 hazards from credible sources, inspecting the workplace for potential safety hazards, identifying health hazards such as the biologic threat of infection from COVID-19 and potential transmission, and conducting incident investigations.

 

How can I identify an approved respirator?

Please be aware counterfeit respirators  are being falsely marketed and sold that may not be capable of proving appropriate protection to you and your team. The CDC a dedicated resource geared toward helping you identify signs a respirator may be counterfeit with misrepresentation of NIOSH-Approval. They have also posted some Additional Tips for Spotting Counterfeit Respirators.

I purchased air purifiers; is there any guidance on their effectiveness and where they should be located in my practice?

Yes, the CDC addresses air filtration in their guidelines for dental care. (Please note, this page has now been archived on the CDC website. Site-specific recommendations for dental practices can now be found in section “3. Site-specific considerations.”

According to the CDC:

Consider the use of a portable air filtration unit while the patient is actively undergoing, and immediately following, an aerosol-generating procedure. The use of these units will reduce particle count (including droplets) in the room and will reduce the amount of turnover time, rather than just relying on the building HVAC system capacity.

My pedo practice has open bays; how can I comply with the guidelines to reduce risk to my team and patients?

The American Academy of Pediatrics (AAPD) put together a return to practice guide for pediatric offices that specifically addresses this concern. Their recommendation is for the practice to, “consider barriers in bay” and “consider having drapes installed between chairs.”  You can read the full AAPD Return to Practice Guide for more details.

Human Resources

How do I manage employees who need leave due to schools closed or closing?

The Families First Coronavirus Response Act addressed this issue. Employers with fewer than 500 employees are required to provide up to 12 weeks of paid expanded family and medical leave if the employee must care for a child whose school or child care provider is closed for reasons related to COVID-19. You may have employees who exhausted their FFCRA leave in the spring, or as a small employer, perhaps you sought a small business exemption from the FFCRA mandate.

We encourage you to create a workforce strategy that outlines specific policies for your practice. Assess your team to determine which employees will be affected by school closures.

  • Have they exhausted their FFCRA leave time?
  • Are flexible working arrangements an option for them and the practice?
  • Consider and discuss alternate shifts or hours by mutual agreement.
  • Consider “work share” arrangements between employees.
  • Is unpaid leave an option?*
  • Do they have other options for child care?
  • Anticipate you may need additional part-time staff members to allow for these changes.

*Keep in mind, employers are not legally required to provide unpaid personal leave. If you decide to provide unpaid leave, you are advised to document the requirements or restrictions in your employee policy handbook and apply it consistently to all employees for fairness and to avoid allegations of discrimination.

As needs change throughout the pandemic, there should be an ongoing dialogue between you and your employees about what accommodations work best in order to set expectations around availability.

Due to the complex nature of federal statutes and their interaction with state and local laws, employers are advised to seek legal counsel for leave-related questions.

Can I limit my dental team member’s activities outside the practice during the pandemic?

Employers cannot control what employees do with their hours outside of work. Attempting to put some type of control over the employee’s off-hours is illegal.

What can dentists do when it comes to discussing hours outside of work with their team and COVID-19 safety measures?

You can certainly encourage and/or suggest employees practice social distancing, wear masks, and otherwise do all they can to avoid exposure and/or infection, for the good of themselves, their families, their co-workers, and the practice’s patients.

For further HR questions, we recommend you reach out to our preferred partner, CEDR Solutions. Additional answers to frequently asked “COVID” questions can be found on their website.

Scheduling & Fees

I’m worried about the impact of eligibility requirements on my Hygiene schedule during and after COVID-19. What should I do?

We know dental plans have unique eligibility requirements to provide reimbursement for dental cleanings:

  • Two preventative cleanings in a benefit year, which usually runs from Jan 1st–Dec. 31st, is a common frequency limitation.  (Plans written for school districts tend to run from Sept. 1st–Aug. 31st. )
  • The next most common frequency limitation requires preventive cleanings to be 6 months + 1 day apart from the last cleaning.

We recognize the 6 month + 1 day limitation, and varied benefit years, is challenging for practices that closed their doors to elective care to reduce the transmission of COVID-19.  The good news is, many plans are providing greater flexibility to allow their members an opportunity to maintain their oral health. Since there isn’t an all-inclusive approach to this challenge, we recommend you reach out to your contracted plans to learn how they are helping members gain access to care, and the level of flexibility they are offering with regard to frequency limitations.

How do we handle patients who want to schedule, but work in a hospital setting that treats COVID-19 patients?

