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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Joint Comment of the Federal Trade Commission Staff and the Antitrust Division to North Carolina State Senator Bill Cook on North Carolina HB 436 Concerning Online Legal Forms and the Practice of Law

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FTC staff and the U.S. Department of Justice Antitrust Division submitted a joint comment, in response to a request from North Carolina State Senator Bill Cook, on the impact of interactive websites for generating legal forms on competition and consumers.  North Carolina House Bill 436 would exclude from the statutory definition of the practice of law the operation of a website that generates legal documents based on consumer responses to questions presented by interactive software, provided certain conditions are satisfied.  The comments encourage the North Carolina General Assembly to consider the benefits of interactive websites for consumers and competition in evaluating HB 436, and also recognize that such products may raise legitimate consumer protection issues.

Comment Filed by Jessica Rich on Privacy Enforcement Implications of FCC’s Proposed Set-Top Box Rulemaking

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Federal Trade Commission Bureau of Consumer Protection Director Jessica Rich filed a comment today with the Federal Communications Commission regarding the FCC’s proposed rulemaking to expand the commercial availability of television set-top boxes for consumers.

FTC Staff Comment to the Kentucky House of Representatives Regarding House Bill 77, Which Would Recognize and Regulate Denturists

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FTC staff submitted a comment, in response to a request from Kentucky State Representative Tom Burch, on the competitive implications of proposed legislation that would license and regulate denturists within Kentucky. The comment recommended that the legislature consider the potential benefits of enhanced competition among oral health care professionals, such as improved access to care, more cost-effective treatment, and the development of more effective care delivery models that may offer greater choice to health care consumers. The comment encouraged the legislature to “maintain only those scope of practice limitations necessary to ensure patient health and safety.”

FTC Staff Comment to the Alaska State Legislature Regarding Telehealth Provisions In Senate Bill 74, Which Would Allow Licensed Alaska Physicians Located Out-of-State To Provide Telehealth Services

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FTC staff submitted a comment, as public testimony, regarding proposed legislation that would allow licensed Alaska physicians located out-of-state to provide telehealth services in the same manner as in-state physicians. The comment noted that eliminating the in-state requirement appeared to be a procompetitive improvement in the law. The change likely would expand the supply of telehealth providers, promote competition, and increase access to safe and cost-effective care. It could also reduce transportation costs for Alaska patients and providers.

FTC Staff Comment to the West Virginia House of Delegates Regarding SB 597 and the Competitive Implications of Provisions Regarding "Cooperative Agreements" Between -- and Possible Exemptions From the Federal Antitrust Laws For -- Health Care Providers

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FTC staff submitted a comment, in response to a request from West Virginia State Delegate Mike Pushkin, on the competitive impact of provisions in proposed legislation that would provide for “cooperative agreements” between health care providers, and provisions purporting to confer “exemptions” from federal antitrust laws on certain health care providers. According to the comment, the bill incorrectly assumed that the antitrust laws prohibit efficient health care mergers, acquisitions, and collaborations. Given that federal and state antitrust laws already permit cooperative agreements that are likely to benefit consumers, the purported antitrust exemption would have no procompetitive application. FTC staff expressed concern “that this legislation is likely to foster mergers and conduct that are anticompetitive, inconsistent with federal antitrust law and policy, and liable to cause serious harm to West Virginia health care consumers.”

FTC and USDOJ Joint Comment to the Massachusetts House of Representatives Regarding House Bill 1973 to Allow Non-Surgical Treatment of Glaucoma by Optometrists

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The FTC and DOJ Antitrust Division jointly submitted a statement, in response to a request by Massachusetts State Representative Bradley H. Jones, encouraging the Massachusetts legislature to consider expanding the services that optometrists can provide to glaucoma patients, subject to certain training and referral requirements, consistent with practice in other states. The statement described the potential benefits to patients of enhanced competition among glaucoma care providers, including greater access to timely and cost-competitive care, noting that unnecessarily broad scope of practice restrictions “can impose significant competitive costs on health care consumers and other payors.” The statement recommended that the legislature restrict optometrists’ ability to treat glaucoma only to the extent necessary to ensure patient health and safety.

FTC Staff Comment to the Senate of West Virginia Concerning the Competitive Impact of WV Senate Bill 516 on the Regulation of Certain Advanced Practice Registered Nurses (APRNs)

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FTC staff submitted a comment, in response to a request from West Virginia State Senator Kent Leonhardt, on the competitive impact of a legislative proposal to modify the supervision requirements imposed on West Virginia APRNs. The bill would permit some APRNs, under limited conditions, to write prescriptions without a formal agreement with a particular supervising physician. The bill would also place the regulation of certain APRNs under the authority of the West Virginia Board of Medicine or Board of Osteopathy. Although the comment noted potential patient benefits if APRNs were able to engage in some independent prescribing, the comment emphasized that undue regulatory restrictions on APRN practice, including mandatory physician oversight, can impose significant competitive costs on patients and third-party payors, and may frustrate the development of innovative and effective models of team-based health care. The comment also noted that because the bill “would assign regulatory authority over APRN prescribing to the Boards of Medicine and Osteopathy, it raises concerns about potential biases and conflicts of interest.” The comment urged the legislature to consider whether these proposed requirements are necessary to assure patient safety, noting that removing unnecessary and burdensome requirements may benefit West Virginia consumers by increasing competition among health care providers.