Prompted by the Cullen case, Pennsylvania, New Jersey, and 35 other states adopted new laws which encourage employers to give honest appraisals of workers' job performance and which give employers legal protections when they provide a truthful employee appraisal. The New Jersey laws in particular formed the model that the rest of the states would follow. First, the 2004 Patient Safety Act increased hospitals' responsibility for reporting "serious preventable adverse events". The 2005 Enhancement Act was a supplement to the Patient Safety Act, and required hospitals to report certain details about their employees to the New Jersey Division of Consumer Affairs. It also mandated that complaints and disciplinary records relating to patient care be kept for at least seven years.