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Most of industry leaders, including the NFDA, seem resigned to the reality that the Funeral Rule will be amended to require the posting of price lists on funeral home websites in some form or fashion. But the FTC extension of the comment deadline from January 3rd to January 17th indicates the Commission does value input from funeral directors. Consequently, we recommend that funeral directors take the opportunity to address the issues they may still influence by filing comments with the FTC.
One issue that seems to resonate with both funeral directors and the Commission is the need to define when the obligation to provide a price list is triggered. One Commissioner provided comments at the end of the October 20th open hearing to state that the FTC staff agreed that the current Rule does not require the price list production until pricing is raised. Comments from funeral directors about the confusion when disclosure is required should help prompt the FTC to clarify when the GPL must be handed out.
Funeral directors should also offer comments about the need for flexibility in how price lists may be delivered to the on-line shopper. As we previously posted on our blog, funeral homes should be given the option of providing price lists by electronic deliveries other than posting on a website. Funeral homes should expect that they will be required to disclose on their websites the availability of price lists by electronic delivery when requests are made by email or telephone calls. If FTC should take this approach, then funeral homes should expect requirements for when requests must be complied with. If this type of flexibility is important to you, then we recommend you file a comment with the FTC.
With regard to the disclosure of third party charges such as crematory fees and cemetery interment charges, funeral directors need to comment on the burden this would create when forced to update GPLs multiple times during a year.
You may follow this hyperlink to file your comments to the propose Funeral Rule changes.
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