Funeral Consumers Alliance of SC Joins Consumer Federation of America
Your FCASC has been accepted as a member of the Consumer Federation of America, an umbrella
organization of non-profits and public agencies working to protect the interests of consumers.
The Consumer Federation of America (CFA) was established in 1968 by national, state, and local pro-
consumer groups to advocate the consumer interest before the U.S. Congress and federal regulatory
agencies. In the last several decades, it has broadened its mission to include advocacy on state issues,
assistance to other consumer groups, and the delivery of services directly to consumers. The CFA
includes more than 270 organizations across a broad spectrum of concerns.
CFA promotes consumer protection by advocating for strong laws and regulations, working for trade
agreements that provide real benefits for consumers and do not weaken their rights, encouraging good
business practices, supporting consumers’ ability to complain and obtain redress, and educating
consumers about their rights and how to avoid fraud and abuse.
organization of non-profits and public agencies working to protect the interests of consumers.
The Consumer Federation of America (CFA) was established in 1968 by national, state, and local pro-
consumer groups to advocate the consumer interest before the U.S. Congress and federal regulatory
agencies. In the last several decades, it has broadened its mission to include advocacy on state issues,
assistance to other consumer groups, and the delivery of services directly to consumers. The CFA
includes more than 270 organizations across a broad spectrum of concerns.
CFA promotes consumer protection by advocating for strong laws and regulations, working for trade
agreements that provide real benefits for consumers and do not weaken their rights, encouraging good
business practices, supporting consumers’ ability to complain and obtain redress, and educating
consumers about their rights and how to avoid fraud and abuse.
New Information on DHEC Website
The SC Department of Health and Environmental Control has posted some helpful documents on their
website. If you are considering caring for a loved one as they are dying or want to act as your own funeral
director, you will want to look at the following:
1. Instructions for Filing a Death Record without a Licensed Funeral Director
This document will give you information about transporting a deceased individual for final dispostion, in
other words, how to obtain a BRT (Burial-Removal-Transit) permit. This is the form needed in order to
move the deceased from the place of death to the place of final disposition, be that a cemetery or a
crematory.
2. Filing of Death Record
This instruction on the DHEC website includes a link to a South Carolina Certificate of Death Non-funeral
Home Worksheet (DHEC-670D)
3. Obtaining a Certified Copy of a Death Record
The website has a link to obtain an application.
Go to www.dhec.sc.gov/VitalRecords/Forms.
You may also want to consider our pamphlet on "Caring for Your Own Dead in South Carolina," a copy of
which is available here.
website. If you are considering caring for a loved one as they are dying or want to act as your own funeral
director, you will want to look at the following:
1. Instructions for Filing a Death Record without a Licensed Funeral Director
This document will give you information about transporting a deceased individual for final dispostion, in
other words, how to obtain a BRT (Burial-Removal-Transit) permit. This is the form needed in order to
move the deceased from the place of death to the place of final disposition, be that a cemetery or a
crematory.
2. Filing of Death Record
This instruction on the DHEC website includes a link to a South Carolina Certificate of Death Non-funeral
Home Worksheet (DHEC-670D)
3. Obtaining a Certified Copy of a Death Record
The website has a link to obtain an application.
Go to www.dhec.sc.gov/VitalRecords/Forms.
You may also want to consider our pamphlet on "Caring for Your Own Dead in South Carolina," a copy of
which is available here.
Funeral Pricing Practices in Greater Columbia
A 2016 Report of the Funeral Consumers Alliance
In 1984 the Federal Trade Commission, in an attempt to “level the playing field” between the sellers and buyers of funeral goods and services, imposed a trade regulation known as the “Funeral Rule” on the funeral industry. It changed the landscape by requiring funeral homes to give prospective purchasers a list of prices for the 17 most commonly purchased goods and services in the form of a General Price List (GPL). This made it possible for consumers to gather and compare prices and for the Funeral Consumers Alliance to monitor the industry’s compliance with the Funeral Rule.
This is the twelfth in a series of surveys of funeral pricing practices among South Carolina’s funeral homes. Previous surveys of the Greater Columbia area were completed in 2001, 2003, 2005, 2007, 2010, 2012 and 2104. We have also conducted surveys of Charleston’s funeral homes (2005, 2011), those in the Upstate (2009) and, most recently, the Grand Strand (2015). All of the surveys have been conducted by the Funeral Consumers Alliance of South Carolina, a not-for-profit consumer education and advocacy organization that is one of nearly one-hundred local affiliates of the national Funeral Consumers Alliance (www.funerals.org). As with each of our previous surveys, we have gathered pricing information from the GPLs collected from all of the funeral homes listed in the Yellow Pages for the area. We have made every effort to list the prices exactly as they appear in the GPLs, but because of the wide variety in the way that this information is listed, we advise that consumers review prices with the funeral homes of their choice to confirm accuracy.
