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1 Dennis Murphy, Funeral Rule Impact Evaluation Studies 1 (1982)

handle is hein.usfed/frimpev0001 and id is 1 raw text is: To: Commission From: Dennis A., , Bureau of Economics Subject: Funeral Rule Impact Evaluation Studies Date: July 16, 1982 In its Commission memo of July 15, 1982, the-funeral rule staff recommends that the results of the funeral rule impact evaluation and telephone follow-up studies be placed on the public record section of the rulemaking record. Bowever, staff argues that the results of the studies are consistent with other record evidence and that the Commission therefore can choose not to rely on the studies in deciding whether to issue a rule. This course would obviate the need to reopen the rulemaking record to allow public comments on the impact evaluation data. The Bureau of Economics has analyzed the results of the two studies and has consulted with Prof. Gary Ford, Chairman of the Marketing Department of the University of Maryland, and Prof. J. Paul Peter of the Marketing Department of the University of Wisconsin. Prof. Ford has broad experience in designing and evaluating surveys that use members of the Market Facts mail panel as respondents. Prof. Peter was selected by BCP staff to evaluate the consistency of responses to the original baseline mail survey and the follow-up telephone survey. Based on our own analysis and discussions with Professors Ford and Peter, we have concluded that the baseline study does contradict rulemaking evidence concerning the frequency of refusals by funeral homes to provide telephone information over the phone. Further, we believe the baseline results are substantially more reliable than existing record evidence. We therefore recommend that the Commission reopen the rulemaking record and rely on this new evidence in determining whether to issue the telephone disclosure provisions of the proposed funeral rule. The impact evaluation baseline study provides a rich source of information on a broad range of issues relating to the selection and purchase of funerals. A sample of 1200 members of the Market Facts mail panel who had recently participated in arranging a funeral responded to questions dealing with the type 1

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