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1 Impact Evaluation Survey, Funeral TRR 1 (1982)

handle is hein.usfed/ipevsv0001 and id is 1 raw text is: UNITED STATES GOVERNMENT oAn, July 15, 1982 memorandum PLYTo Funeral Rule Staff ATTN OF: SUBJECT: Impact Evaluation Survey, Funeral TRR (Program Code 104) TO: Commission I. Introduction In 1979, the Impact Evaluation staff, together with the staff of the funeral industry project, commenced work on a survey of individuals who had recently arranged funerals. The purpose of the survey was to provide baseline statistics on the current incidence of those funeral practices which would be addressed by a final funeral rule. A similar study was to be conducted after the rule became effective, to determine whether the rule had the predicted impact. The results of this baseline study apppeared to show that certain practices on which the rule tentatively adopted by-the Commission is predicated were not as common as staff's analysis of the rulemaking record had suggested. The discrepancy, if it existed, might have reflected such significant changes in funeral industry practices as to undermine the factual predicate of the proposed rule, or it might have been due to inaccuracies in the rulemaking record itself. Alternatively, however, we felt it possible that the unanticipated responses to the survey might have been attributable to methodological problems which caused respondents to select answers not accurately reflecting their experiences. Certain findings in the baseline study not only varied fromstaff's analysis of the rulemaking record but were substan- tially at variance with data received from the funeral industry itself about prevailing practices. To the extent that significant factual predicates for the funeral rule were con- tradicted by the baseline study, we believed that reopening of the record would have been necessitated. Before recommending such a drastic step, with its obvious attendant implications, we arranged for the Impact Evaluation staff to conduct a validation survey to determine whether the baseline study findings were accurate or simply a manifestation of a deficient methodology. The validation survey consisted of a telephone follow-up to a segment of the sample originally included in the baseline study. Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan

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