Draft guidance on funeral costs consultation: analysis of responses

Display of Pricing Information

To assist consumer choice, the draft guidance sets out a range of measures for burial and cremation authorities and funeral directors about the display, accessibility and transparency of pricing information.

Legislation is already in place which dictates that local authorities must publish their charging information for burials, (both in paper form and online via local authority websites), and legislation is due to be commenced that requires the same for local authority cremation fees. The draft guidance encourages local authorities to make information on burial and cremation charges as easily accessible as possible by displaying the information alongside other burial and cremation information on the local authority's website.

Although there is no equivalent legal requirement for funeral directors, private cemeteries and private crematoriums to publish their charging information, the draft guidance encourages the same practice as that which applies to local authorities.

These measures, alongside measures to help increase awareness of affordable options, should allow consumers to make more informed funeral decisions.

Displaying Information Online

Respondents were asked as part of the consultation to indicate their agreement with the draft guidance for private cemeteries and crematoriums and funeral directors with a website to display their pricing information online.

Q3. Do you think that the guidance should include measures which encourage private cemeteries and crematoriums and funeral directors with a website to display their pricing information online?

	Number	Percentage
Yes	45	92%
No	1	2%
No response	3	6%
Total	49	100%

All but one individual who answered this question supported the display of pricing information online. Indeed, this area of the consultation received the most support, overall. Importantly, however, some who did not give a closed response to this question, did go on to provide views against the proposal.

Q4. Please explain your answer.

Transparency and Parity

The main reasons given in support of this proposal included that it would allow consumers to compare services being offered by different providers more easily, thus allowing more informed choices, would be more transparent and be seen as fairer for consumers. It may also encourage more funeral directors and private cemeteries to be more competitive when setting prices, it was felt. Another reason put forward was the parity that this would achieve between local authorities and private providers:

"This is essential, given the mix of public and private service providers for the statutory guidance to apply equally to both public bodies such as councils, which are already subject to fees and charges scrutiny and governance checks as the normal part of Council governance. Private cemeteries and crematoriums and funeral directors also need to adhere to the guidance to provide a level playing field of consistency of information online for the public and bereaved families. This will allow people to fully understand what they are paying for and therefore to make an informed choice."

One local authority confirmed that they already displayed all pricing information and agreed that private providers should do likewise. Importantly, one third sector advice organisation, who endorsed the proposal, noted that it would strengthen existing legislation which, they perceived, was not always adhered to (i.e. although local authorities have a legal duty to publish charges, these are not always displayed in a logical place on local authorities' websites, it was felt). Another noted that they welcomed the draft guidance because they perceived that cemeteries and crematoriums often failed to make clear where prices could be found or failed to break down prices sufficiently to demonstrate the difference in cost, for example, an early morning slot compared to a weekend one.

Improved Consumer Experience

Three individuals who responded to this question wrote candidly about their own direct experience of bereavement and the added challenges that had been experienced in trying to understand the costs associated with arranging a funeral at a time of grief. If price information had been clearly displayed, time could have been saved in liaising with funeral directors, thus allowing more time to grieve, it was explained:

"I found it very distressing and confusing trying to decipher costs, in particular when it came to choosing the crematorium as I had a choice of locations but the costs differed greatly."

At a time of loss, people did not want to be discussing money and costs, especially if on a low income, it was suggested. Having prices clearly displayed would negate the need for difficult discussions. It would also remove the need to "ring around" different providers, which can be time and cost intensive and cause additional stress, it was suggested. Being able to access the information from home (i.e. online) was particularly welcomed:

"It allows people a chance to look over the information and take time to digest this. Sometimes, at a stressful time like this, people don't always listen or understand what is being said. A website would allow them to look before or after their meeting with relevant agencies."

"We know that many people will look to access information about pricing and will want to do some comparisons without speaking to people on the phone or being there in person. Some people can feel more comfortable looking at prices and working out costs against their budget at home and as part of online research. We believe online information will allow people to study prices in a way that meets their needs and preferences."

