NASDAL Goodwill Survey finds big fall in NHS practice values

This week saw the latest survey results published from the NASDAL (National Association of Specialist Dental Accountants and Lawyers) Goodwill statistics. This survey covers the quarter ending 30th April 2021 and includes data on valuations as well as deals done (i.e., practices bought or sold by NASDAL members’ clients in the period).

Goodwill as a percentage of fee income in the quarter across all types of practice averaged 128% of gross fees – down from 139% in the quarter to January 2021. The big drop was in NHS practice goodwill – down from 191% of gross fees in the previous period to 146% of gross fees this time.

Private practices values stayed steady at 110% of gross fees compared to 114% of gross fees in the previous period. Mixed practices, which can be the most volatile of the three categories, saw quite a leap – up to 156% of gross fees compared with 110% last time.

More realistic valuations?

The graph also illustrates a big drop in valuations. Alan Suggett, specialist dental accountant and partner in UNW LLP who compiles the goodwill survey, said, “I wonder if the big drop in valuations has seen the dental valuation market catch up with the prices that are actually being paid and is just the market correcting itself.

“In regard to the big drop in NHS practice values, I would have to say that I am somewhat surprised by this. It has certainly not been my subjective experience. I have heard some raise concerns about the long-term effect of the Covid pandemic on the ability of NHS practices particularly to run profitably. While the virus was initially seen to be short-term and something that we might be over in a few months, banks were perhaps willing to lend on previous accounts and figures. As it rumbles on, less so.

“It does seem likely that from a dental perspective there will be longer term implications in regard to PPE, patient numbers, air filtration and so on. Whether this will hit NHS practices hard that needed a good level of patient throughput to be successful, only time will tell.”

The goodwill figures are collated from accountant and lawyer members of NASDAL in order to give a useful guide to the practice sales market. These figures relate to the quarter ending 30th April 2021.

NASDAL reminds all that as with any averages, these statistics should be treated as a guideline only.

NASDAL holds its annual ‘State of the Nation’

Thursday 25th March saw NASDAL (National Association of Specialist Dental Accountants and Lawyers) hold its annual press conference – this year virtually at BDIA Dental Showcase – and many Principals, Associates and team members, along with the dental media, joined what was an enlightening event with 5 presentations and then an interactive Question & Answer session.

It has been an unusual twelve months and this year’s event reflected this by being billed as a ‘State of the Nation’ press conference dealing as it did with a wide variety of dental related financial and legal matters.

After being welcomed by Nick Ledingham, Chartered Accountant and Senior Partner of Morris & Co, Specialist Dental Accountants and Chairman of NASDAL, the conference heard the latest goodwill value statistics announced by Alan Suggett, specialist dental accountant at UNW and NASDAL Media Officer. These are normally produced on a quarterly basis but due to the pandemic, the latest figures covered the four months that ended 31st January 2021.

Against what many may have expected, the latest period showed very little reduction in practice values due to the pandemic. As with the last survey (which covered the period from 1st April to 30th September 2020), in NASDAL members’ experience, although there have been only limited price reductions, there has been a considerable lengthening of the sales process. Alan commented, “It certainly does show that the UK dental practice sales market is not the dystopian nightmare that some commentators have suggested!”

Benchmarking Statistics – “continued fall in NHS practice profits but better news for Associates”

Ian Simpson, Chartered Accountant and a partner in Humphrey and Co, then presented the Benchmarking Statistics for the year 2019-2020. The NASDAL benchmarking statistics are published annually in March and reflect the finances of dental practices and dentists for the most recent tax year. The NASDAL figures provide a detailed picture of dental practice finances, sourced directly from dentists working privately and in the NHS. They are immensely useful but this year, as the period in question only ran until March 2020, they have limited information to offer about the effect of the pandemic. However, they do make interesting reading. Some of the key points from this year were:

  • A continued fall in NHS practice profits – this is perhaps as NHS practices tend to depend more on the use of Associates
  • A slight fall in net profit across the market as a whole
  • Better news for Associates with an increase in fee income of 3% and an increase in net profit of 2%
  • Practice expense ratios stayed very consistent with previous years

Ian Simpson said, “Overall, we have seen results similar to the previous year with a small impact of COVID-19 in Feb/Mar 2020. Net profit of a typical dental practice fell back to £129,178 from £134,387 in 2019 and both NHS and Private practices saw a reduction in profit (NHS – £116,284 in 19/20 down from £124,475 in 18/19; Private – £133,192 in 19/20 down from £140,591 in 18/19). Only mixed practices bucked this trend with a small rise from £132,940 in 18/19 to £134,342.