We recognize that price is only one consideration, albeit an important one, that factors into the choice of a provider. Because funeral homes differ greatly in their charges for various components of the funeral, it is important to take each of the chosen components into consideration when evaluating the true cost of the complete funeral. Some may have much higher charges for their “basic services” (see below), but comparatively lower charges for other goods and/or services, such as embalming or transfer of the body. Our spreadsheet should be of great help to those persons who are trying to do comparison shopping.
Basic Services
Basic services charges, sometimes referred to as “non-declinable charges,” include the cost for planning the funeral, securing the necessary permits, preparing the notices, and coordinating the cemetery or crematory arrangements. It may also include “overhead” costs. The accompanying spreadsheet shows that this charge ranges from a low of $945 (McClary’s) to a high of $4,925 (Caughman-Harman). Since the kind of services that are provided are constant from one provider to another, the difference in charge is likely due to the differences in salaries and the cost of upkeep of the premises. The average charge among these providers is $2,092.
With some “minimal services” such as direct cremation or immediate burial, a proportion of the basic services fee is included in the price. Some providers state that their basic services fee is included in the prices, but when the basic services fee is greater than the charge for either direct cremation or immediate burial, that would be impossible.
While this confusion does not rise to the level of a Funeral Rule violation, we have tried to encourage providers to clarify this item on their price lists.
We believe that this is best stated as: “This fee is already included at a proportional rate in our charge for direct cremations and immediate burial.”
Embalming
The charge for embalming also varies widely, some might say dramatically. Early versions of the Funeral Rule required the following statement:
Except in certain special cases [emphasis in original], embalming is not required by law. Embalming may be necessary, however, if you select certain funeral arrangements, such as a funeral with viewing. If you do not want embalming, you usually have the right to choose an arrangement that does not require you to pay for it, such as direct cremation or immediate burial.
The Funeral Rule also states that “You [funeral homes] do not need to include the phrase “except in certain special cases,”…if state or local law in the area where you do business does not require embalming under any circumstances.” [emphasis in original] Although that is the case in every jurisdiction, including South Carolina, all but four of our respondents (Holley, McSwain-Evans, Temples-Halloran, and Trezevant) include this misleading, language in their price lists.
Embalming serves no public health function. If one is planning a viewing of the body, as opposed to a visitation or some manner of direct disposition, the funeral home may require embalming to temporarily delay the decomposition of the body, but it may not be done without the permission of the person authorized to act on behalf of the deceased. Refrigeration can also be used in lieu of embalming at a much lower cost.
This language has been changed from permissive to proscriptive in the latest edition of the Funeral Rule and now reads as follows: “Delete the phrase, ‘Except in certain special cases,’ from the embalming disclosure if state or local law in the area where you do business does not require embalming for a viewing or funeral.” (Complying with the Funeral Rule. April, 2015) This change was published by the FTC in April of 2015, more than a year before we collected the GPLs from the funeral homes for this survey and it should be incorporated in the GPLs dated 2016 and subsequent.
This was intended to stress that in states where embalming is never required by law the “except in certain special cases” should be deleted. (footnote on page 24)
The state agency charged with regulating the industry (Board of Funeral Service, hereinafter referred to as the BFS) decided to inform their licensees of this via their Frequently Asked Questions (FAQ) page on their website: (http://www.llr.sc.gov/POL/Funeral/index.asp?file=faq.htm)
Q. In regards to General Price Lists (GPL), the Federal Trade Commission (FTC) guidelines include “embalming if required by law.” Since embalming is not required by South Carolina Law, how do I handle this when discussing funeral plans with families?
A. While South Carolina law does not require embalming and you cannot tell your customers that they are required to embalm, you may make recommendations to your customer about embalming as it suits the customer’s needs. For example, if someone passes away on a Sunday and does not plan to have the funeral right away, they may want to embalm the deceased as a means of delaying decomposition until time for the service if refrigeration is not available.
This, however, is not what the FTC has directed and it is therefore not surprising that this is stated incorrectly in all but four of our area funeral homes. (see above)
The cost for embalming ranges from a low of $495 (Right Choice Cremation) to a high of $1,259 (Holley). Embalming is a standardized procedure involving the removal of body fluids and replacement with embalming fluid, which makes it difficult to justify the wide range of costs, in this case a range of more than twice the lowest price.
