The final regulation's requirements provide covered entities with considerable flexibility in how to best fulfill the necessary training of their workforce. As a result, the actual practices may vary substantially based on such factors as the number of members of the workforce, the types of operations, worker turnover, and experience of the workforce. Training is estimated to cost $737 million over ten years. The Department estimates that at the time of the effective date, approximately 6.7 million health care workers will have to be trained, and in the subsequent ten years, 7 million more will have to be trained because of worker turnover. The estimate of employee numbers are based on 2000 CPS data regarding the number of health care workers who indicated they worked for a health care institution. To estimate a workforce turnover rate, the Department relied on a study submitted in the public comments which used a turnover rate of ten percent or less, depending on the labor category. To be conservative, the Department assumed ten percent for all categories.
Covered entities will need to provide members of the workforce with varying amounts of training depending on their responsibilities, but on average, the Department estimates that each member of the workforce who is likely to have access to protected health information will require one hour of training in the policies and procedures of the covered entity. The initial training cost estimate is based on teacher training with an average class size of ten. After the initial training, the Department expects some training (for example, new employees in larger institutions) will be done by videotape, video conference, or computer, all of which are likely to be less expensive. Training materials were assumed to cost an average of $2 per worker. The opportunity cost for the training time is based on the average wage for each health care labor category listed in the CPS, plus a 39 percent load for benefits. Wages were increased based on the wage inflation factor utilized for the short-term assumptions (which covers ten years) in the Medicare Trustees' Annual Report for 1999.