“What the figures will show for the year of the pandemic is conjecture at this point, but we certainly find ourselves in a very different landscape now from a little over a year ago.”

NHS Quarter 4 – meeting the targets

Alan Suggett then returned to discuss what has happened (in England), since the beginning of January 2020 in terms of Q4 targets and the need to achieve 45% of pre-pandemic activity to avoid any financial penalties by way of ‘clawback’. Alan identified two key issues that were affecting practices.

“First and foremost, my concern is for a small but significant number of practices that will be unable to hit the threshold of 45% of UDA contract amounts and how that ‘cliff edge’ will affect them. The fact that many NHS practices are already hitting this target is good news but irrelevant to those that cannot.”

“Another perhaps unconsidered consequence of the Q4 rules is pay cuts of more than 65% for some self-employed dental associates who carry out NHS work. During the COVID 19 crisis a very important measure of financial protection has been given to NHS associates as so far they have been paid in full. Q4 rules brought this to an end for those associates who work in practices which cannot hit the 45% UDA threshold.

“I feel that a fair compromise is quite simple – remove the ‘cliff edge’ at 36%. I worry that without this change, a small percentage of the total NHS contract holders could be in real trouble. In addition, the associates who work in those practices could suffer a pay cut in excess of 65%.”

“I will leave Heidi to discuss what might happen as of 1st April, suffice to say that there will be no material change in circumstance between 31st March and the following day and therefore I would be surprised to see any movement from the 45% figure.”

Practice sales market – “still buoyant”

Chair of the NASDAL Lawyers Group and partner at Ward Hadaway, Damien Charlton then discussed the Practice Sales market over the last year. As Alan Suggett had already referred to, this was a whole lot busier than many might have expected. What the pandemic did do was slow the entire sales

process. Damien said, “From March 2020 until June 2020 there was a hiatus as society was locked down. Then, volumes of practice sales picked up quickly and NASDAL members saw a particular surge earlier this year as many sought to avoid a potential Capital Gains Tax increase in the Budget that as it turned out, didn’t materialise.”

“To illustrate the added time now involved, it can take up to 20 weeks for the CQC to register a new partnership allocation! As we move forward, it seems that those buying practices are having to do so in more of a ‘blind’ fashion than in is traditional. Even though a practice has been successful in the past, the new world that we find ourselves in, means it is no guarantee of future prosperity.”

The Future – “the reckoning of the end of furlough”

The final presentation was delivered by Heidi Marshall, who is the NASDAL Honorary Secretary and heads up the dental team at Dodd & Co Chartered Accountants. Heidi had the unenviable task – even more so in these times – of considering what may happen in the coming months.

Heidi covered a wide range of areas including Q1 percentages, clawback and the ‘Zoom Boom’ of dentistry. She also shared evidence of mixed practices taking the decision to leave the NHS as they are finding that the numbers no longer add up.

Heidi particularly focused on the end of furlough and that September 2021 will see a real reckoning in many sectors. “I think that we will see the true impact of what the end of furlough will mean for our economy. Potentially hundreds of thousands of people could find themselves out of work and that will certainly mean a reduction in enquiries for elective dentistry but perhaps even the more regular dental care too?”

Nick Ledingham, of Morris & Co, Specialist Dental Accountants and Chairman of NASDAL concluded, “I am pleased to see that the UK dental sector has reacted to the challenge that Covid has provided in a typically robust fashion, but it has been a tough 12 months for many and the future is still uncertain.

“Now, more than ever, it is important that dental practices take specialist advice so that they can understand and react to changes in their business situation.”

NASDAL: Uber ruling – what will it mean for the dental sector?

Many dentists (both Principals and Associates) will be aware that there was a Supreme Court judgement last Friday that ruled Uber drivers must be treated as workers rather than self-employed.

The five key facts in the Uber judgement were:

  1. Remuneration was controlled by Uber including the amount paid to drivers and whether to refund passengers.
  2. Drivers have no ability to negotiate the terms they contract with Uber on or the terms on which they transport passengers.
  3. Once the driver is logged into the Uber App, they have limited power over their operations, placing them in a position of subordination. For example, the driver is not informed of the intended destination before accepting the fare and Uber can log the driver out if their acceptances or cancellations are unsatisfactory.
  4. Uber exercise significant control over the service provided to passengers as the cars are vetted, the software is integral, Uber control the information provided to drivers, and drivers are monitored.
  5. The relationship between the driver and the passenger is restricted to a minimum, preventing the driver from establishing a relationship which benefits their ‘business’ as a driver, which is specifically prohibited by Uber in any event.

