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DC Dental Society Opposes BL21-0415 Universal Paid Leave Act of 2015

The 460 members of the District of Columbia Dental Society (DCDS) oppose BL21-0415 the current proposal for Universal Paid Leave Act of 2015. We have member dentists practicing in all 8 wards of our city. Not only do these practices provide needed health care to the residents of our city, but they are a source of economic support for their employees and the businesses in their surrounding neighborhoods.

Dear Chairman Mendelson and Members of the City Council:

The 460 members of the District of Columbia Dental Society (DCDS) oppose BL21-0415 the current proposal for Universal Paid Leave Act of 2015. We have member dentists practicing in all 8 wards of our city. Not only do these practices provide needed health care to the residents of our city, but they are a source of economic support for their employees and the businesses in their surrounding neighborhoods.

The costs associated with maintaining a dental practice in the District escalate each year. In addition to the high cost of real estate, utilities, and employee wages in the District, each dentist is required to pay numerous licensing and registration fees. These fees include their individual dental license, their US DEA Controlled Substance Registration, their DC Controlled Substance Drug Registration, their DC Property Tax, a DC DOH fee on each x-ray machine in their offices, payroll taxes and DC Worker’s Compensation Taxes. These taxes must all be paid before realizing any personal income.

By adding an additional payroll tax to fund this project, you will be increasing the costs on dental practices. Many dental practices are subject to reimbursement by dental insurance plans and are unlikely to be able to recoup this additional tax by raising fees. These practices will likely refrain from raising salaries on existing employees or by limiting benefits.

The majority of dental practices are small single owner businesses that depend on highly specialized employees. The majority of these employees are regulated by the District’s Department of Health and are either licensed, as in the case of dentists and dental hygienists or are registered in the case of dental assistants. The current state of the licensing/registration process in the District can take in excess of 4 months for a new dentist, hygienist or assistant to obtain a license/registration in the District. This excessive delay in processing a license/registration request has shifted many new practitioners to avoid the District in favor of Maryland or Virginia where processing times are less than 3 weeks.

With the closure of Georgetown University School of Dentistry in 1991, there is a decreased number of dentists, dental assistants and dental hygienists in our city. When we factor in the burdens faced by those who want to practice in the District (delay in getting the license/ registration combined with a high cost), there is a severe shortage of qualified employees.

The “pathways to the middle class” that we so often hear the Mayor and City Council members speak about used to consist of a job in a dental office that would come with “on the job training” that would move employees into more specialized and more skilled work resulting in higher pay and job security. Our current dental assisting licensing regulations prohibit such entry positions and effectively shift these jobs out of the District.

As small business owners, dentists cannot spare an employee for periods of 8 or even 11 weeks under this proposal. The office would not function without a key employee for this period of time and there are no short-term staffing solutions available given the circumstances described previously.

The main objections the DCDS has with the proposal are:

  • The payroll tax will result in decreased benefits to employees or increased fees charged to patients. Medicaid and insurance providers will not reimburse for these costs.
  • The payroll tax should not be solely paid by the employer. If it is a benefit each worker is entitled to receive, then the cost associated with it should also be paid by the employee/ beneficiary. This could be modeled as with FICA withholding with both employee and employers participating in paying for the benefit.
  • All wages should not be subject to taxation in order to fund the new benefit.  Paid family leave law in other states caps the amount of total wages that are subject to taxation to fund the benefit program.
  • The majority of the beneficiaries of this program are not DC residents.
  • The District has not figured out how to pay for a new bureaucracy to administer and oversee the program.
  • There should be a waiting period of at least a year before a new employee is eligible to leave on the program and should apply to full-time workers (more than 32 hours a week).
  • Most dental practices already provide generous vacation and sick leave benefits to their employees. This legislation does not take into consideration the existence of these benefits.
  • There is no restriction allowing an individual from receiving paid family or paid parental leave from the program while they are employed or earning wages from another employer

We ask the Council to refrain from passing the legislation in its current form until the answers to these issues can be decided without the rush to act as the end of this legislative session approaches.  The Council should respect the business owners who have chosen to invest in our city a thoughtful analysis based on financial facts rather than emotions.

We welcome the opportunity to discuss our views with you and other members of the City Council.

Sincerely,

Untitled  

Dr. Thomas Sokoly

President

District of Columbia Dental Society

View the official DCDS letter to the DC Council
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