Beyond the EHR and FHIR server that a physician is already paying for, what else would need to be considered?

Existing Wording:

#implementation - While existing EHRs can certainly implement the security labeling service inside their products, this is not the only approach and the labeling service can be implemented as a separate product  that interacts with a standard EHR and applies labels to the outgoing information on-the-fly or on the existing information in a batch mode.