|From: John McQueen <email@example.com>
To: "'firstname.lastname@example.org'" <email@example.com>
Date: Wed, Jun 23, 1999 1:49 PM
Subject: FTC Funeral Rule Revision
Dear Sir / Madam:
Besides owning a large independant funeral establishment in St. Petersburg, FL, I am also the incoming President of the Florida Funeral Directors Association. Therefore, I would like to express my personal thoughts as to the revision of the funeral rule.
#1 Non-Declinable Service Fees
I believe funeral homes should be allowed to charge a non-declinable service fee for all of their offerings. This fee as we currently understand is used to offset overhead expenses, etc. If this fee is declined in the future by the FTC, the funeral homes will still need to charge for their services and will accomplish this by merely raising other charges to offset the loss.
Although, many of the low cost, often direct cremation providers, do not think this fee should be allowed. I disagree.
This fee should be allowed, but it should be better enforced by the FTC. In other words, this non-declinable fee should be imposed on all of their respective charges or packages. In my travels throughout our State, this is not being done. I believe if you charge a $500.00 non-declinable fee, then this fee should be carried out in all of your charges. If you look to that company's full service traditional funeral or to the least expensive direct cremation charge. Otherwise, the family's with the traditional service is making up the overhead cost for those families who select the direct cremation. Therefore, everyone is not being treated equally.
#2 Casket Handling Fees
Our funeral homes' market places are considered to be one of the toughest competitively in the funeral industry. We receive caskets every day from other funeral homes and vice-versa, and I believe it would be wrong to punish the family for getting a better deal elsewhere. In fact, often times funeral homes will advertise a low service charge to a family and then hit them with an exorbinate casket price. Many of them feel this will get the business in the door and then they will not leave when taken to the selection room. They believe this because most telephone callers will ask what we charge for a traditional funeral, etc. (our service fee) but do not ask what we charge for our caskets, etc. to compare prior to entering the funeral home. However, I believe the families have a right to choose. Therefore, let the funeral home charge the low fee if they choose, but be prepared to possibly lose a casket sale. In fact, its time the profession realize that families deserve a choice and should not be taken advantage of during a time of need. Allowing handling fees again would only punish the consumer further.
#3 Price Disclosure
I am a true believer in providing the families with the proper price disclosures. However, I think the idea of presenting it to the family the minute you sit down with them is ridiculous. I think the funeral director should be allowed to build a rapport and find out a little about the kinds of services the family is interested in before presenting them with the GPL. I believe it can be presented to them prior to discussing actual charges or in clarifying what it would cost for the services they are interested in having. If the charge is too great, they will tell you and you can change to a different offering. This serves the same purpose without presenting to the family that the funeral industry is all about money and presenting a price list at the beginning of the conversation. In fact, I can not think of any other industry in which the moment I sit down to talk to someone that I am given a price list.
#4 Level Playing Field
I do believe that funeral homes, cemeteries and third party providers of services need to be on the same level playing field as far as price disclosure with the FTC. Especially the cemeteries. However, I feel it would be impossible to regulate everyone the same as not all funeral providers fall under the services category. For example, what about monument dealers, cemetery lot brokers and third party casket sellers. Many of these individuals only sell merchandise and do have price lists for their merchandise or cemetery lots. However, many do not sell services such as providing funerals. Therefore, their would need to be some differentiation.
Cemeteries, however, should be required to disclose all of their services to the public in some fashion the FTC deems appropriate. Many cemeteries in Florida are now combined with a funeral home or have a direct disposers license. Therefore, they must comply with the FTC. However, many do not have this affiliation but definitely take advantage of families. They should be required to disclose their Opening / Closing Fees as well as other fees. In fact, many cemeteries throughout the country have told families they can put two people (either full size, cremated, or one of each) in one grave space. Now, long after the purchase, they charge in addition to the Opening and Closing a so-called 2nd Right of Interment Fee which is ridiculous. This is a fee to have the priviledge of placing two people in one grave and it is often times 1/2 the current rate of a grave space in that section. Therefore, many families are required to pay in addition to an opening and closing fee of typically $500 or more, a 2nd right of interment fee which could be in the hundreds or thousands of dollars, and is non-declinable if they want to use what they were promissed. Another bogus fee is the Processing Fee, Archiving Fee or Documentation Fee. Many cemeteries have begun adding an additional fee of $50 or more to a contract for so-called archiving. I view this as another bogus fee and a non-declinable fee. If they are willing to charge such high fees for their property, etc. the least they can do is take care of all necessary record-keeping without charging extra for it.
In closing, thank you for your time and consideration with respect to this matter. If you need to contact me my information is below.
John T. McQueen