Response to two proposed new public holidays in Victoria: maintaining the status quo on State public holidays is the best choice for Victorians’ oral health, and private dental practices

Download 17.6 Kb.
Date conversion12.01.2017
Size17.6 Kb.

4 August 2015

Mr. Roger Arwas

Executive Director

Small Business Victoria

Victorian Department of Economic Development, Jobs, Transport and Resources

By email:

Dear Mr. Arwas,

Response to two proposed new public holidays in Victoria: maintaining the status quo on State public holidays is the best choice for Victorians’ oral health, and private dental practices.
The Australian Dental Association Victorian Branch (ADAVB) is the peak professional membership body for Victorian dentists, and we seek to promote the good oral health of all Victorians (See Attachment A). We are concerned that the Regulatory Impact Statement (RIS) on the impacts of additional public holidays in our State underestimated the economic cost to small businesses, such as dental practices, and did not consider the effect on public access to dental care.
Public holidays reduce access to emergency dental care

Due to the high overhead costs of operating on a public holiday, many private dental practices choose to close on these days. Public holidays therefore reduce public access to dental care, even for dental emergencies. To address this issue, ADAVB operates a dental emergency holiday roster program, to coordinate public access to private dental care over holiday periods, such as Easter and Christmas, when the majority of private dental practices are closed.

Even with our coordinated effort, some parts of Victoria, particularly regional areas, were not covered on some days over Christmas and Easter in 2014. It is therefore likely that people living in the underserviced areas would have encountered difficulty in accessing emergency dental care at those times. Our experience demonstrates that creating more public holidays would decrease public access to emergency dental care on those days.
Additional public holidays would increase the economic pressures on dental practices

Dental practices are often small businesses, with tight budgets. They exist in a challenging economic environment, with slim profit margins. A dental practice is essentially a mini operating theatre, which results in high overhead costs, due to employee wages, compliance requirements, and equipment and consumables costs. Around 70% of the average dentist fee is therefore allocated to paying for overheads, leaving a surplus of just 30%. This equation does not take into account the higher costs, and decreased revenue earned on public holidays.

Public holidays result in substantial economic losses for dental practices, this cost may be passed on to patients

Irrespective of whether a dental practice remains open or closes on a public holiday, the resulting financial impact on the practice is substantial. If the practice remains open, a decrease in revenue is expected, due to having a reduced number of patient bookings. The employer must also pay large penalty rates to the staff (250% of base salary on a weekday public holiday). Therefore, employers who operate on a public holiday would need to pass on some of the cost to the patients who receive treatment on that day. This too is likely to reduce access to care for those who are on tight budgets.

If the practice closes on that day, all opportunity to gain revenue is lost, but the need to pay penalty rates is avoided. Nevertheless, permanent employees still need to be paid at their base rate.
We have modeled the minimum cost to private dental practices of a public holiday on the Friday before the AFL Grand Final (Table 1). Regardless of whether a practice remains open or closes, the economic losses to dental practices across Victoria would be large.
Table 1 – Costs to private dental practices of a public holiday on the Friday before the AFL Grand Final*

Minimum cost to employer, including wages and revenue loss1

If dental practice closes

If dental practice remains open (assume a 50% decrease in patient bookings)

Individual small business dental practice



Minimum cost to all Victorian private dental practices (estimate 1400 practices)



*This is a conservative calculation, and the costs to a larger dental practice, with more employees and a higher daily revenue, would be much higher.
The ADAVB believes that a similar impact would be felt across all health services and small businesses, and we therefore suggest that the modelling of economic impact in the RIS has underestimated the cost to employers.
Effect of public holidays on employees’ personal circumstances and staff morale

On public holidays, staff may be asked to work when they don’t want to, or may want to work, but be unable to if their employer closes the dental practice for the day. This particularly impacts casual staff, who would not be paid. Further, employees have a reasonable right of refusal to work, especially parents who have the responsibility of caring for young children when schools and child care centres are closed. This can affect staff morale.

The Friday before the AFL Grand Final is a regular business day for dental practices

At present, there is little risk of increased absenteeism on the Friday prior to the AFL Grand Final, as this day has no special implications for the operation of dental practices. ADAVB anticipates that most dental practice employees would reasonably consider this day to be a normal Friday, not a day on which they should be entitled to a public holiday.

Transfer of a public holiday from Easter Saturday to Easter Sunday would disadvantage employees

If working on Easter Saturday, employees would be sacrificing time with their families, with the expectation that they would be financially compensated for this. It would therefore be unfair to move this public holiday to Easter Sunday.

Insufficient notice of the proposed changes to the public holiday schedule would disadvantage employers

Most businesses will have already developed their budgets for the 2015-16 financial year. Additional public holidays would come at a cost to the employers, which they have not had the opportunity to account for in their budgets. We therefore advocate for a longer period of public consultation on the introduction of these holidays, rather than their hasty introduction, which is likely to amplify the financial and social costs.

ADAVB therefore recommends that the status quo be maintained for the Victorian public holiday schedule, and that no further public holidays be introduced.

Dr Stephen Liew

ADAVB President

1 Modeled on a solo dentist practice, with one dental assistant and one receptionist, and an average daily revenue of $3,000.

The database is protected by copyright © 2016
send message

    Main page