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Pandemic Recovery Guide

FAQs

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

How do I ensure my PPP loan is forgiven?

On May 16th the 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).
  • Restoring your staff levels and each staff member’s pay to Feb. 15th levels, on or before June 30th, helps you avoid deductions to your loan forgiveness amount.
  • 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.
  • You can’t increase your pay to boost forgiveness. If your compensation was less than $100,000 in 2019, you cannot increase your pay rate in 2020 in order to boost your loan forgiveness amount.
More favorable changes should be coming shortly, and we’ll post those here as they are available.

Last Updated 5/27/20

 

As of May 1st, PPP recipients, and the CPAs who advise them, are waiting for guidance on specific documents required and calculations to use in determining their loan forgiveness amount under the PPP.  The Treasury department and the SBA have shared that guidance is “forthcoming.”  In the meantime, the American Institute of CPAs has developed a resource which outlines the steps to take for PPP loan forgiveness (as of 4/24/2020).

Thomas Doll of the Academy of Dental CPAs has created a helpful PPP Forgiveness Tracker (follow the link to the resources for the most up-to-date version).

For additional information on PPP loan forgiveness, review the information on these sites:

Last Updated 5/6/20

 

The SBA and Treasury Department recently released detailed rules dentists need to follow, so the team members who refuse to return to work in the practice are not held against you for purposes of calculating the practice’s PPP loan forgiveness (FAQ #40). Under Section 1105(d)(2) of the CARES Act, your PPP loan forgiveness amount is reduced if your number of FTE staff is otherwise reduced below pre-pandemic levels.
It’s recommended you provide a notice to each staff member, in writing (by email or regular mail), as soon as possible, in order to comply with this new rule. Your notice should include:
  1. Notice of reopening date and time
  2. Offer of rehire at same wage and same number of hours as prior to closure
  3. Request for a response, in writing, of rehire offer with a response deadline
  4. Notice that if they should not accept re-employment, they may forfeit eligibility for unemployment compensation
For documentation purposes, place a copy of this notice, and all responses received, in each employee’s personnel file, as well as your PPP loan forgiveness file.
Last Updated 5/13/20
Some staff members prefer to stay on unemployment as they are realizing a higher income through unemployment benefits or are fearful for their safety. What should I do?

Educate your staff on unemployment rules in your state. For many unemployment plans, the offer of employment will disqualify them from receiving benefits. In addition, the $600 per week stimulus is a short-term benefit scheduled to end in July. If staff are fearful, you have an obligation to create a safe work environment. Meet with your staff to let them know what you are doing to create a safe place to work to mitigate the spread of COVID-19.

If you applied for the PPP loan, please see the FAQ titled “How do I ensure my PPP loan is forgiven?” for additional information.

 

Can I pass on a PPE fee to patients when I am in-network?

It depends on the contract terms with each carrier. Some carriers consider your PPE fees to be a part of the procedure and will not allow you to bill separately. This process is called “bundling.” When this occurs, the dental insurance company will consider your request either disallowed or non-covered. If the fee is disallowed by the carrier, you cannot balance bill the patient. If the fee is non-covered, you must follow the non-covered benefit laws in your state, but can most likely bill the patient. Non-covered benefit laws prohibit dental insurers from interfering when a contracted dentist agrees to provide a non-covered service to a patient, when the patient understands it is not covered by their dental plan. Currently 36 states have non-covered benefit laws. If you are not in-network as a contracted provider, you may bill the patient a PPE fee.

The ADA is currently advocating for third-party payers to add a per-visit fee to help cover these additional costs and encourage you to use code D1999 for reporting purposes. Best practices would include a chart note that verifies additional PPE use in order to limit the spread of COVID-19, and a protocol to inform the patient of the added fee, prior to treatment. Sign up for the ADA Toolkit for additional guidance.

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.

 

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. Additional explanations have been provided by the ADA.

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.

To comply with recommendations for Hazard Assessments from OSHA, consider implementing the ADA’s Hazard Assessment.

 

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.

 

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.

If you’re re-opening your practice, you might also find this information helpful.

 

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.

 

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.

 

 

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.