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

Matter Number:

P165403

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

Matter Number:

V160008

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...

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

Matter Number:

V160009

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...

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

Matter Number:

V160007

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”...

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

Matter Number:

V160006

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...

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)

Matter Number:

V160005

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...

FTC Staff Comment to Georgia State Senator Valencia Seay Concerning Georgia House Bill 684

Matter Number:

V160004

FTC staff submitted a comment, in response to a request from Georgia State Senator Valencia Seay, regarding proposed legislation that would broaden the types of settings under which Georgia dental hygienists are allowed to provide preventive care without direct on-site supervision by a dentist,...

Joint Statement of the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice on Certificate-of-Need Laws and South Carolina House Bill 3250

Matter Number:

V160003

The FTC and DOJ Antitrust Division jointly submitted a statement, in response to a request by South Carolina Governor Nikki Haley, regarding the competitive implications of CON laws and a legislative proposal that ultimately would repeal South Carolina’s CON laws. The statement explained that the...

FTC Staff Reply Comment Before the State of New York Public Service Commission in the Reforming the Energy Vision Proceeding, Concerning the NY PSC Staff White Paper on Ratemaking and Utility Business Models

Matter Number:

V140012

Docket Number:

14-M-0101

FTC staff submitted a comment in the New York State Public Service Commission’s (NY PSC’s) Reforming the Energy Vision (REV) proceeding regarding that agency’s “Staff White Paper on Ratemaking and Utility Business Models.” The comment suggests that the White Paper, which describes the REV’s...

FTC Staff Comment to South Carolina Representative Jenny A. Horne regarding House Bill 3508 and 3078 on Advanced Practice Registered Nurse Regulations

Matter Number:

V160000

FTC staff submitted a comment, in response to a request from South Carolina State Representative Jenny A. Horne, on the competitive impact of legislative proposals to modify the supervision requirements imposed on South Carolina APRNs. One bill would impose additional supervision requirements,...

FTC Staff Comment Submitted to the Food and Drug Administration, In Response to FDA's Request For Comments on Its Guidance for Industry on the “Nonproprietary Naming of Biological Products; Draft Guidance for Industry; Availability”

Matter Number:

P131208

Docket Number:

FDA-2013-D-1543 [80 Fed. Reg. 52296 (Aug. 28, 2015)]

FTC staff submitted a comment to the FDA, in response to the FDA’s request for comment on its draft guidance addressing nonproprietary names for biological products. The comment expressed concern that the FDA draft guidance might hinder competition, and recommended that the agency consider...

Joint Statement of the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice to the Virginia Certificate of Public Need Work Group

Matter Number:

V150011

The FTC and DOJ Antitrust Division jointly submitted a statement, in response to a request by Virginia State Delegate Kathy Byron, suggesting that Virginia consider whether its COPN program best serves the needs of its citizens. The statement explained that the agencies historically have urged...

FTC Staff Comment Before the Pennsylvania House of Representatives Regarding Proposed Legislation to Regulate Pre-Need Cemetery and Funeral Merchandise Sales

Matter Number:

V150014

FTC staff submitted a comment, in response to a request from Pennsylvania State Representative Robert W. Godshall, on legislative proposals that would further regulate the pre-need sale of cemetery and funeral merchandise and services in Pennsylvania. “The bills, if enacted, appear to impose...

FTC Staff Comment to the Tennessee Department of Health Regarding the Implementation of Laws Relative to Cooperative Agreements and the Granting of Certificates of Public Advantage

Matter Number:

V150013

Docket Number:

Proposed Chapter 1200-38-01 of the Hospital Cooperation Act of 1993

FTC staff submitted comments to the Virginia and Tennessee health departments, in response to calls for public comments, as part of those agencies’ respective processes to promulgate proposed rules regarding hospital cooperation agreements in their states. FTC staff offered assistance to each of...

FTC Staff Comment to the Virginia Department of Health Regarding Virginia's Rules and Regulations Governing Cooperative Agreements

Matter Number:

V150012

Docket Number:

12 Virginia Administrative Code 5, Chapter 221

FTC staff submitted comments to the Virginia and Tennessee health departments, in response to calls for public comments, as part of those agencies’ respective processes to promulgate proposed rules regarding hospital cooperation agreements in their states. FTC staff offered assistance to each of...

FTC Staff Reply Comment Before the State of New York Public Service Commission in the Reforming the Energy Vision Proceeding, Responding To Third-Party Comments on the NY PSC Benefit-Cost Analysis

Matter Number:

V140012

Docket Number:

Case 14-M-0101

The FTC staff submitted a reply comment to the New York State Public Service Commission (NY PSC) regarding that agency’s Reforming the Energy Vision (REV) proceeding. The FTC staff comment recommended that the principles set forth in the NY PSC Staff White Paper on Benefit-Cost Analysis (Staff BCA...

FTC Staff Comment Before the Food and Drug Administration Regarding the Current Use of Human Drug and Biological Products Labeled As Homeopathic, and the FDA's Regulatory Framework For Such Products

Matter Number:

P114505

Docket Number:

80 Fed. Reg. 16327 (Mar. 27, 2015)

FTC staff has recommended that the U.S. Food and Drug Administration (FDA) reconsider the framework it uses to regulate homeopathic medications because it may appear to conflict with the FTC’s advertising substantiation doctrine in ways that could harm consumers and cause confusion for advertisers...

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