 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.Unfortunately, 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.