to public hospitals for further care and treatment. In 1987 33 complaints of patient dumping were made to the US Department of Health and Human Services, and the following year 1988, 185 complaints were made. Since private hospitals ceased publishing their mortality rates, analysts pointed to high costs of dealing with Medicaid's reimbursements and uninsured patients as the motivation. This refusal of care resulted in patient deaths and public outcry culminating with the passage of a federal anti-patient dumping law in 1986 known as the Emergency Medical Treatment and Active Labor Act (EMTALA). In 1985 the Consolidated Omnibus Budget Reconciliation Act (COBRA) was passed which was meant to regulate how patients were transferred and also end patient dumping. COBRA was not a complete solution, and in the years after its passage hospitals struggled with creating appropriate discharge protocols and the cost of providing health care for homeless patients. Statistically, Texas and Illinois had the highest rates of patient dumping because of economic difficulties. Researchers have reported that the language in COBRA was not precise enough to significantly disincentivise healthcare providers to discontinue patient dumping practices. For example, in the 1980s Texas state law had a loop hole that allowed hospitals to transfer patients to nursing homes. Early 21st century policy Homeless dumping continued to be an issue in the United States into the 21st century. University of California Los Angeles professor Abel (2011) claimed that these policy interventions have not been effective because the United States' health care system is too heavily influenced by the patients ability to pay. In the early 21st century, illegal immigrants were reportedly subject to patient dumping by being deported or repatriated. Research articles also describe dumping of homeless individuals or mentally ill individuals by police as another form of inappropriately shifting people from one area of a city to another instead of taking them to adequate care facilities like shelters. In September 2014, the U.S. Commission on Civil Rights issued a report entitled "Patient Dumping". Statistics A report published in 2001 by Public Citizen's Health Research Group stated that there were widespread violations of EMTALA throughout the United States in 527 hospitals. Between 2005 and 2014 another study reported 43% of the US hospitals studied had been under EMTALA investigation which resulted citations for 27% of the hospitals. The other findings of this study were that the number of EMTALA violations have been decreasing