This has meant that the political hot potato of whether Associates should be self-employed or not has again risen its head. From a tax perspective, this has been covered in previous NASDAL (National Association of Specialist Dental Accountants and Lawyers) releases and the position is still very clear – HMRC guidance contained in “Employment Status Manual ESM4030 Particular occupations: dentists” states:

“It should be noted that there are standard forms of agreement for ‘associate’ dentists which have been approved by the British Dental Association (BDA) and the Dental Practitioners Association (DPA)(sic). These agreements relate to dentists practicing as associates in premises run by another dentist.

“Where these agreements are used and the terms are followed, the income of the associate dentist is assessable under trading income rules and not as employment income. In these circumstances the dentist is liable for Class 2/4 NICs and not Class 1 NICs.

“The NHS General Dental Services Contract, which came into force from 1 April 2006, provides for less fluctuation in Associate Dentist’s income. However, providing the Associate Dentist continues to be responsible for paying their share of laboratory fees etc. for work relating to their patients and other terms of the standard agreement are followed, the above guidance will still apply.”

Alan Suggett, specialist dental accountant and partner in UNW LLP, said, “What is perhaps less clear now is that arguably an Associate could be considered self-employed by HMRC and yet be a ‘worker’ from an employment law perspective. Perhaps where the Associates are different to most Uber drivers is that they want to be self-employed.”

Some have expressed concern that these potential employment rights could have an effect on the vicarious liability of the Associate as well as worker benefits. If Principals became liable for maternity leave and holidays, this could drive Associate pay down and employment might actually be a more attractive option for all moving forward. However, one of the key factors in the judgement is that the Uber drivers could not substitute or send a locum in to do their work. They had to perform it personally. This is not always the case for dentists. They usually have the right to substitute in their contract and this is why it is key that contracts are abided by and not changed without expert advice.

UNW employment tax partner Lee Muter added, “The Uber case is more to do with employment rights obtained for the individual drivers as being “workers” which is a separate category within employment law, probably a hybrid between an employee and self-employed, rather than affecting the status for tax purposes. One of the quirky things about this is that the driver could still potentially be classed as self-employed for tax purposes but a worker for employment law purposes, so having potentially the best of both world in that they could obtain some valuable employment rights such as holiday pay, etc but also have the flexibility and other benefits associated with being self-employed for tax.”

Supreme Court Ruling – pay out for dentists?

Last Friday saw the Supreme Court back many small firms including dental practices over business interruption insurance claims reports the National Association of Specialist Dental Accountants and Lawyers, (NASDAL) reports.

The Supreme Court found largely in favour of small firms receiving payments from business interruption insurance policies. For some practices it could provide a lifeline and the ruling is likely to cost the insurance sector hundreds of millions of pounds. The City watchdog, the Financial Conduct Authority (FCA), brought the test case, and the Supreme Court rejected the appeals from 6 insurers against the Judgement handed down by the High Court in September 2020 following the FCA Business Interruption Test Case.

Steven Davidson, NASDAL member and partner at Olive Clive & Co Chartered Accountants commented, “this does appear to be excellent news for policy holders claiming for Business Interruption following Covid-19 Lockdown. While today’s Supreme Court ruling provides clarity for many thousands of claimants, it is unlikely to provide a clear-cut resolution for all. There are still a number of issues that need resolving. One is the question of aggregation and whether insurers will accept that the disruption caused by the pandemic is one event or more – this issue has not been decided by the Supreme Court and may well have to be decided by future litigation.

“There is also the question of whether any applicable sub-limit or multiple sub-limits of liability applies to any one loss, any one claim, any one occurrence, any one event or any one originating cause under the policy and are recoverable particularly under non-damage BI extensions.”

Latest NASDAL Goodwill Survey released, covering 1st April – 30th September

This week saw the latest results published from the NASDAL (National Association of Specialist Dental Accountants and Lawyers) Goodwill Survey statistics. In a normal world, these statistics are produced on a quarterly basis – however, 2020 has proved to be far from normal – hence six months delay since the last publication. This survey covers the period from 1st April to 30th September 2020 and is based on deals done (i.e. practices bought or sold by NASDAL members’ clients in the period).

