NRPM: Standards for Privacy of Individually Identifiable Health Information. Footnotes

11/03/1999

1 We have used two different data sources for our estimates of the number of entities. In the regulatory impact analysis (RIA), we chose to use the same numbers as we used in other Administrative Simplification rules. In the regulatory flexibility analysis (RFA), we used the most recent data available from the Small Business Administration (SBA).

We chose to use the Administrative Simplification estimates in the RIA because we wanted our analysis to be as consistent as possible with those regulations and also believe that because it is higher than the more recent SBA data, it was the more conservative data source.

We chose to use the SBA data in the RFA because we wanted our analysis to be as consistent to SBA definitions as possible to give the greatest accuracy for the RFA purposes.

2 Establishments are the physical location where an enterprise conducts business. An enterprise may conduct business in more than one establishment.

3 Office of Advocacy, U.S. Small Business Administration, from data provided by the Bureau of the Census, Statistics of U.S. Businesses, 1996.

4 Op.cit, 1996

5 Office of Advocacy, U.S. Small Business Administration, from data provided by the Bureau of the Census, Statistics of U.S. Businesses, 1996.

6 Op.cit., 1996

7 Health Care Finance Administration, OSCAR

8 Faulkner & Gray’s Health Data Directory, 1999

9 International Billing Association, 1999

10 We are not suggesting that these investments are exclusively computer-related. They may also include costs for personnel training, reorganization, and contract negotiations with outside entities.

11 Health Care Finance Administration, 1996, http://www.hcfa.gov/stats/nhe- oact/tables/t10.htm

12 Office of Advocacy, U.S. Small Business Administration, from data provided by the Bureau of the Census, Statistics of U.S. Businesses, 1996.