21 Code For Federal Regulation Parts 1305, 1311 Page 27

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years. The total cost of both systems was estimated using a seven percent and a three percent
discount rate. Table 5 presents the ten-year total cost of orders under the Form 222 system, the
electronic system, and the combined systems as the electronic system is phased in over the first
five years as well as the annualized cost of the three systems over ten years. Table 6 presents the
costs of digital certificates and software needed to create digitally signed orders.
Table 5: Total Cost of Orders Over Ten Years (Present Value)
Paper System
Electronic System
Combined Phase-In
Total (7%)
$2,699,913,000
$298,086,000
$704,112,000
$384,407,000
$42,441,000
$100,250,000
Annualized (7%)
Total (3%)
$3,223,440,000
$363,653,000
$781,438,000
Annualized (3%)
$377,886,000
$42,631,000
$91,608,000
Table 6: Total Costs of Digital Certificates and Software Over 10 Years
(Present Value)
New Costs
Total (7%)
$149,308,000
Annualized (7%)
$21,258,000
Total (3%)
$172,093,000
Annualized (3%)
$20,275,000
In addition to the cost savings, electronic orders will also provide a number of other
benefits that cannot be quantified. Purchasers will be able to create and send single unified
controlled substance orders to their suppliers. With Forms 222, purchasers must create the
separate Form 222 for the Schedule I and II controlled substances and complete other orders for
all other controlled substance purchases from a particular supplier. If a purchaser needs more
than 10 Schedule I or II substances, multiple Forms 222 must be completed because the form is
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