ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
ehr onc final certification - Department of Health Care Services
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The RFA requires agencies to analyze options for regulatory relief <strong>of</strong> small<br />
businesses if a rule has a significant impact on a substantial number <strong>of</strong> small entities.<br />
While Complete EHRs and EHR Module developers represent a small segment <strong>of</strong><br />
the overall information technology industry, we believe that the entities impacted by this<br />
<strong>final</strong> rule most likely fall under the North American Industry Classification System<br />
(NAICS) code 541511 “Custom Computer Programming <strong>Services</strong>” specified at 13 CFR<br />
121.201 where the SBA publishes “Small Business Size Standards by NAICS Industry.”<br />
The size standard associated with this NAICS code is set at $25 million in annual<br />
receipts 17 which “indicates the maximum allowed for a c<strong>onc</strong>ern and its affiliates to be<br />
considered small entities.”<br />
Based on our analysis, we believe that there is enough data generally available to<br />
establish that between 75% and 90% <strong>of</strong> entities that are categorized under the NAICS<br />
code 541511 are under the SBA size standard, but note that the available data does not<br />
show how many <strong>of</strong> these entities will develop a Complete EHR or EHR Module. We<br />
also note that with the exception <strong>of</strong> aggregate business information available through the<br />
U.S. Census Bureau and the SBA related to NAICS code 541511, it appears that many<br />
Complete EHR and EHR Module developers are privately held or owned and do not<br />
regularly, if at all, make their specific annual receipts publicly available. As a result, it is<br />
difficult to locate empirical data related to many <strong>of</strong> the Complete EHR and EHR Module<br />
developers to correlate to the SBA size standard.<br />
17 The SBA references that annual receipts means “total income” (or in the case <strong>of</strong> a sole proprietorship,<br />
“gross income”) plus “cost <strong>of</strong> goods sold” as these terms are defined and reported on Internal Revenue<br />
Service tax return forms.<br />
http://www.sba.gov/idc/groups/public/documents/sba_homepage/guide_to_size_standards.pdf<br />
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