 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.