21 Code For Federal Regulation Parts 1305, 1311 Page 24
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67As discussed in the NPRM, DEA developed estimates of the time required for each step
in the process of issuing and processing an order and used weighted wage rates based on the
number of orders registrant groups are estimated to issue. DEA estimates that issuing and
processing a Form 222 order costs purchasers about $26 and suppliers about $13. In contrast,
issuing and processing a digitally signed order will cost about $2.60 for purchasers and $3.00 for
suppliers. (These costs do not include the cost of obtaining a digital certificate or installing
software, most of which are one-time costs.) The costs for a single registrant vary depending on
the number of orders issued and filled. DEA estimates that annual costs for Form 222 orders
range from $26 for a registrant who issues a single order to more than $184,000 for distributors
who both issue and fill orders. The annual costs for electronic orders range from $2.60 to about
$40,000. The initial registrant costs of obtaining a digital certificate range from $156 to about
$600, varying with the number of applicants a registrant has.
Table 1 presents the total annual hours and costs for the Form 222 system for 2004
orders. Tables 2 – 4 present the total annual hours and costs for obtaining digital certificates,
issuing electronic orders, and developing and installing software, if these activities occurred in a
single year.
Table 1: Total Annual Hours and Costs for the Form 222 System (2004 orders)
Hours
Labor
Capital
O&M
Total
Purchaser
Complete and send
1,640,250
$139,323,000
$7,355,000
$146,677,000
order
Requisition order
3,124
$265,000
$23,000
$288,000
Annotate order
328,050
$27,865,000
$27,865,000
File orders
109,350
$3,087,000
$129,700
$2,668,000
$4,472,000
Supplier
Enter order
1,640,250
$58,770,000
$58,770,000
24
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