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<strong>CMS</strong>-1403-FC<br />

4 minutes per call, labor, and telecommunication costs, at<br />

more than $78 million per year, for a total cost for faxes<br />

and phone calls of $88.8 million per year. 9<br />

Another national drug store chain offered a similar<br />

analysis. They estimated that a prescription refill<br />

request undertaken by telephone takes 1.43 minutes longer<br />

to complete than one initiated by computer-generated<br />

facsimile. Without further modification of the<br />

computer-generated facsimile exception, as of<br />

January 1, 2009 this national drug store chain would have<br />

to replace the more than 123 million computer-generated<br />

facsimile refill requests that are made each year with<br />

phone calls or paper faxes. They estimate that this would<br />

result in 9.2 lost hours of staff time per store per week,<br />

resulting in $88 million in additional costs, based on a<br />

blended payroll rate of pharmacists and staff.<br />

Extrapolating this cost across the entire pharmacy industry<br />

based on this commenter's market share, they estimated an<br />

impending pharmacy industry loss of at least $520 million<br />

unless the computer-generated facsimile exception is<br />

further modified. 10<br />

9 CVS/Caremark Discussion Points on E-Fax Ruling Exceptions, January 3, 2007.<br />

10 December 22, 2007 correspondence from Walgreen’s to <strong>CMS</strong> re: <strong>CMS</strong>-1385-FC, Final Rule with<br />

Comment Period: Amendment of the E-Prescribing Exemption for Computer-Generated Facsimile<br />

Transmissions<br />

1065

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