Policy Statement on Providing Price Lists and Telephone Price Information
Compliance with the amended Funeral Rule is not just a matter of designing price lists that meet the requirements of the Rule. A large part of compliance depends upon a clear understanding on the part of all employees regarding when, where and to whom price information is to be distributed. This includes not only the offering of price lists, but also the conveyance of price information over the telephone.
To assist members in training staff and maintaining compliance with the Rule, NFDA has drafted a Policy Statement on Providing Price Lists and Telephone Price Information. It is suggested that the funeral home formally adopt this Policy Statement and incorporate it into the training of all employees.
Since the primary purpose of the Policy Statement is to educate employees, it is important that the funeral home distribute copies of the Policy Statement to all staff, including non-licensed personnel who have contact with the public. The Policy Statement should also be incorporated into the funeral home's employee handbook if it has one.
By adopting the policy and using it in the training of employees, the funeral home is demonstrating a good faith effort to comply with the Rule. This is an important factor in the event the FTC was to bring a compliance action against the funeral home. Evidence that the funeral home took good faith steps to comply with the Rule constitutes a mitigating factor in the determination of civil penalties under the Rule.
Policy Statement of ________ Funeral Home on Providing Price Lists and Telephone Price Information
In order to ensure compliance with the FTC amended Funeral Rule, all funeral directors and staff of Funeral Home shall comply with the policy set out below when dealing with members of the public either in person or on the telephone.
The GPL must be physically handed to individuals who inquire in person about funeral goods or services, or the prices offered by the funeral home. Upon the beginning of a face-to-face discussion with a member of the public regarding the overall type of funeral services or dispositions, the selection of specific funeral goods or services, or the prices offered by the funeral home, you must physically hand the GPL to the person for retention. The following points regarding the distribution of the General Price List should be noted:
The Casket Price List and the Outer Burial Container Price List must be given to individuals who inquire in person about these funeral goods or the prices for these goods. It is our policy to distribute each list upon the beginning of any discussions concerning the goods or their prices, but in any event, before showing the individual the caskets or the outer burial containers.
The following points should be noted by you with regard to the distribution of Casket and Outer Burial Container Price Lists.
It is our policy to provide the consumer for his/her retention a Statement of Funeral Goods and Services Selected at the conclusion of the discussion of funeral arrangements. All funeral goods, services and cash advanced items purchased must be listed on an itemized basis. If prices of cash advanced items are not known, an estimate must be made.
If a package is selected in lieu of itemized goods and services, that must be noted on the statement. A description of all goods and services contained in the package must be listed on the statement. In the alternative, you can attach to the statement a description of the package.
Subtotals for the services purchased, the merchandise purchased and the cash advance items purchased must be filled in. If any cash advance item is marked-up, identify that item in writing on the statement. It is also necessary to list the reasons for embalming and any legal, cemetery or crematory requirements which made any purchase of goods or services mandatory.
The Statement of Funeral Goods and Services Selected must be provided at the conclusion of the funeral arrangements conference. Therefore, it will be necessary to write up the statement and provide it to the consumer during the arrangement conference. If the arrangements are made over the telephone, the statement should be promptly sent to the consumer.
Whenever anyone telephones the funeral home and asks any questions regarding our prices or offerings, you must provide accurate information from the GPL, Casket Price List, Outer Burial Container Price List and any other readily available source of information in order to reasonably answer the questions.
In meeting this requirement of the amended Funeral Rule, you must be aware of the following points:
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