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.”

FTC Staff Comment to the Federal Communications Commission: Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991: Proposed FCC Rule Amendments To Limit Robocalls To Consumers

Matter Number:

P064803

Docket Number:

CG Docket No. 02-278

FTC staff submitted a comment to the FCC regarding proposed amendments to the FCC regulations that limit robocalls to consumers. The proposed amendments implement a recent change in the law that permits robocalls to collect debt owed to or guaranteed by the federal government without a consumer’s prior express consent. The FTC staff comment urges caution with any expansion of permissible robocalling. In the comment, FTC staff outlines the consumer protection concerns raised by these calls and recommends that the FCC create standards for collecting government debt that are consistent with several related laws enforced by the FTC.

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

Matter Number:

V160012

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.

FTC Staff Comment to the NTIA: The Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things

Matter Number:

P165403

Docket Number:

160331306-6306-01

FTC staff submitted a comment to the NTIA regarding the Internet of Things. The comment addresses a number of proposed best practices for businesses regarding the Internet of Things, providing recommendations regarding data security, data minimization, and how best to give consumers meaningful notice and choice about the collection and use of their data. The comment also addresses the potential impact on consumers and competition from creating standards that allow various Internet of Things devices to interact and work together.

FTC Staff Comment to the Federal Communications Commission: In the Matter of Protecting the Privacy of Customers of Broadband and Other Telecommunications Services

Matter Number:

P165405

Docket Number:

16-106

FTC staff submitted a comment to the FCC regarding its proposed privacy rulemaking for broadband internet access service providers. The comment responds to questions from the FCC and offers suggested changes that address a number of issues in the FCC’s notice of proposed rulemaking, including how personally identifiable information is defined, the structure of privacy notices, the role of consumer notice and choice in various business practices, and the proposed regulations on data security and breach notification.

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