SCORM-conformant courseware content is difficult to measure in terms of complexity and development time; however, most people would agree that there are certain qualities (like level of interactivity) that make some web-based content more difficult to develop than other content. COSCOMO is an algorithm to assist both the government and developers in estimating all of the decision points taken by an instructional designer and later the software developer when designing and developing SCORM-conformant courseware content. Quantifying this in a comparative numerical measure makes development and test cost estimates more meaningful and accurate; thereby, reducing risk to SCORM-conformant courseware projects.