|July 12, 1999
Dear Ms. Kelley,
Thank you for this opportunity to address several issues concerning the Funeral Rule, amendments and additions to the Rule. I would like to offer the following comments:
1. Is there a continuing need for the Funeral Rule? Yes. The Rule has been good for the public and the Funeral Professional. It has given the public the opportunity to understand a complicated business and at the same time removes some of the mystic that surrounds the funeral industry. The Rule has given the funeral professional the opportunity to see his or her operation as a business entity and to better see the costs that are involved in operating a business.
2. The Rule sometimes conflicts with state laws as related to cemeteries, monument dealers and casket sellers. This gives reason to expand the definition of "Funeral Provider" to include the non-traditional members of the funeral industry within the scope of the Rule's coverage. These non-traditional providers should be required to have price lists and disclosure statements, as well as standards for operating.
3. Requiring the price of private viewing without embalming may or may not be needed however could easily be added.
4. Requiring the price of donating a body to a medical school should not be on the General Price List. This Fee would be the same as a "transfer fee".
5. The price of renting a casket in connection with a cremation could be included on the General Price List, however the cost of the cremation process should not. Other industries are not required to disclose their cost for items. For example, the Automobile industry is not required to disclose their cost for tires and other accessories.
Ernest C. Adams, Jr.