Electronic Health Records (EHR) are touted by proponents within the healthcare industry as a means to both improve quality and reduce cost through a combination of reduced errors and improved communication. The drive to standardize the process for the utilization of electronic healthcare records gained its greatest impetus from the electronic transaction standards of HIPAA, first enacted a decade ago with the Health Insurance Portability and Accountability Act of 1996. Since that time, healthcare reform advocate from both industry and government have pushed for the transition to HER. More recently, a provision of the Medicare Prescription Drug, Improvement and Modernization Act of 2003 (MMA) required the federal government to develop Stark exceptions and Safe Harbors to facilitate the implementation of EHR systems.