In America, eight states have passed laws prohibiting some or all surrogacy arrangements. Courts in some states have refused to enforce such contracts, while ten states have passed laws authorizing surrogacy. Some of the disputes involve disagreements over the rights of the surrogate mother, the Wall Street Journal explained. Other cases concern the health of the child, inheritance issues, and termination of pregnancy. In addition, several hospitals have filed lawsuits seeking to avoid responsibility for any injury caused by assisted reproductive technology (ART). In California, licensed physicians can enter into agreements with married couples to be paid for providing embryos that will be used to create children through in vitro fertilization (IVF). The parents must give their consent for this procedure; they cannot use or sell the embryos. Physicians who perform more than two such transactions within a year are required to receive training about human reproduction and inheritability of traits. In Colorado, contracts for surrogacy services must include warnings about genetic defects and disabilities being passed on from parent to child and cannot contain fees until after the birth of the child. Surrogates can revoke their consent at any time before the embryo is transferred into the woman's uterus. If this happens, the surrogacy contract is considered voidable rather than void and no penalty applies. In Hawaii, individuals can hire someone to act as a gestational carrier for them if they cannot afford in vitro fertilization (IVF).