As the graph illustrates, goodwill prices have held up very well. Goodwill as a percentage of fee income in the period across all types of practice averaged 141% of gross fees – only down from 159% from the quarter to January 2020 – the last pre-Covid quarter.

And, the level of deal activity is very much higher than many expected.

NHS Goodwill values were higher when compared to the previous quarter with 191% of gross fees across the six months to 166% of gross fees last time. Private goodwill values fell back to 114% of gross fees from 143% of gross last time. The big fallers were mixed practices – falling from 188% of gross fees in the quarter ending January 2020 to just 110% of gross fees this time.

What does this mean?

Alan Suggett, specialist dental accountant and partner in UNW LLP who compiles the goodwill survey, said, “I have to say that both the level of deal activity and the pricing levels have surprised me. I was expecting to see a big drop in the number of practice sales coupled with a sharp fall in prices. In NASDAL members’ experience, there have been only limited price reductions and the corporates haven’t used Covid as an opportunity to negotiate lower deal values. It certainly does show that the UK dental practice sales market is not the nightmare that some commentators have suggested!

“We do know that many lenders are coming up with an increasing array of hoops for borrowers to go through – which puts cash buyers in a stronger position.

“We decided not to include valuations during this six month period as the amount of data was lower than usual, and valuations are invariably subjective, which is unhelpful during this period of uncertainty.

The goodwill figures are collated from accountant and lawyer members of NASDAL in order to give a useful guide to the practice sales market. These figures relate to the six months ending 30th September 2020.

NASDAL reminds all that as with any averages, these statistics should be treated as a guideline only.

NASDAL: More than half of UK dental practices rely on Government loans

A recent NASDAL (National Association of Specialist Dental Accountants and Lawyers) survey has found that 52% of UK dental practices have relied on either CIBLS (Coronavirus Business Interruption Loan Scheme) or BBLS (Bounce Back Loan Scheme) from the government.

The survey was carried out last month and a sample of 121 practices (with a total fee income of £88 million) was taken from NASDAL accountant member practice owning clients on a random sampling basis. The survey found that:

  • 11% of practices have taken out CBILS loans, mainly private practices
  • The average CBILS loan is £105k (12% of fee income)
  • 41% of practices have taken out BBLS loans, covering all types of practices.
  • The average BBLS loan is £49k (7% of fee income).

The average loan is £32k (4% of fee income) and overall, 52% of dental practices have taken advantage of Government backed Covid loans.

 Alan Suggett, specialist dental accountant and partner in UNW LLP who compiles the goodwill survey, commented, “these findings don’t surprise me and reflect what I have found when speaking to dental clients. The CBILS application process was particularly arduous and difficult and this meant that in my experience, those practices that applied for CBILS loans really did need the funds. BBLS however, required just a couple of ticks and the money was in the account 48 hours later. I suspect that a large number of applicants did so on a ‘just in case’ basis and will be happy to pay the money back in full next year.

“One of the major concerns that NASDAL had when we reported to the short life working group (SLWG) headed up by Deputy CDO England, Jason Wong, was that most dental practices are fundamentally sound businesses and to see a good number in potential difficulty purely because of capital loan repayments, is a real concern. That is why it was key for us that in the recommendations, a government guaranteed loan support scheme to underpin lenders confidence in supporting dental practices and dental laboratories at risk was included.

“When the CIBLS and BBLS repayments become due next year, we will see how many dentists and practices are in difficulty.”

NASDAL COVID SURVEY RESULTS

Number of Practices in survey   121  
Total Fees     £88,418,701  
Total NHS Fees   £35,948,501 41%
Total Private Fees   £52,470,200 59%
Total COVID Support Borrowings   £3,822,000  
Average Support Borrowings (Per Practice)   £31,587  
Percentage of Borrowings to Total Turnover   4%  
         
Number of Practices with CBILS   13 11%
Total Fees (of Practices with CBILS)   £11,896,317 13%
Total NHS Fees (of Practices with CBILS)   £1,941,133  
Total Private Fees (of Practices with CBILS)   £9,955,184 84%
Total CBILS Borrowing   £1,369,000  
Average of CBILS Borrowings to Number of Practices with CBILS £105,308  
Percentage of Borrowings to Total Turnover (of Practices with CBILS) 12%  
         
Number of Practices with BBLs   50 41%
Total Fees (of Practices with BBLs)   £34,481,458 39%
Total NHS Fees (of Practices with BBLs)   £15,198,902  
Total Private Fees (of Practices with BBLs)   £19,282,555 56%
Total BBLs Borrowing   £2,453,000  
Average of BBLs Borrowings to Number of Practices with BBLs £49,060  
Percentage of Borrowings to Total Turnover (of Practices with BBLs) 7%  

NASDAL Goodwill Survey – what happens next

This week saw NASDAL (National Association of Specialist Dental Accountants and Lawyers) release their Goodwill Survey statistics – these statistics are normally produced on a quarterly basis and provide a useful snapshot of the dental practice sales market.