Transportation
Transportation costs include such things as transfer (picking up the body from the place of death and delivering it to the funeral home), use of the hearse (carrying the casket from the funeral home to the cemetery), and a limousine or family car (to accompany the hearse).
The costs for transfer are based on service within a defined distance from the funeral home and range from a low of $150 (Jones) to a high of $595 (Caughman-Harman, Dunbar, and Elmwood). The price is typically based on a defined distance with additional mileage imposed beyond that.
The costs for the use of the hearse vary from a low of $225 (Dicks) to a high of $495 (Caughman-Harman, Dunbar, Elmwood, and Thompson).
The use of the limousine or family car ranges from a low of $150 (Barr-Price, Moseley) to a high of $375 (McClary’s).
Caskets
Caskets and vaults (see next section) often constitute the most expensive itemized costs at the funeral home—with the exception of some basic services charges—and in 1994 the Federal Trade Commission made it clear that consumers were free to provide their own caskets or alternative containers if they chose not to purchase them from the funeral home. Although caskets were available on the retail market well before that time—and some may prefer to make their own caskets—there has been a dramatic increase in both online availability of caskets and offers from large marketers like Costco and Walmart. There is evidence on record that the mark-up on caskets is often in the range of 400-600 percent, a figure making careful shopping attractive.
The cost of a casket depends upon a variety of factors that are not reflected in the price ranges on the typical GPL. The ranges listed on our spreadsheet only give some indication of what might be available, keeping in mind that materials, manufacturer, and quality may vary from one to another. Also, it was impossible to determine from some of the GPLs whether the lowest-priced casket was really a casket or if it might better be described as an “alternative container” of the type that might be used for cremation. With that caveat, the least expensive casket offered was $400 (Holley) while the most expensive was $26,995 (also Holley).
There is yet another way of analyzing the data. Since the points at which funeral homes choose to “anchor” their casket selections may influence consumer choice, e.g., there is a tendency for most consumers to eschew either the least or most expensive caskets (or vaults), setting a higher “bottom” or “top” of the offerings may influence consumers to select a more expensive item. Accordingly, the least expensive “top-of-the-line” casket offered by one of our respondents was $1,475 (Right Choice Cremation) and the most expensive “bottom-of-the-line” casket was $1,850 (Good Shepherd) The average price of caskets ranged between $848 and $12,278.
Vaults
Vaults, also known as outer burial containers, are designed to encase the casket and protect the gravesite from sinking as the casket begins to deteriorate and the earth starts to settle. Like caskets, vaults come in varying materials and designs. Since cemeteries sometimes require the use of a vault to make it easier and safer to care for the grounds, some will make available less expensive “grave liners” (wood or concrete) than the vaults typically sold at the funeral home.
As was the case with caskets (above), it is impossible to compare prices without knowing about the manufacture and composition of the merchandise. The following reflect only the most and least expensive vaults offered by each of our respondents. The least expensive vault was $395 (Jones) and the most expensive was $22,230 (Bostick-Tompkins). Looking at this as above, the least expensive “top-of-the-line” vault offered by one of our respondents was $2,995 (Good Shepherd) while the most expensive “bottom-of-the-line” vault offered by another (McCollom-Myers) was $1,325. The average price of vaults ranged between $800 and $10,250.
Alternative Containers
The Funeral Rule requires the following disclosure:
If you want to arrange a direct cremation, you can use an alternative
container. Alternative containers encase the body and can be made
of materials like fiberboard or composition materials (with or without
an outside covering.) The containers that we provide are (specify containers).
This is where things get confusing. In spite of the Rule, the various funeral homes don’t always clearly specify the composition of their alternative containers, often listing different prices for alternative containers available for direct cremation and immediate burial, although there is no reason why the same container could not be used for either. Most funeral homes use either fiberboard or reinforced cardboard as their alternative containers, therefore it’s hard to understand the variation in cost from $10 (Barr-Price) to $450 (Palmer).
Immediate Burial
Both immediate burial and direct cremation (below) are regarded as “minimal services.” Typically the body is picked up at the place of death and transported directly to the cemetery or crematory. As with other types of disposition, the purchaser has the right to provide their own container or select one from the funeral home. The cost for the service does not include the container unless stated otherwise. Although some funeral homes state that the cost of their basic services is included in the cost for immediate burial or direct cremation, what they really seem to mean is that the cost of the basic services provided is included proportionally.
The least expensive cost of immediate burial was $1,100 (McCollom-Myers) and the most expensive was $4,445 (Dunbar, Devine Street & Woodrow Street). It is also difficult to understand why there is a difference of $1,830 between an immediate burial done out of Dunbar’s Devine Street location and an immediate burial done out of their Hard Scrabble Road location. The average cost was $2,480.
