The Funeral Director's Brief

Issue #3 -- March 24, 2026

Weekly regulatory intelligence for New York funeral directors

THIS WEEK'S TOP STORY

The Apprenticeship Bill Is Dead. Here's What Killed S8152 -- and What's Still Alive.

Senate Bill 8152, the four-year apprenticeship alternative to mortuary school, has been stricken. The enacting clause was removed on June 9, 2025, and the bill was recommitted. It is off the active calendar.

This means S8152 will not receive a committee hearing, will not go to a vote, and cannot become law in its current form.

What happened:

The bill lost momentum before it could gain a committee hearing. Senator Leroy Comrie (D-Queens), the sponsor, did not advance it through the Health Committee. No public hearing was ever scheduled. The "enacting clause stricken" designation means the legislature formally withdrew the bill's operative language.

Why this matters for your funeral home:

If you were counting on the apprenticeship pathway to help with hiring -- especially in rural areas where mortuary school is not nearby -- that route is on hold. The current education requirements remain in place. If you are training someone informally now, they still need to complete an accredited mortuary science program to get licensed.

But the idea is not dead:

The Assembly companion bill, A5172 (sponsored by Marianne Buttenschon), is still in the Assembly Health Committee as of this week. It was referred there on January 7, 2026. If the apprenticeship concept is going to survive, it will be through A5172.

What to do:

1. If you support the apprenticeship pathway, contact your Assembly member and ask them to support A5172. The Senate version failed partly because it had no organized support behind it. 2. If you have staff who would benefit from the apprenticeship route, keep them on your radar. This concept is likely to return. 3. Watch this space. We will report if A5172 gets a hearing or gains co-sponsors.


BILL TRACKER

Where All Six Tracked Bills Stand This Week

BillTitleStatusCommitteeLast Action
S9112Licensed Funeral Arranger ActIn Senate CommitteeHealthReferred to Health (Feb 3)
A10095Licensed Funeral Arranger (Assembly)In Assembly CommitteeHealthReferred to Health (Jan 30)
S81524-Year ApprenticeshipSTRICKEN--Enacting clause stricken (Jun 9)
A51724-Year Apprenticeship (Assembly)In Assembly CommitteeHealthReferred to Health (Jan 7)
A7630Residency OverhaulIn Assembly CommitteeHealthReferred to Health (Jan 7)
S7690Residency Overhaul (Senate)In Senate CommitteeFinanceReported and committed to Finance (Feb 24)
Notable movement: S7690 (Residency Overhaul, Senate version) has moved from the Health Committee to the Finance Committee. This means it cleared the Health Committee review and is now being evaluated for fiscal impact. That is forward progress. Senator Michael Gianaris (D-Queens) is the sponsor. S9112/A10095 (Licensed Arranger): No movement. Still in committee with no hearing scheduled. NYSFDA remains opposed.

FEDERAL WATCH

FTC Opens Funeral Rule Comment Window. Deadline May 31.

The Federal Trade Commission published a Paperwork Reduction Act notice in the Federal Register on January 26, 2026 seeking public comment on a three-year extension of the OMB clearance for the Funeral Rule's information collection requirements. Comment deadline: May 31, 2026.

This is not a rule change. The OMB clearance is what authorizes the FTC to require funeral homes to provide itemized price disclosures during compliance review -- General Price Lists, casket price lists, outer burial container price lists, and the statement of funeral goods and services. If the clearance is renewed, those requirements continue unchanged for three more years.

A note on confusing trade-press coverage:

Two other FTC Federal Register items appeared in the same window (a January 23 notice and a February 6 correction). Those concern shared FTC/CFPB enforcement under Regulation O, the mortgage marketing rule -- not the Funeral Rule. The February 6 correction explicitly removed an erroneous Funeral Rule reference from the original. The Funeral Rule remains FTC-enforced, not jointly enforced with CFPB.

What this signals:

When the FTC extends its collection authority, it typically means they plan to use it. Combined with the 2024 Funeral Rule amendments (effective July 2024), the comment window is the formal moment to put concerns about enforcement priorities and compliance burden on the record. NYSFDA and other state associations are the natural channel for a coordinated comment.

What to do:

1. Pull your General Price List right now. Check that every item, every price, and every required disclosure matches current FTC requirements. The July 2024 amendments added new pricing transparency requirements. If your GPL has not been updated since then, fix it this week.
2. Ask NYSFDA whether the association is filing a comment by May 31. Coordinated industry comments carry more weight with OMB than individual submissions.


DOH UPDATE

Inspections Are Going Statewide. What the Bureau Is Looking For.

As we reported in Issue #1, new Bureau Director Stephanie Gilman has staffed up the office and set up remote operations so inspectors can travel the state. This means homes that have not seen an inspector in years should expect a visit.

Based on the November 2025 Comptroller Audit, expect inspectors to focus on:
  • Prep room compliance: Chemical storage, ventilation, PPE, proper labeling
  • Death certificate documentation: Registration and filing procedures
  • Pre-need contract files: Completeness, trust account documentation, consumer disclosures
  • General Price List accuracy: Every item priced, FTC-required disclosures present
  • Three things you can do today:

    1. Walk your prep room. Check chemical labels, OSHA sheets, ventilation. If an inspector walks in tomorrow, would you be comfortable? 2. Pull 5 random pre-need files. Are they complete? Is the trust account properly documented? 3. Compare your posted GPL to your actual pricing. Any discrepancies need to be fixed before an inspector finds them.


    VIDEO THIS WEEK

    Two new videos on The Funeral Director's Brief YouTube channel:

  • [Apprenticeship Bill S8152 Stricken: What NY Funeral Directors Need to Know](https://youtu.be/FYTZ15RkKYQ) -- Full breakdown of what happened and what to watch next
  • [DOH Inspections Going Statewide: What NY Funeral Directors Need to Prepare](https://youtu.be/Bk0Ax6LNIOo) -- What they are looking for and three things to do now
  • Subscribe to [@FuneralDirectorsBrief](https://www.youtube.com/playlist?list=PLYgNaAgjOyf7M3yWoRwV2ZDpIMdqo4yDB) for weekly video updates.


    UPCOMING

  • NYSFDA Convention: August 17-19, 2026, Saratoga Springs. Mark your calendars.
  • A5172 watch: Will the Assembly apprenticeship bill get a committee hearing? We're monitoring.
  • S7690 in Finance: The residency overhaul cleared Health Committee. Finance review is the next hurdle.

  • The Funeral Director's Brief is a weekly regulatory briefing for New York funeral directors. Questions? Reply to this email. Subscribe: [funeraldirectorsbrief.com](https://funeraldirectorsbrief.com)

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