However, these are not normal times. Due to the Covid-19 pandemic, this week saw the delayed release of the figures for the quarter ending 31st January 2020.

The survey for the quarter saw a small increase – again – in the goodwill as a percentage of fee income in deals done. This is the sixth quarter in a row that deals have risen – from a low of 122% of gross fees in quarter ending October 2018, to 159% of gross fees in this latest quarter.

Again, NHS practice values fell back a little – from 166% of gross fees in the previous quarter to 155%.

The quarter did see a big rise in valuations though – up from an average goodwill value of 132% of gross fees in the quarter ending 31st October 2019 to 157% of gross fees this time. Valuations of NHS, private and mixed practices were all up in the quarter with particularly big rises in the valuations of mixed and private practices.

What will happen next?

Alan Suggett, specialist dental accountant and partner in UNW LLP who compiles the goodwill survey, said, “It is fair to say that the most interesting part of this survey is effectively what it doesn’t show – that is what has happened since March 2020 and the advent of the Coronavirus pandemic. Following this, I think it is fair to say that the days of the spectacular corporate deals we have seen in recent years, are over.

“At NASDAL we obviously spend a good deal of time speaking with other professional service providers such as bankers, valuers, IFAs and so on; the prevailing view is that we are currently in a ‘marking time’ stage as everyone waits for normality to return. And, most do expect normality to return. The number of practice sales during the last few months has massively reduced and those that are being done are often seeing a substantial discount to go through.

“At present, most buyers are requesting a delay in the process. There is more uncertainty with regard to lender valuations, some valuers are valuing at pre Covid levels but based on the assumption of a longer sale period rather than the previously normal 6 months. Lenders are still happy to lend but they want more information such as up to date management accounts, or even vendor prepared cashflow forecasts.”

The goodwill figures are collated from accountant and lawyer members of NASDAL on a quarterly basis in order to give a useful guide to the practice sales market. These figures relate to the quarter ending 31st January 2020.

NASDAL reminds all that as with any averages, these statistics should be treated as a guideline only.

NASDAL: “Beware 31st January tax pitfalls”

Last week saw the Summer Economic Statement delivered by the Chancellor of the Exchequer. Rishi Sunak concentrated very much on job support, job creation and job protection with temporary tax reductions targeted specifically at the hard-hit hospitality sector and at the sluggish residential property market.

There was relatively little of direct relevance to the dental sector and Charles Linaker, a tax partner with NASDAL members UNW, says that the most important Covid-19 measure of which dentists need to be aware is a measure announced previously in relation to their 31 July payments on account due under Self-Assessment.

“The majority of dentists will have had average earnings above the limits which might have rendered them eligible for help under the Self-Employment Income Support Scheme and so, for them, the main measure of relief is the opportunity to defer their second payment on account for tax year 2019/20, due at the end of July, until next 31 January 2021, which was brought in as a response to Covid-19. By now, most dentists should have received their Self-Assessment statements from HMRC showing that their 31 July payment has been deferred automatically to 31 January 2021.

This has been done so that HMRC’s IT systems do not automatically charge late payment interest on any 31 July 2020 payment on account paid between 1 August 2020 and 31 January 2021. In other words, while it remains an option to make the payment as normal, should dentists choose not to, so as to preserve cash at this uncertain time, they need take no action to inform HMRC and will not be at risk of interest or penalty charges so long as the amount has been paid by no later than 31 January 2021.”

Linaker continued, “of course, it may be argued that deferring until 31 January 2021 is doing no more than putting off the evil day and that there will then be a doubling up of tax payments, because the first payment on account will then be due for tax year 2020/21. But that is to overlook the fact that there is a long standing facility, of which many dentists may never have needed to take advantage previously in their professional careers, to make a claim to reduce the 2020/21 payments

on account for 31 January 2021 and 31 July 2021, on the grounds that current year profits for 2020/21 will be reduced significantly compared to those for the preceding year 2019/20. Given the timing of lockdown as a result of Covid-19, this is likely to be a facility which many dentists will want to make use of and they should ensure they liaise with their accountants well before 31 January 2021, so that appropriate calculations can be made to justify a claim to reduce their 2020/21 payments on account.”

