reduction in Illinois' Medicare expenditure as evidence of the policy's success. The 1986 Emergency Medical Treatment and Active Labor Act (EMTALA) was meant to regulate Medicare-participating hospitals and ensure that patients received appropriate medical treatment regardless of their ability to pay. Some scholars described how EMTALA provided a means to take legal action against healthcare providers and hospitals that did not comply, and provided examples of cases in Florida, California, and North Carolina. Even though hospitals have had to pay penalties, patient dumping remained an issue throughout the country. Legal scholars Kahntroff and Watson (2009) also reported that the implementation of the policy has been flawed with issues of lack of adherence and confusion on what is compliance. A study that looked at 5,594 hospitals in the United States between 2005 and 2014 reported that the number of EMTALA investigations has decreased through that period which may be an indication that hospitals and physicians are improving their adherence to EMTALA protocols. The decrease in EMTALA investigations might also indicate that patient access to emergency care and treatment is improving. Researchers also interviewed doctors who reported that EMTALA citation fines were a disincentive to violate EMTALA protocols. In 1988 the COBRA Act was meant to be a series of revised regulations which required hospital emergency rooms to treat every patient that walked through the door and doubled the fine for violations. News Editor for the American Journal of Nursing, Brider (1987), reported that public hospital staff in Illinois were under a lot of pressure due to the influx of patients that were being sent to them from other hospitals, and that the incidence of patient transfers or patient dumping increased through a loophole in COBRA. The incentives offered to doctors in terms of payment for their services have an effect with patient care outcomes and can minimize the chance of patient dumping or shifting patients to other providers. A study conducted on doctors at the Fairview Health Services hospital in Minnesota reported that grouping doctors into teams to incentivize collaboration between the doctors to ensure the average of the team provided high quality health care for the patient. But doctors who out performed other doctors on their teams did not like the program because the other doctors who were underperforming did not have the incentive to improve. Some of the doctors interviewed in the study claimed that underperforming doctors would only