Indeed, one organisation noted that accessing the information remotely and anonymously may remove the need for personal contact with service providers which can sometimes lead to clients feeling obliged to enter into agreements rather than walk away and compare the market:

"Many funeral director websites do not display any pricing at all. This means that the customer will often go into the parlour before they even have an idea of the estimated price and feel tied to going with the funeral director in question. The person will often sit through making the full funeral arrangement with the arranger (sometimes up to an hour) in which time a relationship has been built and the customer may find it hard to walk away."

This may be particularly relevant in remote areas or close-knit communities where service providers are scarce and/or where there may be an expectation that one provider will be used, as they are already known to the family, they suggested:

"In remote communities the provision and choice of funeral services may be limited…In addition, having the opportunity to gain pricing information anonymously from websites also helps to mitigate the potential for stigmatisation in areas of poverty and deprivation where a family of the deceased may be struggling to afford burial, crematorium and the costs of funeral directors."

Overall, it was felt that providing information online across the board would allow people to plan in advance, as well as at a time that was most suitable for them, and to be able to make truly informed funeral planning decisions.

Alternative Formats

As with the glossary of terms, calls were made for pricing information to be presented clearly and using Plain English to make it accessible to those with impairments, disabilities or other complex needs. While several respondents noted that there was an increased reliance on the internet and websites to find information about services, (and so welcomed the online publication of fees), they felt that costs should be easily accessible off-line too, as well as in alternative formats (e.g. printed or written quotes, brochures, telephone quotes, by email, audio, etc.):

"People should be able to request pricing information in different formats, including over the phone, easy read, braille, audio, and large print. By providing pricing information in different formats it will ensure that they are accessible to all, and will enable people to make an informed decision."

If not available online, the fees should be displayed clearly off-line in printed form in the premises of service providers, as well as in funeral homes and other public spaces where such services are offered, it was suggested.

Using non-digital/online routes to share pricing information was particularly important for demographic groups who traditionally may be less likely to have internet access, including the elderly and those in the lower socio-economic groups, it was suggested. If displayed on websites, respondents urged that pricing information be clearly signposted on 'home' pages and available as downloadable PDF files. Websites providing information to consumers must also be compatible with screen readers, it was suggested.

Given the large proportion of deaths that occur in institutional settings (i.e. hospitals, care homes, hospices, etc.) professionals working in such institutions were also seen as potentially influential and important gatekeepers to information on pricing and funeral provider choices. More thought on encouraging awareness among this group around competing services may be required, it was posited.

Comparing Like-for-Like

It is important to note that, while this part of the draft guidance was widely supported, some organisations (mainly representing those in the private sector) highlighted some limitations to publishing information in this way. This included perceptions that it was not possible, at present, to compare like-for-like within the industry, given a lack of shared definitions for particular service elements, as well as concerns around competitive tendering or commercial confidentiality for private providers.

Several organisations stressed that, while they supported enhanced price transparency in the funeral market and, therefore, the inclusion of measures that encourage cemeteries, crematoriums and funeral directors to display comprehensive pricing information online, they perceived this would only be meaningful if there was also consistency in the services being described. For example, given that there is no cross-industry agreement on what constitutes a simple or standard funeral, consumers comparing prices for what they believe to be the same service, may not actually be comparing like-for-like:

"Without such agreement, funeral directors may be justifiably apprehensive about providing cost information online, as consumers might attempt to make direct comparisons with incomparable services elsewhere. An agreed cross-industry definition of a simple and standard funeral would facilitate the provision of cost information which could be effectively compared online and thus give funeral directors the confidence to display price information on websites, knowing that the services they offer vis-a-vis competitors will not be misinterpreted. In the absence of agreed definitions, while the provision of cost information online can still benefit consumers, direct comparisons between services are not easily made."

