Advocacy Filings

When government bodies and other organizations consider cases or policy decisions that affect consumers or competition, the FTC may offer insight and expertise to decision makers by filing an advocacy letter. To find a specific filing, use the filters on this page.

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FTC Staff Comment To the Delaware Board of Speech/Language Pathologists, Audiologists and Hearing Aid Dispensers Regarding Its Proposed Revisions To Its Telecommunication and Telehealth Regulations

Matter Number:

V170001

FTC staff submitted a comment to the Delaware Board of Speech/Language Pathologists, Audiologists and Hearing Aid Dispensers on its proposed regulation that would allow telepractice in those fields but require an initial in-person evaluation. Staff stated that allowing telepractice could enhance consumer choice by providing an alternative to in-person care, potentially reducing travel expenditures and increasing both access to care and competition. However, because the proposed regulation requires that all initial evaluations be conducted in person, it may unnecessarily discourage the use of telepractice and limit its potential benefits.

FTC/DOJ Joint Comment to the Federal Energy Regulatory Commission (FERC) Regarding Modifications to FERC Requirements for Review of Certain Transactions and Market-Based Rate Applications

Matter Number:

V170000

Docket Number:

RM16-21-000

The FTC and DOJ submitted a comment to FERC regarding market power in wholesale electricity markets. The comment responds to a FERC request for comments on how it assesses market power with respect to mergers and electricity sales at market-based rates, which it evaluates under the Federal Power Act (FPA). The agencies encouraged FERC not to rely solely on structural indicators of market power, such as market share or concentration, when assessing market power under FPA sections 203 and 205.

Comment of Jessica L. Rich, Director, Bureau of Consumer Protection, to the National Highway Traffic Safety Administration Supporting the Inclusion of Consumer Privacy and Cybersecurity Guidance in the Document “Federal Automated Vehicles Policy”

Matter Number:

P135405

Docket Number:

NHTSA-2016-0090

BCP Director Jessica L. Rich submitted a comment to NHTSA regarding its request for comments on proposed industry guidance for highly automated vehicles. Rich commends NHTSA for its “thoughtful consideration of the emerging issues presented by innovative technologies in vehicles, and the agency’s strong commitment to protect consumer privacy and vehicle cybersecurity in the HAV area.” Rich also commends NHTSA for “includ[ing] recommendations designed to ensure that privacy and security issues are considered throughout the vehicle lifecycle, particularly in the design phase.”

FTC Staff Submission to the Tennessee Department of Health Regarding the Certificate of Public Advantage Application of Mountain States Health Alliance and Wellmont Health System

Matter Number:

151 0115

FTC staff submitted a comment to the Tennessee Department of Health that opposes issuing a certificate of public advantage (COPA) to Mountain States Health Alliance and Wellmont Health System. If approved, the COPA could allow the merger of Mountain States and Wellmont, the two largest healthcare systems in northeast Tennessee and southwest Virginia, to proceed with regulatory oversight from the State of Tennessee. Staff expressed concern that the proposed merger of Mountain States and Wellmont would lead to significantly less competition for healthcare services in those areas.

FTC Staff Submission to the Southwest Virginia Health Authority and Virginia Department of Health Regarding Cooperative Agreement Application of Mountain States Health Alliance and Wellmont Health System

Matter Number:

151 0115

FTC staff submitted a comment to the Southwest Virginia Health Authority and the Virginia Department of Health opposing the cooperative agreement application submitted by Mountain States Health Alliance and Wellmont Health System. “The proposed merger presents substantial risk of serious competitive and consumer harm in the form of higher healthcare costs, lower quality, reduced innovation, and reduced access to care,” the written comment states.

FTC Staff Comment to the Delaware Board of Dietetics/Nutrition Regarding Its Proposed Telehealth Regulation

Matter Number:

V160015

FTC staff submitted a comment to the Delaware Board of Dietetics/Nutrition regarding its proposed telehealth regulation that would require in-person initial evaluations of patients, and then allow licensed dietitians and nutritionists to determine whether to use telehealth thereafter. Staff stated that the proposed regulation could promote the use of telehealth, potentially enhancing competition in the provision of nutrition services, as well as reducing patient travel costs.

FTC Staff Comment Before the Delaware Board of Occupational Therapy Concerning its Proposed Telehealth Regulation

Matter Number:

V160014

FTC staff submitted a comment to the Delaware Board of Occupational Therapy Practice on its proposed regulation that would likely facilitate the provision of occupational therapy services to Delaware consumers. The proposed regulation would allow licensed occupational therapists (OT) to determine whether telehealth is an appropriate level of care for a patient, and allow OTs to determine the level of supervision required for the provision of telehealth services by OTAs. Staff stated that by not imposing rigid and unwarranted in-person care and supervision requirements, the proposed telehealth regulation would likely benefit Delaware consumers.

FTC Staff Comment to the Department of Veterans Affairs: Proposed Rule Regarding Advanced Practice Registered Nurses

Matter Number:

V160013

Docket Number:

RIN 2900–AP44

FTC staff submitted a comment to the U.S. Department of Veterans Affairs regarding a proposed rule that would permit the VA to grant “full practice authority” to the four main categories of Advanced Practice Registered Nurses (APRNs), “regardless of State or local law restrictions.” Staff stated that removing the remaining state law based supervision restrictions for APRNs working within the Veterans Health Administration system could benefit VA patients nationwide “by improving access to care, containing costs, and expanding innovation in health care delivery.”

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