Draft guidance on funeral costs consultation: analysis of responses

Transparency of Pricing at the Point of Sale

At the heart of the funeral costs draft guidance is ensuring that consumers are aware of the full array of cost options when arranging a funeral, to ensure that decisions are as informed as possible.

Key to this is ensuring that people are made aware of lower-cost options, where these are available, to negate the need for people to have to proactively ask about lower-cost options. Highlighting the availability of lower-cost options could help to reduce the stigma or guilt that some people arranging a funeral may feel about asking for lower-cost funeral options where they may have limited money available to pay for the funeral.

The draft guidance includes a measure suggesting that funeral directors should ensure that, where appropriate, the full range of price options available is presented for each purchasing decision, as well as confirming, in writing, what is included in each element of the funeral. Specifically, the draft guidance encourages funeral directors to provide written confirmation of costs in the form of both a written estimate and in a detailed itemised final account (including a breakdown of fees received directly by the funeral director and those paid onwardly to a third party, on the client's behalf).

Care of the Deceased

As part of achieving transparency in the costs of funerals, the consultation specifically sought views on whether funeral directors should describe their processes for 'care of the deceased' i.e. the way in which bodies are cared for by funeral directors in the period between uplift of the body and the burial or cremation taking place.

Q9. Do you think that the guidance for funeral directors should include a measure suggesting that funeral directors should describe their processes for care of the deceased to help consumers understand costs associated with this?

	Number	Percentage
Yes	39	80%
No	5	10%
Don't know	1	2%
No response	4	8%
Total	49	100%

The majority of respondents who answered this question agreed with the proposed measure. Only five did not agree and one respondent was undecided. The remainder did not answer the question.

Q10. Please explain your answer.

Transparency and Sensitivity

Several respondents supported this measure on the basis that it would allow families to make more informed decisions as well as negating the need for families to proactively ask what the process entailed (which could be emotionally challenging):

"Consumers should be given the opportunity to understand the service they are paying for and, while they may not always understand all the technical details, provision of this information will increase transparency for consumers."

It was generally perceived that this measure would also break down some of the barriers that may exist for consumers who are unsure about what they should/should not ask of service providers (i.e. being "afraid to ask"):

"Arranging a funeral is a very infrequent task for most members of the public, and therefore their understanding of the process can be strengthened through provision of such guidance. People might not want to ask undertakers as they would be unsure and also in a very emotional state and would not be able to understand the discussions taking place. With this additional help, people could choose which type of care they would like and could afford."

This also aligned with earlier views that a full breakdown of professional fees should be available to everyone to ensure transparency, ensure that care of the deceased is not compromised and standards are maintained and are clear to users. Explaining why each service may be deemed necessary was also encouraged to empower families in making their choices and ensure that they were not exclusively focused on price, it was felt:

"Consumers cannot currently make a meaningful comparison of services as they are not able to effectively assess non-price factors, such as care of the deceased."

Again, it was considered important that the language used by funeral directors to convey this information was clear, sensitive and appropriate. This measure was seen as a simple continuation of the transparency of language used, as discussed earlier in the consultation:

"It is important that consumers have the option of being informed regarding the care of the deceased. This should be done in a language which is both understandable and sensitive. This provides reassurance that their loved one is being treated with dignity and respect."

Importantly, transparency should not compromise sensitivity, it was suggested, and the Scottish Government could consider guidance around how information is conveyed:

"…while funeral directors should always inform consumers that a full description of care processes is available, the Scottish Government should consider carefully the terminology used in the descriptions and the methods of administering such information."

Individuals commented, based on personal experience of arranging funerals, that they had found understanding of what was involved in care of the deceased, and how this varied between providers to be very confusing. Another individual also commented that they had found this complex and had not understood that some services that they paid for could have been offered free of charge by the local authority. One local authority echoed that a lack of awareness often resulted in secondary distress for families and could be avoided by this measure:

"Good quality information and advice are essential to enable people to access services and make informed decisions. The need for a better understanding of associated costs by the public would be a benefit to both funeral directors and consumers in clarifying the processes of care being provided. Experience from front line advisers supporting clients highlight a lack of understanding of some associated costs for services offered by funeral directors, in some instances an absence of awareness of where to get help and support and people being mis-informed by friends and family."