Indeed, several respondents suggested that a more transparent approach would be to require providers to itemise different service options, i.e. displaying the costs of each component part of a funeral individually. For example, listing the cost associated with collecting the deceased or the cost associated with storing the deceased, as separate and individual services:

"Under such a system, while different funeral directors may offer funeral services with differing component parts, consumers would have access to information that would still facilitate price comparison of core services and would help consumers to identify any individual service that carry an unreasonably high cost burden within the overall funeral package."

This would reduce the risk of consumers making misleading comparisons, it was suggested. Under this model, one organisation also urged that all providers should be encouraged to present a cost for the lowest cost bundle against which the services and prices of other bundles can be compared. This would assist comparison across providers, as well as providing a simple baseline option for comparison, they felt.

Similarly, two other organisations stressed that while they promoted online, easy to find price lists and transparent practice, they had concerns about the way in which services could be described and the ambiguity that this may introduce to comparisons:

"...as there are so many different ways in which products and services are described there is the unintended consequence of using marketing talk and opaque descriptors, so that the products and services can't be compared like for like."

A coffin, for example, may be described as such yet cover a broad range of options from cardboard to solid oak which would, justifiably, differ in price. Without knowing what type of coffin was being provided for by each service provider in their costs, a simple comparison of the prices advertised for a coffin would not be possible. Both respondents suggested that the Scottish Government refer to the style of the US Federal Trade Commission, The Funeral Rule, which legislates for standard language and ensures a level marketing playing field. Another organisation simply noted that cost information alone was insufficient to allow consumers to make informed choices and, along with fellow funeral service providers, urged that face-to-face conversations with funeral directors to allow services to be properly described could not be replaced:

"We strongly believe that the best way for a bereaved family to be able to fully understand the various services, products and options available and their associated costs is to directly discuss these with a funeral director. Having the opportunity to discuss their needs and then allowing the funeral director to give advice and guidance on the various options available is the only way to ensure the consumer is fully informed and able to make the right decision for them."

Third party costs may also influence the total cost that providers need to charge, it was noted. Respondents felt that there was no financial incentive for funeral directors to recommend any one crematorium over another, for example, but geographical variations in availability of different crematoriums, and their associated costs, may mean that third party costs impact on the total costs that funeral directors are able to advertise:

"Third party costs (such as crematoria and burial fees) may differ on a location by location basis. In some areas where there are multiple crematoria and burial grounds, there may be different prices between the crematoria. To the extent there is geographic variation, each client should be presented with the relevant information for them."

For funeral directors covering more than one area, including those who provide UK wide services, there may be a need to allow consumers to give basic geographical information at the time of requesting a quote, to allow an individualised total cost to be generated, it was suggested. However, a requirement to display all possibilities online, with all variants, depending on location, may result in overly complex pricing pages and may be overwhelming for consumers. More thought was needed, it was felt, on how 'variable' costs could be displayed, and how publication of online information could be linked to a geographical location, to ensure all clients have access to relevant price information and avoid information overload.

Benchmarking

A small number of respondents indicated that it may be helpful to publish guidance on the 'average' cost of simple funerals, either nationally or for specific providers, to allow consumers to compare services with an average:
"There are Scotland-wide figures for the average cost of different types of burials and cremations available. We would prefer that funeral director pricing documents and websites were required to link to or refer to the average nation-wide costs for a simple cremation and simple burial.

"We feel that pricing should be as clear as possible, across the board. The advertised price should always be the price that most people (or the median person) actually pay for that type of funeral with that funeral director."

While some noted the commercial sensitivities of requiring private providers to publish information openly, it was still seen as essential to allow at least baseline comparisons to take place. Giving providers an opportunity to decide against advertising fees for 'non-essential elements' may be an appropriate compromise:

"Whilst we accept that private service providers may deal with delivering services in a commercially sensitive arena, there should be an ability to effectively 'benchmark' core fees across both commercial and private providers. This would ensure that there is some evidence of transparency in the basis for fees. We would accept that the publication of other elements which relate to the commercial factors and are non-core to burial or cremation, should be at the choice of each provider."