NASDAL offers clarification on SEISS

The National Association of Specialist Dental Accountants and Lawyers (NASDAL) have welcomed clarification on the potential issues that may arise when dentists were eligible to claim the Self-Employment Income Support Scheme (SEISS) grant whilst also receiving their usual level of NHS income. It was highlighted that the amount of grant received may exceed the reduction of private income.

The eligibility criteria for the SEISS grant requires that you have been adversely affected by Covid-19 and that your average self-employed earnings (from all sources) over the last three tax years have not exceeded £50k pa. HMRC have confirmed that if part of a dental practitioners’ income (private income) reduces, but another part remains the same (NHS income), it is legitimate for a claim to be made in full and retained.

Alan Suggett, specialist dental accountant partner in UNW LLP and NASDAL Media Officer, said, “We have received communication from the BDA following discussions with NHS England on this matter and they confirmed that receiving both NHS income and the SEISS grant does not constitute a duplication of wider government support and therefore does not breach any of the terms of the NHS contract payment arrangements.”

Fellow NASDAL accountant Johnny Minford of Minford & Co, who has a number of clients in Northern Ireland, added, “However, our Principal colleagues in Northern Ireland still have a problem as the mechanism there does not permit a double claim and the choice is in the hands of associates. There could be practices where the associate has chosen to claim SEISS, so the practice gets NONE of the IOS payment due for the associates’ proportion of the healthcare.”

NASDAL: Uncertainty reigns

The National Association of Specialist Dental Accountants and Lawyers (NASDAL) has called for clarification over a number of key financial issues affecting the profession.

Alan Suggett, specialist dental accountant partner in UNW LLP and NASDAL Media Officer said, “We quite understand that matters of patient safety and all things clinical taking are precedence in the current situation. However, dentists and practices need resolution on a number of financial and contractual issues. We cannot ignore the fact that dental practices are businesses. Indeed, a recent Dental Protection survey showed that more than one in two (53%) dental professionals said financial worries were having the biggest impact on their mental health in the face of Covid-19.

A new NHS contract in line with the Prototypes must be introduced. The CDO (England) letter says “…mechanisms for the full 2020/21 contract year with the intention of reintroducing a link to delivery of activity and outcomes”. For the foreseeable future an activity-based NHS contract will be unworkable. Now is the time to implement the vision of the late Sir Jimmy Steele and achieve preventative dental care within a viable financial framework for NHS practitioners. Until this happens, our clients must attempt to make plans and financial forecasts with no idea of what the new NHS contract financial landscape will look like”

Other issues lacking clarity include NHS contract payment abatement, and duplication of government support e.g., SEISS, Bounce Back loans, and Small Business Rate Relief grants.

Johnny Minford, of Minford Dental Accountants commented, “in regard to SEISS, a number of difficult questions arise for dentists carrying out both the NHS and the private work. Many dentists earn more than the £50,000 threshold, but some don’t, for a variety of reasons.

The self-employed grant (SEISS) is paid if an individual’s taxable profit is less than £50,000, after capital allowances, but before pensions or superannuation. However, HMRC is unaware of any income under the NHS contract provisions. There is therefore a risk that the NHS Covid payment rules may be breached when the receipt of SEISS, in addition to NHS Covid earnings, exceeds pre-Covid income levels.

A recurring theme from the NHS is ‘reasonableness’. It is vital that NHS practitioners keep notes and records of the factors leading to decisions taken, and why they were made. This will give the best protection against comeback.

Alan Suggett went on to add, “the fact that UK dentistry and healthcare are devolved, has further added to a sense of confusion. We would like the CDOs of England, Wales, Scotland and Northern Ireland, and the appropriate devolved administrations, to realise how vital clarity of financial matters is to NHS contract holders, and communicate this in a clear and unambiguous format as a matter of urgency. As a nonpartisan association, NASDAL are happy to engage with and assist these parties with this vital task. The CDO (England) has stated that ‘all parts of the UK will be aligned’. However the differences in the systems of delivery of NHS dentistry mean that this cannot be achieved without an integrated plan dealing with technicalities.”