Things to consider regarding year-end infection control

December 9, 2019

Are there things you should be doing annually, but haven't done them? Don't panic yet-here's what you need to do now and what can wait.

Just like that, 2019 is almost over. If your practice has a to-do list that kept getting kicked down the road all year, don't panic just yet. As far as infection control is concerned, there are certainly items that need to be accomplished each year. But if the practice hasn’t completed those, there is still time to do so.

Requirements

“The CDC has a checklist,” Dr. Lisa Kane, DMD, dental consultant at Dental Office Compliance of New England, says. “You’re supposed to go through your office and make sure you’re following all the rules. The end of the year is a good time to make sure you’ve done that.”

According to the CDC’s Summary of Infection Prevention Practices in Dental Settings, the following administrative tasks should be performed regularly:

  • Policies and procedures should be tailored to the dental setting and reassessed.

  • Employers should involve those dental healthcare professionals (DHCP) who are directly responsible for patient care (e.g., dentists, hygienists, dental assistants) in identifying, evaluating, and selecting devices with engineered safety features, at least annually and as they become available.

  • Education and training should be provided during orientation to the setting, when new tasks or procedures are introduced, and at a minimum, annually.

“You should make sure that all your training logs are up-to-date and you’re testing a new device,” Dr. Kane observes. “You have to evaluate a new device each year to make sure that you’re up to doing the most current, the easiest, the safest techniques with sharps. And so, you’re supposed to document that you’ve tested new devices, every year.”

Penalties

It isn’t just a good idea to have performed these annual tasks. In some cases, the CDC or the state-or some other regulatory authority-may penalize a practice if they have not kept up these annual responsibilities. Muddying the waters a bit is the fact that there isn’t a nationwide set of standards. Different states have different requirements-some are less restrictive, some are more.

“Different states have different requirements,” Dr. Kane observes. “For example, I’m in Massachusetts, and Massachusetts says that whatever the CDC says, even if it says ‘recommendation’, you have to do it. So, in Massachusetts, and in other states that require CDC guidelines, you have to follow everything that’s in the CDC’s Summary of Infection Prevention Practices in Dental Settings. Do everything in the checklist at the end of the book, and document that you’ve done it.

“You should be checking everything in your office-your infection control protocols and your standard operating procedures,” Dr. Kane continues. “You should be making sure that every single thing is updated. And if you’ve had any breaches or you’ve had any needlesticks, you should be trying to figure out how you’re going to prevent that in the next year.”

Staying out of trouble is one thing, but the larger issue-protecting patients and staff-is more important.

“The more you’re doing, the safer that you’re doing things, the safer you patients are,” Dr. Kane says.

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Tax Implications

The end of the year is a good time to consider major purchases and how their acquisition affects the practice’s tax position. But businesses are warned not to buy something just for the sake of the tax break.

“I always tell people, ‘Don’t do something only for tax reasons, because you end up getting burned a little bit when you do that’,” Bruce Bryen, CPA, CVA advises. Bryen is Principal of RKG Tax & Business Services and an expert in the accounting practices for dental and healthcare offices. “If you were going to buy this in January, February, or March, you’re better off buying it in December, because if you were going to buy it, you’ve got the opportunity to defer your tax for another year by buying it in December.”

One advantage is that, depending on the equipment and how it is financed, the practice may not be financially affected by its purchase-on paper, at least.

“You buy it in December, if you finance it, you haven’t even paid for it,” Bryen illustrates. “You’ve got an advantage, and the accountant for the dentist can show how, if you did finance it, you’ve got this real nice, 100 percent tax deduction in 2019. And, if you paid for it over five years, people might say, ‘Well, I don’t want to pay the interest.’ But if you think, ‘What kind of tax bracket am I in?’ If I’m in California or New York, a state with a high tax bracket, plus federal, plus-if you’re the owner-you’re paying double social security and Medicare, so you’re over 50 percent. And if you financed it, you just got half your money back, immediately. You could, actually, figure out when is the break-even point? How many years does it take me before I’m even paying for this? So, when you reach that point, maybe three years, maybe two years and nine months, you’ve got the use of this for those number of years to make your practice better, safer and more sanitary and haven’t paid a thing until whatever that date might be.”

However, taxes can work both ways. While there are tax breaks possible when new equipment is purchased, one must consider what’s to be done with an old piece of equipment, if it is being replaced.

“Let’s just say you sell the piece of equipment and you can get $5,000 for it after you’ve written the whole thing off,” Bryen says. “Well, that $5,000 becomes income. So, you want to think about that, where if it’s not something that you’re using and getting an economic benefit from it, it really ends up costing you, if it doesn’t increase the value of your practice.”

Another consideration is that in order to realize the benefit of the tax break, the piece of equipment must be up, running, and in-use before the end of the year. Simply having purchased it is not enough to realize the benefits of the tax break.

“A lot of people don’t know that they’ve got to have this in place,” Bryen says. “It’s got to be in use by December 31st. It just can’t be in transit or in a warehouse, not hooked up. A lot of people have never heard that’s what you’ve got to do. It’s a very common mistake because somebody would go ahead and buy something, and they wouldn’t consult with the accountant or financial advisor.”

2019 is not over yet, but there are still infection control tasks that need to be completed. And, if the practice needs to buy a piece of equipment to help with infection control needs, there may still be time to purchase, put that equipment into service, and still be able to reap the tax break benefits.