ehr onc final certification - Department of Health Care Services

of the more sophisticated EHR Modules would only be prepared to be tested and certified
to 1 or 2 of the more complicated certification criteria or would be prepared to be tested
and certified to multiple certification criteria.
Table 3. Estimated One-Time Costs to EHR Module Developers to Prepare EHR Modules to be
Tested and Certified (3 year period) – Totals Rounded
One Time Cost Per EHR
Type
Module ($M)
Number
Prepared Low High
Page 200 of 228
Total Cost All EHR Modules over 3year
Period ($M)
Midpoint
Low High Mid-point
EHR
Modules 50 $0.1 $0.5 $0.3 $5.0 $25.0 $15.0
Total 50 $5.0 $25.0 $15.0
In total, if we were to distribute the costs to prepare Complete EHRs and EHR
Modules between 2010 and 2012 evenly per year, we believe they would likely be in the
range of $67.35 to $205.3 million or $22.45 to $68.43 million per year with an annual
cost mid-point of approximately $45.44 million. However, we do not believe that the
costs will be spread evenly over these three years due to market pressures and the fact
that higher upfront incentive payments are available under the Medicare and Medicaid
EHR Incentive Programs. We assume this factor will motivate a greater ratio of
commercial vendors and open source developers of Complete EHRs and EHR Modules
to prepare such technology for testing and certification in 2010 and 2011 rather than
2012. As a result, we believe as represented in Table 4 that the costs attributable to this
final rule will be distributed as follows: 45% for 2010, 40% for 2011 and 15% for 2012.
Table 6. Distributed Total Preparation Costs for Complete EHR and EHR Module
Developers (3 year period) – Totals Rounded
Year Ratio
Total Low
Cost Estimate
($M)
Total High
Cost Estimate
($M)
Total Average
Cost Estimate
($M)
2010 45% $30.31 $92.39 $61.35
2011 40% $26.94 $82.12 $54.53