Draft guidance on funeral costs consultation: analysis of responses

Transparency of Cremation Charges

There is currently variation among crematoriums in what is included in their charges. To help consumers understand the cost of cremation and to be able to compare the costs across different providers more easily, the draft guidance set out both a definition of what a standard cremation service should comprise, as well as guidance around additional items which would not normally be included. The definition was developed in consultation with those working in the industry.

The draft guidance also recommends that charges made for additional items, which are not included in the standard service, should be clearly displayed separately. This would help consumers differentiate between service elements that are optional and mandatory. The draft guidance also includes a measure stating that where direct cremation is offered as a lower cost option, crematoriums should clearly describe what this includes and what it does not include, so that people can consider if this option is suitable for them.

Standard Cremation Service Definition

The standard cremation service definition included a number of core components, these being:

• cremation fee;
• mercury abatement fee (where applicable);
• provision of container for ashes;
• cremation certificate;
• provision of chapel/service room; and
• administration and processing of forms.

Respondents were asked to consider the standard definition and offer suggestions for any missing elements.

Q5. Do you think that the standard cremation service definition proposed in the draft guidance captures all of the necessary elements?

	Number	Percentage
Yes	22	45%
No	15	31%
Don't know	9	18%
No response	3	6%
Total	49	100%

There was some disagreement around the definition of the standard cremation service, with less than half indicating that the current definition captured all necessary elements and almost a third suggesting that additions/edits were required. Nearly a quarter of respondents either did not answer the question or indicated that they were unsure.

Q6. If not, please provide suggestions for items that you think should be added or removed.

The main areas where greater clarification was sought were around the interment of ashes, the provision of music services at cremations, time allowed in chapels/service rooms at crematoriums as part of a standard package and extra charges for selected day services.

Flexible Elements

Specifically, some respondents commented that clarity may be required that ashes can be interred in a lair (i.e. someone can bury ashes), in addition to the maximum permitted coffins, but that there may or may not be a cost associated with this. As stated, the draft guidance does not make clear if the cremation fee covers the cost of interring ashes nor that ashes could be stored. One respondent suggested that links could be included to local government sites to allow consumers to know that ashes can be interred in local burial plots.

In relation to organists and music, it was noted that many crematoriums currently include this in their standard fee. By not including this as part of a standard cremation service, there was a risk that some crematoriums would now be able to charge extra for the provision of music, and that this would disadvantage the consumer, respondents said:

"We would also hope that where crematoriums offer services over and above those described in a standard cremation service, such as music, this does not result in consumers facing additional charges for these, at present free, services. It is also important that consumers feel that they are providing a dignified send-off for their loved one and, if this would incur additional charges to them, these are explained fully."

The duration of time allocated to a family for the chapel/service room at the crematorium also needed to be more clearly specified, it was suggested. There is currently considerable variation in how long families may require this room (if at all), it was suggested, and clarity is needed on if/when additional charges may be incurred if the use of this facility is more than 'standard' or not used at all:

"The crematoria should be required to make clear how the price will be reduced where the service or chapel room are not used."

Additionally, for those who seek a civil ceremony, the inclusion of a chapel or service room within the standard cremation package may lead some consumers to presume than an officiant is also included, it was suggested.

In relation to nominated day services, it was suggested that greater clarity was required on if this would incur an additional charge. When booking a cremation, bereaved families often have a preference for a particular day of the week or time of day, as both can impact on their ability to secure a celebrant or minister, and can affect turnout at the memorial service, it was suggested. To reflect this, crematoria should make clear where the costs associated with a standard cremation will differ, depending on the date and time of the booking, respondents noted:

"Crematoria fees often differ dependent on the day and, in some cases, the time of the service. A standard cremation service charge should make clear during which hours of operation it applies, any uplifts that apply to weekend services and what is included in the fee, for example, use of music systems."

One private provider also stressed that many families most welcomed time at the crematorium to grieve without interruption and that guidance on appropriate/sufficient time should be built into the standard definition:

"We would therefore suggest that the guidance could support consumers by… encouraging crematoria operators to provide clarity on the length of slot offered."

Two other private providers endorsed this view and suggested that crematoriums should also include details of the length of time allowed for a service and any additional charges for extra time or for a 'double-time slot', making it clear that the allotted service time includes entering and exiting the chapel/service room and, as such, the actual length of service may be reduced accordingly.

