In the new era of Zoom meetings, the Federal Trade Commission is holding a “public workshop” on September 7th to get further input on Funeral Rule changes that would require funeral homes to post their price lists on line. The workshop will be televised, and interested parties can watch by using this hyperlink.
Federal Trade Commission
Funeral Rule Revisions: Minority Communities
By Bill Stalter on
Posted in Compliance
The last section of the Funeral Rule notice (Issues 37-40) raises questions whether there are funeral provider practices that disproportionately affect minority communities. Again, we are not quite sure the intent of the FTC when raising these questions. Concerns have been raised that FEMA’s COVID-19 funeral assistance did not benefit the minority communities as much…
Funeral Rule Readability: What Makes for a Good GPL?
By Bill Stalter on
Posted in Compliance, Uncategorized
The next-to-last section of the Funeral Rule notice (Issues 32-36) deals with what the FTC calls Price List Readability. This seemed to us as a very nebulous phrase, and so we searched “Price List Readability” in the context of the Consumer Funeral Alliance, and lo and behold, the CFA has guidelines for what it…
Funeral Rule’s Embalming Disclosure: When Required by State Law
By Bill Stalter on
Posted in Compliance
Issues 28 through 31 of the FTC Funeral Rule notice concern the embalming disclosure. Consumer advocates are pressing to have the Funeral Rule be more specific about when state law does or does not require embalming. For states that require embalming under certain circumstances, consumer advocates want the GPL to reference the state law and…
The Funeral Rule Changes: Alternate Forms of Disposition
By Bill Stalter on
Posted in Compliance
Issues 23 through 27 of the FTC Notice to amend the Funeral Rule raise questions concerning the new alternative forms of disposition: alkaline hydrolysis and natural organic reduction. For the most part, consumer advocates have embraced these new forms of disposition as friendlier on the environment and more economical. However the Issues seem to express…
Funeral Rule Revisions: Reduced Basic Fees
By Bill Stalter on
Posted in Compliance
The intent behind Issue No. 22 of the FTC Notice to revise the Funeral Rule has us a little perplexed. Funeral providers may charge a lower basic services fee for direct cremations and immediate burials. Issue 22 seems to be asking whether funeral providers must disclose when they do not have a lower basic service…
Funeral Rule Revisions: Mark Up on Trade Services
By Bill Stalter on
Posted in Compliance
The FTC’s second area of concern for Funeral Rule revisions is titled Crematory Fees and Additional Costs. For this post, we are going to look at Issues 16 and 17. Funeral consumer advocates are focused on the fact that many funeral homes do not own their own crematory and therefore outsource that service to…
FTC’s 40 Issues: Confirming Delivery of Price Lists to the Online Shopper
By Bill Stalter on
With Issues No. 10 through 15 of the FTC’s Funeral Rule notice, the agency begins inquiries on how to ensure the online shopper has access to all of the funeral home’s price lists before making any selections. Would it be sufficient to require the funeral home’s website to provide links for downloading the GPL (and…
The FTC’s Seven Areas of Concern: Funeral Rule Revisions
By Bill Stalter on
Posted in Compliance, Consumer Advocates
As discussed in our prior post, the FTC’s rulemaking notice for amending the Funeral Rule requests public comment on 40 Issues. Those 40 issues are grouped by the FTC in the following 7 categories of potential amendments:
- Electronic price disclosure – whether and how funeral providers should be required to display or distribute price information
…
FTC’s “Forty Issues” and the Funeral Rule Comment Period: Time to Get Serious
By Bill Stalter on
By a posting made November 1, the Federal Trade Commission gave formal notice of its intent to revise the Funeral Rule and opened a 60 day comment period. The notice is quite lengthy and signals that that the FTC wants major revisions to the Funeral Rule that go well beyond whether to require the posting…