Analysis

ONC's October 28 health-IT rule contains two unreconciled differences in its perpetual savings table: $49,055 in present-value accounting and $84,062 in annualized accounting. These are comparisons of printed numbers, not findings of missing money or misconduct. The table's purpose is to estimate the economic effects of reducing certification work.

Tables R-6 and R-7, pages 230–231 of the final rule, use different accounting horizons. R-6 covers ten years; R-7 uses perpetual accounting. Comparing their totals without preserving that difference would create a false discrepancy.

At 7%, R-6 prints gross present-value savings of $945,304,464 and present-value costs of $1,208,886. Subtracting yields $944,095,578, the same net present-value figure the table prints.

R-7 prints gross present-value savings of $1,545,804,005 and costs of $1,208,886. Subtraction yields $1,544,595,119. The table instead prints net present-value savings of $1,544,546,064, which is $49,055 lower than the result from its displayed components.

R-7 also prints annualized gross savings of $108,206,280 and annualized costs of $172,118. Subtraction yields $108,034,162. Its printed annualized net savings of $108,118,224 is $84,062 higher than that subtraction result.

The analysis does not establish why those components and printed net figures differ. An explanatory adjustment, an error or another accounting treatment cannot be selected from the inspected evidence. The printed figures should be preserved until the discrepancy is explained, rather than silently replaced with the subtraction results.

The agency's narrative reports about $1.55 billion in present-value cost savings and $108.1 million in annualized net savings for the whole rule, in 2024 dollars at 7%, beginning in 2027 and in perpetuity. Those are ONC's reported formulations. They do not measure patient cash savings or the decision-support revision alone.

The separate ONC Decision Support Interventions guide, updated May 5, 2026, explains work behind part of the rollback: maintaining source information and risk-management practices for supplied predictive interventions. Those are compliance activities whose removal ONC treats as developer savings.

The decision-support calculation on page 215 is independently reproducible from its displayed inputs. Multiplying 251 products by 211 or 1,527 annual hours and then by $139 per hour gives $7,361,579 or $53,275,503 in modeled undiscounted annual savings. That multiplication does not reconcile the whole-rule perpetual table.

A published cost-benefit estimate should let a reader follow the arithmetic. These two differences remain questions for the agency, not answers about where any money went.