The CDC has a set of supplemental screening questions specific to this situation. If the healthcare provider follows strict PPE guidance during their contact with COVID-19 patients, they are considered to be at low risk of transmission and should be scheduled accordingly.

Patient Communication

How can I best communicate the changes I am making to reassure patients?

Your patients may be anxious or even fearful; the information you share, and the manner in which you share it, will help alleviate anxiety and foster trust that strengthens patient relationships. Here are some helpful talking points to get you started.

PPP Loans

How do I ensure my PPP loan is forgiven?

First Draw PPP loans qualify for full loan forgiveness if during the 8- to 24-week covered period following loan disbursement:

  • Employee and compensation levels were maintained
  • The loan proceeds were spent on payroll costs and other eligible expenses; and
  • At least 60% of the proceeds were spent on payroll costs

Second Draw PPP loans made to eligible borrowers qualify for full loan forgiveness if during the 8- to 24-week covered period following loan disbursement:

  • Employee and compensation levels are maintained in the same manner as required for the First Draw PPP loan
  • The loan proceeds are spent on payroll costs and other eligible expenses; and
  • At least 60% of the proceeds are spent on payroll costs

We encourage you to review the list of lenders participating in direct forgiveness to determine whether you must apply through the SBA.

For borrowers whose lender participates in direct forgiveness, you can use the SBA portal to apply after August 4, 2021. Direct forgiveness borrowers must use the SBA forgiveness portal.

For borrowers whose lender is not participating, you must apply through your lender. Your lender can provide you with the appropriate forms and further guidance on how to submit the application.

Last Updated 7/30/21

SBA has created an application form for PPP Loan borrowers. Download the Paycheck Protection Program Loan Forgiveness Application PDF with instructions and calculation form for borrowers.

No comprehensive rules were issued (as anticipated) with the form, however, some things were clarified:
  • Loan forgiveness isn’t all or nothing – if you didn’t spend 75% of the PPP loan on payroll costs (as required), the rules for forgiveness have you divide the total amount you did spend on payroll costs by 75%’, giving you the maximum loan forgiveness amount for your loan (assuming the balance was spent on other qualifying expenses).
  • If you pay weekly, or every 2 weeks, the revised rules allow a delay to the start of the 8-week period (for payroll costs only) to the start of your next pay period following disbursement.
More favorable changes should be coming shortly, and we’ll post those here as they are available.

Last Updated 5/27/20

FAQs You Might Be Hearing From Your Patients

Have any of your team members tested positive for COVID-19?

Yes. We have had a team member test positive. We are able to identify symptoms quickly since we screen our staff in a similar manner to how we screen our patients. They must report any symptoms and have a temperature check prior to starting their shift each day. If the staff member has any symptoms, or fever, they are immediately sent home and asked to get a COVID-19 test. If positive, each patient they treated, or had contact with, in the last 3 days, is informed. The staff member remains home until all symptoms have resolved and their quarantine period has ended. We strictly follow our local healthcare authority guidelines as well as CDC and OSHA guidelines in this regard. We are committed to keeping you, ourselves, and our community safe.

No. We are able to identify symptoms quickly since we screen our staff in a similar manner to how we screen our patients. They must report any symptoms and have a temperature check prior to starting their shift each day. If the staff member has any symptoms, or fever, they are immediately sent home and asked to get a COVID-19 test. If positive, each patient they treated, or had contact with, in the last 3 days, is informed. We are committed to keeping you, ourselves, and our community safe.

Have any of your other patients tested positive for COVID-19?

Yes. We have learned that a patient we treated was later diagnosed with COVID-19. We are so fortunate to have protocols in place to be able to quickly identify and respond to these situations. We ask every patient to inform us if they have had a positive COVID-19 test within 3 days of care at our practice. We will ask the same of you after your appointment. If a patient reports back to us, we identify staff members who treated the patient and take appropriate actions. Patients wait in their vehicles prior to their appointment to avoid patient-to-patient contact. It is one of our many protocols in place to keep you, ourselves, and our community safe.

No. We continue to follow all the ADA and CDC guidelines, including taking the temperature of all employees and patients before they enter the practice each day.  We are closely monitoring our team members’ health, prescreening patients, and asking both to alert us if they have any family members or social interactions with anyone who has developed symptoms.  We will continue to strictly follow these policies and update our screening when new guidelines emerge from the CDC, ADA, and our local health authority. We actively monitor that information on a daily basis. It is our goal to keep you, ourselves, and our community safe.