Direct Cremation
Direct cremation has become an increasingly popular choice. In the first decade of the 21st century the national cremation rate has increased from 26.17 percent to 40.62 percent, although rates are lower in southern states such as South Carolina. (NFDA, 2012)
In comparing the prices for direct cremation one must keep in mind that some providers state the price of the cremation itself is NOT included while others state that cremation is included if relevant. Aside from the fact that repeated inquiries have yet to produce any explanation as to how cremation could ever be irrelevant to cremation, this strange practice can be traced to a sample GPL in a business guide (Complying With the Funeral Rule) provided by the FTC, but neither they or the industry seem to be able to explain it. Some of our respondents specifically state that the cost of cremation (itself) is included, but others fail to mention whether it is or not.
For years we (FCASC) had been asking the state regulatory agency, the Funeral Service Board, to require their licensees to correct this misleading practice, but they had declined to do so. But, as with the language regarding embalming, this should have changed as providers begin to understand that the FTC has changed the requirement. The Funeral Rule now (April 2015) eliminates the “cremation, if relevant” language. Providers must either include the words “and cremation” or explain that an “…added crematory charge will be estimated or itemized in the Statement of Funeral Goods and Services Selected.”
As with the case of embalming, the BFS decided to communicate this information to their licensees on the FAQ pages of their website: http://www.llr.sc.gov/POL/Funeral/index.asp?file=faq.htm
Q. The Federal Trade Commission (FTC) guidelines for General Price Lists (GPL) include a line that says, “cremation if relevant,” under the line for direct cremation charges. What is the “cremation if relevant” line for?
A. If you own your own crematory, you should put all of your charges in the direct cremation line, but some funeral homes send their cremation cases out to crematory since they do not have their own. For funeral homes that must outsource cremation, you may want to add the cost of the cremation in the “cremation if relevant” line.
There is, however, no “line for direct cremation” on the FTC’s guidelines and the FTC makes no reference to such a line in their instructions.
On March 17, 2016 the BFS sent out an “e-blast” to their licensees with a revised Q and A segment:
Q. Is it true that the Federal Trade Commission no longer requires the phrase, “cremation if relevant,” on the General Price List under direct cremation?
A. Yes. The Federal Trade Commission, in its latest “Complying with the Funeral Rule,” which was published in April, 2015, no longer includes the language “cremation if relevant,” under direct cremation on the General Price List.
As with the BFS directions on embalming, this does not correctly state the instructions of the FTC, which called for an elimination of the “cremation if relevant” language.
The prices for Thompson, the provider with the highest charge for direct cremation ($3,325) and Holley, the provider with the lowest charge for direct cremation ($795), illustrate the importance of the Funeral Rule. While Thompson includes the price of the cremation Holley fails to mention whether it is included or not. Others who do not mention whether the charge includes the cremation are Bostick-Tompkins, Dicks, and McCollom-Myers. Good Shepherd, Jones, and Leevy’s, continue to use the bewildering “cremation, if relevant” language. What this all means to the consumer is that in these latter instances it is important to inquire whether the cost on the GPL includes the cost of cremation.
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The Funeral Consumers Alliance of South Carolina, a not-for-profit consumer education and advocacy organization that is one of approximately 100 local affiliates of national Funeral Consumers Alliance. (www.funerals.org) We have released the results of each of our surveys to the media, distributed them to members of FCASC and to the public (upon request), and presented them to the state regulatory agency, the Board of Funeral Service.
The analysis of the data and writing of this report was done by Dr. Gere B. Fulton, President of the FCASC Board of Directors.
Recommended sources of further information:
Caring for Your Own Dead in South Carolina, a pamphlet available from the Funeral Consumers Alliance of South Carolina, www.scfunerals.org.
Complying With the Funeral Rule, Federal Trade Commission, April (2015).
https://www.ftc.gov/tips-advice/business-center/guidance/complying-funeral-rule
FTC Facts for Consumers, Paying Final Respects: Your Rights When Buying Funeral Goods & Services, Federal Trade Commission, May (2007).
Funerals: A Consumer Guide, Federal Trade Commission (undated).
All of the above may be obtained from the FTC website at http://www.ftc.gov/bcp/menus/consumer/shop/funeral.shtm
The Funeral Director’s Guide to Consumer-Friendly General Price Lists, (2007). Available free at: http://www.funerals.org/affiliateresources/cat_view/48-affiliate-resources-/70-funeral-price-survey-instructions-and-help
Green Burial: Environmentally Friendly Burial, a pamphlet available from the Funeral Consumers Alliance of South Carolina, www.scfunerals.org.