For those who offer only the simple funeral option, and have one fixed fee, it was also seen as essential that the phrasing of the guidance did not impede on their ability to display a single, simple price.

Ownership

Two respondents raised particular concerns linked to online publication of services and fees, in that they perceived there was no oversight or monitoring of how providers described or presented their operating status online. Specifically, it was suggested that some firms who advertise and appear prima facie to be independent, family run businesses may actually be corporately owned and/or operated. Given research which indicates that many people may be more likely to employ a family run business rather than a corporate business, this may be strategy used by some providers to secure business, they said:

"By the manipulation of parent company names, there are now corporate funeral director firms masquerading as local family run firms…In all surveys going back many years, the public's trust in the family run local firm far more than the corporate firms, therefore it's easy to see why this practice is increasing. At present it is legal, but we do question the ethics."

Greater transparency of ownership was urged to ensure protection of public interests and this could perhaps be incorporated into this section of the guidance^[2].

Further Consultation and Widening Dissemination

Several respondents encouraged greater consultation within the industry to refine and finalise an agreed set of terms and definitions for different funeral elements before this part of the guidance was implemented or enforced, meaning that like-for-like comparison would be more reliable.

Some third sector respondents also encouraged the wider dissemination of pricing information via support services, rather than via local authority and private sector websites alone, as this would maximise accessibility, it was suggested:

"We suggest that church ministers and other religious leaders could have this information to hand, to offer to people who come to them for help with arranging a funeral."

Several organisations urged that, while the clear online display of information was welcomed, care was needed that people did not feel pushed to transact all funeral planning and payment online as there was still a need for people to liaise in person with funeral providers to ensure that they fully express their wishes and know exactly what they are receiving in return:

"We also suggest that businesses who do display funeral costs online are cautious with providing the option of paying for a funeral online, as there is a danger that some people may not fully understand what they have purchased without speaking directly to a service provider."

Indeed, one organisation commented that their own research indicated that a large proportion of consumers make decisions around service provision based on recommendations from family/friends/others or based on their own previous experience, and so the display of information may do little to alter this consumer behavior. The same organisation also highlighted that costs should never be considered as the main factor driving consumer choice, and cited such things as reputation of the staff/funeral company, ability to personalise a funeral, location of the funeral director, trust and experience as all being significant contributing factors which the simple display of pricing could not accurately reflect.

On a related note, one respondent urged that the display of pricing information should also make clear to consumers that Church of Scotland ministers have no fees (although payment of expenses may be welcomed). There was concern that this service may, at present, be presented as being included in the fee, while entailing no actual cost to the funeral director. While it was noted that humanist and celebrants' fees may be included here, the same level of follow-up and bereavement care may not be offered by these individuals, whereas parish ministers would ordinarily try to ensure bereavement care is provided directly or by the local congregation at no cost. Such aftercare was seen as vital for individuals experiencing bereavement and so the way that this service is presented under any cost matrix should be carefully, consistently and truthfully handled.

Other Caveats to Support

Other comments included that providing too much information may be counterproductive from a consumer perspective, and that there may be risks with partial information skewing consumer behaviour. Some customers may also want bespoke packages and this measure may be of only limited use to this group. One individual also noted that the display of pricing information, while helpful, did nothing to contribute to reducing fees, which they considered to be the main issue at hand:

"The ordinary public do not understand the disproportionate rises in funeral costs in comparison to inflation. The information may indeed be provided but this does not justify or quantify the costs, as helpful as this may be."

The one person who stated explicitly that they did not agree with the proposal did not say why and, on the whole, respondents agreed that the guidance on funeral costs provided an invaluable opportunity for the Scottish Government to encourage greater transparency around funeral costs.