Tennessee funeral board authorizes rulemaking to raise licensing fees after two years of deficits

The Board of Funeral Directors and Embalmers voted to authorize its legal staff to begin a rulemaking package to increase licensing and establishment fees, citing consecutive fiscal-year deficits and declining reserves.

Board legal counsel and staff presented financial summaries showing the board had consecutive net deficits and that the fiscal-year 2025 shortfall is projected at about $340,000, which will reduce the board’s reserves from roughly $1.1 million to about $758,900, according to the materials presented. Board members and staff said the increases would fund technology upgrades, ongoing regulatory work and staff retention.

Executive Director Robert Gribble summarized the financial position and the rationale for changes, saying the board’s fees had not increased in more than two decades and that “we have to address it because each board has to be self-sufficient.” Legal counsel explained the proposed rule package would change only numeric fee lines in the rule text and would not revise definitions or other regulatory language. Counsel added that no proposed increase would exceed 100 percent and that the largest increase would be for establishment fees.

Board members discussed how increases would affect different license categories. Several members urged caution about impacts on individual practitioners and apprentices. One board member recommended doubling the apprentice registration fee from $50 to $100, citing the staff time required to process applications and quarterly reports. Members noted that many funeral directors pay employer-side costs such as health benefits and that retaining qualified staff, including attorneys and investigators, requires adequate funding.

Counsel and staff explained the multi-step rulemaking process that follows internal review: publication, a public rulemaking hearing, review by the attorney general’s office and final consideration by the legislature’s Government Operations Committee. Staff said the board would have at least two additional opportunities to review proposed fee amounts before a public rulemaking hearing and that their goal is to complete the process before the next fiscal year if possible.

After discussion, a motion to authorize the office of legal counsel to prepare and file a fee rulemaking package passed on a voice vote.

The board did not set final fee amounts in the meeting; staff said specific dollar values and a redline of the rules would return to the board for review at a subsequent meeting and a formal rulemaking hearing.

Ending

Board staff said they will circulate the draft rule package for additional review and expect to present an internal-review version at an upcoming meeting before the formal rulemaking hearing. No final fee changes were adopted at the meeting.