We have successfully represented several hospitals in making self-reports of potential violations of the Emergency Medical Treatment and Labor Act (EMTALA). After consideration of the self-reports, the Centers for Medicare & Medicaid (CMS) often declines to pursue further action. We have also successfully argued against imposition of civil money penalties (CMPs) where CMS refers an EMTALA incident to a Quality Improvement Organization (QIO) for the potential imposition of CMPs by the Office of Inspector General (OIG).