On a more general note of support, one organisation welcomed the guidance in the absence of any current regulations around care of the deceased. An increase in competition in the market, and competition between funeral directors had, they perceived, led to an inconsistent quality of care for the deceased across the country:

"The level of care provided by a funeral director is important to clients. However, differing care and quality standards are often not clear to clients who take at face value the quality of service and standard of care in a trusted profession. We therefore welcome measures which provide greater transparency on the standards of care of the deceased."

Strengthening the Measure

Some suggestions were put forward to strengthen the measure even more, including funeral directors specifying daily rates for keeping/caring for a body, clearly specifying refrigeration practices/capacity, and setting out how regularly bodies were checked (with daily checking being considered by one respondent to be the appropriate level of care^[7]). As with earlier comments in the consultation, clarity around embalming and hygienic cleaning was emphasised, to make these particular processes more understandable to consumers.

One organisation suggested that the introduction of a 'quality ranking' for funeral directors specifically linked to care of the deceased may assist consumers further in comparing what different providers may offer (e.g. similar to Ofsted rankings for schools):

"In general, quality ratings are more likely to be effective in assisting clients' decision making where there is a variance in the results. Therefore, we recommend that funeral directors are assessed against stringent, meaningful requirements, and are rated accordingly. Such a rating will assist clients in choosing high quality services, and will therefore encourage greater competition over quality of service."

On a related note, one funeral service provider commented that there is often a misconception that "the cheaper the funeral the worse the standard of care". This was something that they challenged and suggested that direct funerals or cremations can often provide a more suitable solution for some families.

One organisation that supported proposals for funeral directors to provide consumers with a description of their processes for care of the deceased also recommended that this could include a description of the support offered to the bereaved:

"…the quality of care offered by the funeral director, the time funeral director spends with the bereaved, the ease with which the service is assembled, the funeral director's ability to meet specific religious, cultural or geographical requirements, and the care that is taken to honour the memory of the deceased will contribute to consumer satisfaction, above and beyond costs."

Reasons for Lack of Support

Among those who did not agree, the reasons given were that this may be too much information for a family to take on board at what is already a difficult or challenging time. Three separate respondents proposed that information could be offered to individuals only if they wanted it, i.e. on an optional basis^[8]:

"…I think that this detailed information should be optional - you could give families the choice as to whether they want more detailed information or whether they are happy with a broad overview. Some people may not feel psychologically strong enough to deal with the processes of a preparation of a body etc. at that time."

"We consider that the desire to access this information or otherwise may depend very much on the individual in question. While some may benefit from a detailed breakdown, others could find such details upsetting or overwhelming. We therefore consider that it would be helpful if funeral directors could make such information available upon request."

Another disagreed on the basis that essential care should always be included in the standard funeral. Only where the family opt for a direct cremation or a family centred funeral would care of the deceased possibly differ. In encouraging funeral directors to describe their processes of care in more detail, there may be a risk of them selling additional unnecessary higher standards of care, it was suggested. Indeed, one not-for profit organisation expressed shock that the consultation mentioned that some funeral directors had expressed concern that a focus on making funerals more affordable could lead to less investment in mortuary/refrigeration facilities, and stressed that this topic should not be avoided:

"Of course, a dignified and careful approach should be taken in raising the options of cheaper funerals; however, any suggestion that this topic should be avoided completely in fear of offending is simply a reflection of funeral directors without sufficient experience broaching such discussions carefully, and who would personally profit from people opting into higher cost funerals. Their views should not be given high weighting in light of these vested interests they hold."

One respondent noted that they considered it incumbent on funeral directors to always fully explain what the consumer is paying for and that this was a basic consumer right.

Some private providers disagreed on the basis that the minimum standard for the care of the deceased was to be included in the forthcoming Code of Practice. Given that this will be subject to inspection and scrutiny by the Inspector of Funerals, reference to this minimum standard in the code should be sufficient, they suggested (and one commented specifically that it should therefore be removed from the guidance).

Finally, one respondent echoed comments from earlier in the consultation that 'low cost' options should not be labelled as such, as this was stigmatising and may put some people off choosing such services as they feel they are "scrimping" on their loved ones. The costs of care of the deceased, whether included as part of the standard (essential) or additional (optional) service, should be clearly set out and explained.

Overall, the proactive nature of this measure was welcomed, and was seen as alleviating uncertainty and associated stress for families, by most respondents.