NSFDA Member Update Regarding New York State Bill #10095

WHAT THIS BILL DOES

A10095 / S9112 restructures funeral service in New York by creating:

A “Licensed Funeral Arranger” Category

This new licensure category may perform nearly all consumer-facing funeral directors except embalming.

They can:

• • • Conduct at-need arrangements
    • Execute pre-need contracts
    • Provide General Price List disclosures
    • Coordinate removals
    • File death certificates
    • File burial and transit and cremation permit

A “Registered Transporter” Category

This new registration structure will allow for the removal and transportation of human remains.

This creates:

• • • A Separate registration tier inconsistent with other role’s licensure requirements
    • Additional regulatory oversight responsibilities
    • Expanded supervisory requirements
    • A new enforcement layer within the same distressed regulatory system

Together, these changes fragment responsibilities that are currently unified under the Licensed Funeral Director.

WHAT OUR MEMBERS SAID

The Nassau-Suffolk Funeral Directors Association polled funeral directors across Long Island’s Nassau and Suffolk Counties. These members represent New York State Funeral Director’s Association’s Region 9 constituency.

The results of our polling reflect strong and consistent professional concern.

90.4% oppose the bill
91.8 % support NSFDA formally opposing the bill

This reflects broad regional consensus among funeral professionals and firms.

On a scale of 1 to 5 (with 1 representing no concern, and 5 representing extreme concern)

93.2% rate their concern as 4 or 5

Funeral professionals express serious concern, not mild hesitation.

94.5% believe the bill weakens
New York’s funeral licensure framework

Respondents frequently cited concerns about altering New York’s long-standing unified professional accountability model.

Recurring themes in written comments:

Across open-ended responses, members consistently raised concerns about:

• • • Fragmented professional responsibility
    • Two-tiered workforce structure
    • Additional regulatory strain before addressing current oversight shortfalls
    • Marketplace instability
    • Added complexity through transporter registrations

WHY NSFDA OPPOSES THE BILL

The Nassau-Suffolk Funeral Directors Association opposition is documented on input and professional consensus. It is not speculative; it reflects direct feedback from the funeral professionals serving families in our community.

Our opposition is focused on concerns for structure, oversight, and consumer clarity – not emotion.

Regulatory Oversight Gaps Already Exsist

The November 2025 New York State Comptroller audit identified oversight deficiencies in funeral directing regulation, including:

• • • Gaps in verification of death-related documentation
    • Weak compliance assurance for embalming and preparation room
    • Over 2,500 instances of death registration occurring after disposition was held
    • Weakness in monitoring and enforcement of registration
    • Limitations in data coordination and tracking

Expanding licensure categories
and adding a registered transporter role
increases regulatory complexity
before baseline oversight controls are strengthened.

Regulatory stabilization should precede regulatory explansion

Families do not distinguish between license tiers. Under this bill:

• • • A new arranger tier may execute contracts and file death certificates
    • A separate transporter tier handles removals
    • Embalming remains under a separate and isolated credential
    • Supervisory and regulatory authority becomes layered

Together these compound and increase consumer confusion, supervisory and regulatory ambiguity, liability uncertainty, and enforcement complexity.

Funeral service depends on steadfast responsibility.

There is no demonstrated consumer harm which justifies such a sweeping reinvention

• • • No statewide study has shown that New York’s unified funeral director licensure is in jeopardy of failing to meet the needs of consumers
    • No fiscal analysis has demonstrated that split-licensure will benefit or result in cost savings for families
    • No workforce study has illustrated a shortage which is caused by the current unified funeral director license
    • Sweeping structural reform requires the diligence of documented necessity

The needs of the workforce do not match the scope of the bill

The bill is not limited to embalming flexibility. It expands authority over:

• • • Pre-need contracts
    • At-need financial execution
    • Death certificate and permit registration
    • Removal and transportation of decedents

All while adding

• • • New licensure tiers with new and undefined regulations
    • Additional regulatory monitoring
    • Expanded licensure enforcement
    • Increased administrative requirements

GET INVOLVED

NSFDA LEGISLATIVE CONTACT DIRECTORY