Other Elements to Include

Other comments made by just one respondent each included that:

• in Asian tradition, the standard service should include bathing and the putting on of a new set of clothes a day or two before cremation;
• greater clarity was required around if standard services and fees include transportation of the body to the crematorium;
• no container is needed in cases where ashes are scattered at the crematorium, and thus, if a container for ashes is included in the standard cremation service charge, it should be clear how the price is reduced where no container is required^[3];
• it should include an environmental protection fee (separate to the mercury abatement fee);
• return of ashes, where applicable, be included at no extra charge;
• ashes could be scattered or stored (for up to one month);
• if the consumer wishes to have the ashes back, the funeral director will arrange to collect them from the crematorium and make them available for collection by the family from the funeral home at an agreed time (or the family may choose to collect them directly from the crematorium if they wish);
• a means of standardising or making clear the differences in memorialisation provision prices;
• extra charges may be in place for removing pacemakers, recycling costs/gains of titanium hips, gold teeth, etc. which are 'non-standard'; and
• there should be no fee for cremations of new born deaths, as standard.

Similarly, where charged, one organisation suggested that additional fees needed to be clearly set out, including:

• any additional charge that applies in relation to an international cremation certificate;
• any additional overnight 'holding over' fees;
• if no container for ashes is provided free of charge, the price charged for a container;
• pricing information for visual tributes (this is something that is often overlooked until after a decision has been made, it was suggested. In some areas it can even be more cost effective to have the cremation at one crematorium but to scatter ashes at another); and
• any environmental levies or other unavoidable charges

While there were no other specific suggestions for inclusions/edits, some more general comments were received that the definition was too vague in the draft and that something that allowed people to see individual costs being itemised so that they could select relevant service items and aggregate them into their own 'package' would be preferable. For example, a list of services and costs for an unwitnessed cremation, and a list of services and costs for a witnessed cremation, etc. This would make even clearer what could be purchased from different providers and at what cost, and would ensure that cremation authorities justify their fees in a like-for-like fashion. Similar provisions or guidance should also be in place for burial services, it was suggested (although this was covered later in the consultation).

One organisation suggested that the guidance could specifically list those services that are not included, as standard:

"This would make it clear to the consumer that all other services - such as provision of music, webcasting, dispersal of ashes or the purchase of an urn - are optional costs."

The Scottish Government was also asked to encourage crematoria operators to label clearly optional services as non-compulsory, while also making it easy for consumers to add such services on to the standard package. Such a system would enable consumers to build a bespoke package, which meets their individual needs, without paying for services that they do not require, it was felt.

One organisation noted that the proposed standard cremation service definition was acceptable, subject to the various components being further explained in the glossary of terms, as appropriate. Another requested that it be reviewed regularly and in conjunction with the public and key stakeholders, including those delivering services.

Although not specifically answering the question, another commented that they had concerns more generally that the definition of 'direct cremation' needed to be revised to ensure that it was not presented as an inferior option and also that, for some, it may be a more appropriate service option, in terms of being more relaxed or personal:

"It feels important to describe direct cremation (or direct or simple committal) in a positive and non-judgmental way and to fully explain that it still perfectly possible to hold a memorial service that might follow traditional rituals without a body present. The Church of Scotland does this. It may also be useful to explain more fully that a direct cremation can give people more time to plan a more personal celebration of life ceremony."

The key thing was to make clear that direct cremation separated the memorial service from the disposal of the body and would be attended only by funeral director staff and crematorium staff, it seems. A suggested definition was put forward, as follows:

"…this is where the disposal of the body is separate from any memorial service or ceremony organised by family or friends. No mourners are present at the crematorium for the simple committal, only the funeral director staff and crematorium staff. Some funeral directors may be able to speak some words or read a brief poem on the family's behalf if this is desirable."

Finally, one respondent indicated that they did not think that consumers cared about the detail of what was provided in practice, and that the final total bill was the main concern. It was suggested that costs were increasing year on year, disproportionately to the actual costs of providing cremation services and this was potentially damaging consumer confidence in private and public authorities. This was, however, a lone view.

Overall, respondents seemed to welcome the draft guidance in defining standard cremation services but felt that it should be subject to the above adjustments. They noted that this would assist consumers in their funeral choices, and allow for greater transparency and consistency in cremation service provision and practice.