Over the past decade, electronic transactions have slowly supplanted paper-based systems in many industries. For example, individuals and Wall Street brokerage firms employ electronic trading; federal and state taxpayers increasingly e-file their returns; and attorneys e-file pleadings and federal court documents. However, a physician jotting notes on a paper chart, which will then be stored in a large filing cabinet, remains the norm.

In February, President Barack Obama signed a $787 billion economic stimulus bill, the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-005, 123 Stat. 115 (2009), which contains the Health Information Technology for Economic and Clinical Health Act encouraging health care providers to adopt electronic medical records. With billions of dollars allocated toward the digitalization of health care, the era of electronic medical records has begun in earnest.

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