Harris, Mark, Grave Matters: A Journey Through the Modern Funeral Industry to a Natural Way of Burial, New York: Scribner (2007)
Slocum, Josh and Lisa Carlson, Final Rights: Reclaiming the American Way of Death, Hinesburg, VT: Upper Access, Inc. (2011). Available at www.funerals.org
September 2016
FCASC changes course on membership.
At its meeting on April 18, 2011, the FCASC Board voted to drop the membership fee that used to confer lifetime membership for a single payment of $35 for an individual and $50 for a couple.
Instead, we will add to our mailing list, as a Friend, anyone who desires to receive educational information on funeral matters. Rather than collect membership fees for operating income, the FCASC will rely on donations from those who wish to help support our work.
Be a Friend of the FCASC. You can join the mailing list simply by sending your name, mailing address, and email address to:
Mailing List
Funeral Consumers Alliance of SC
2701 Heyward St.
Columbia, SC 29205
A form for joining the mailing list can be found here.
By becoming a Friend, you will receive a newsletter twice a year, an invitation to our annual meeting, notices of educational workshops, and periodic surveys of funeral home prices in South Carolina. Since we will be relying on donations, you also will receive occasional requests for financial contributions. We thank you in advance for your support.
4/25/2011
For contact information, click here.
FCASC Ends Cooperative Agreements
Since its founding in 1993, the Funeral Consumers Alliance of South Carolina, following a
model common to memorial societies, has maintained “cooperative agreements” with two
Columbia funeral homes. Under those arrangements, cooperating funeral homes have
agreed to give FCASC members discounted prices on funeral services. More recently,
however, the national FCA has been encouraging its affiliates to adopt a more educational
and public-service role, rather than serving as “buyers’ clubs” for their members.
Following that trend, the board of the FCASC voted unanimously on July 12 to end its
cooperative relationships with funeral homes. That decision had nothing to do with the
quality of service offered by the two establishments, but the board thought that
continuing those relationships was problematic for several reasons.
The FCASC’s mission is state-wide in scope, yet the board had relationships only with
Columbia funeral homes, meaning that the benefits were accessible only to members
living in the Midlands. Furthermore, the discounted prices those homes offered to
members were higher, sometimes considerably higher, than the regular rates offered by
many of their competitors in the greater Columbia area. Using FCASC price surveys,
members could easily find less expensive arrangements without being lured by the offer of
a discount.
By publicizing the cooperative agreements and discounts, the FCASC was, in effect,
driving business to two companies at the expense of their more economical competitors.
Doing so seemed counter to the FCA’s mission, which is to protect the interests of the
funeral consumer.
Furthermore, by having those agreements, the FCASC appeared to be giving special
endorsement to the two funeral homes, even though its volunteer board was unable to
conduct regular inspections of their services. The FCASC was exposing itself to possible
adverse publicity if those homes should come under public criticism. The board concluded
that it should not be associated in any way with funeral businesses. Instead, it should
focus on educating consumers and protecting their interests in dealings with the funeral
industry.
* * * *
model common to memorial societies, has maintained “cooperative agreements” with two
Columbia funeral homes. Under those arrangements, cooperating funeral homes have
agreed to give FCASC members discounted prices on funeral services. More recently,
however, the national FCA has been encouraging its affiliates to adopt a more educational
and public-service role, rather than serving as “buyers’ clubs” for their members.
Following that trend, the board of the FCASC voted unanimously on July 12 to end its
cooperative relationships with funeral homes. That decision had nothing to do with the
quality of service offered by the two establishments, but the board thought that
continuing those relationships was problematic for several reasons.
The FCASC’s mission is state-wide in scope, yet the board had relationships only with
Columbia funeral homes, meaning that the benefits were accessible only to members
living in the Midlands. Furthermore, the discounted prices those homes offered to
members were higher, sometimes considerably higher, than the regular rates offered by
many of their competitors in the greater Columbia area. Using FCASC price surveys,
members could easily find less expensive arrangements without being lured by the offer of
a discount.
By publicizing the cooperative agreements and discounts, the FCASC was, in effect,
driving business to two companies at the expense of their more economical competitors.
Doing so seemed counter to the FCA’s mission, which is to protect the interests of the
funeral consumer.
Furthermore, by having those agreements, the FCASC appeared to be giving special
endorsement to the two funeral homes, even though its volunteer board was unable to
conduct regular inspections of their services. The FCASC was exposing itself to possible
adverse publicity if those homes should come under public criticism. The board concluded
that it should not be associated in any way with funeral businesses. Instead, it should
focus on educating consumers and protecting their interests in dealings with the funeral
industry.
* * * *