ehr onc final certification - Department of Health Care Services

Step 1 ($59.30/hr plus 21.35/hr for benefits) given the educational and professional
experience we believe would be necessary to lead this type of activity. Multiplying the
total hourly rate by the 2500 hours yields a total preparation cost of approximately
$201,000. Thus, even if we were to assume that a high average for preparation of a
Complete EHR or EHR Module would be double what the commenter stated, it would
only represent close to $400,000 in preparation costs. Accordingly, we believe that our
estimates are in fact comparatively high and the estimate range covers a wide range of
possibilities.
In the absence of additional data or any evidence to the contrary from public
comment to guide revisions to our estimates, we are finalizing them according to the data
and assumptions we identified in the Interim Final Rule. We believe that our estimates
are sound, based on reasonable assumptions and data, and sufficiently accommodate
varying costs for different types of Complete EHR and EHR Module developers. We
believe that the additional clarity and specificity we have provided for some certification
criteria and the removal of some required capabilities would further contribute to
lowering the cost estimates for complying with this final rule. Consequently, we
anticipate actual costs will fall somewhere between the low and mid-point ranges of our
estimates rather than between the mid-point and high ranges of our estimates.
Finally, with respect to the commenter who expressed concern regarding the total
costs associated with developing a Complete EHR which had never been certified, we
note that our estimates should not be construed to imply that a Complete EHR developer
would have to spend over $1 million in order to prepare a Complete EHR. To the
contrary, had we calculated our low range for preparing a Complete EHR based on the
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