More thoughts for the FSCSR to ponder on

As today’s meeting of the Funeral Service Consumer Standards Review Working Group B (the Transparency Working Group) gets underway, we are delighted to share the thoughts of another respondent to the invitation to comment issued by the FSCSR on the Friday before the Bank Holiday weekend.

Today’s contribution is from Fran Glover and Carrie Weekes of A Natural Undertaking.

NB: The as yet unpublicised members of the FSCSR Transparency Working Group may wish to consider some of the questions posed below.

Dear Mr Shand Smith

We were hoping to get this email to you by Friday 30th but as a small independent funeral director we have been incredibly busy.

We write in relation to the call for views from non-trade association affiliated funeral directors. We were alerted to this by two of the FSCSR members, Poppy Mardell and Sarah Jones, and whilst we are members of SAIF feel we have some questions about this group that we would like to ask independently.

We are a progressive and passionate funeral director, working hard to provide a high quality and personal service to the people who come to us. We welcome the government review of the funeral industry and the independent perspective that they will bring.

For ease and the sake of brevity we list our questions below:

  • Can you help us understand what this group hopes to achieve that is not already within the remit of the government appointed CMA team, and why it would be doing this work ahead of the CMA timetable for delivery or any recommendations that come out of it? This feels confusing for someone in the industry, let alone a member of the public who may not be quite so familiar with what is currently taking place.
  • We would like to understand how the group plans to deliver an impartial, independent response where most members of the steering group are heavily invested in any remedies which will be prescribed? (Key members being NAFD, SAIF, COOP and Dignity who all manage or deliver a large proportion of funerals currently)
  • We would also like to understand where the legitimacy of this group originates. Our understanding is that this is not a government appointed group, so where does the authority to call itself a consumer review group stem from?
  • Assuming a funeral director expresses interest in taking part, we would like to know what that actually means? Will those funeral directors have a seat at the table to discuss the challenges, or is it merely to ‘review’ and ‘comment’ upon the work that the FSCSR discuss? To what extent would their views be incorporated into any remedies?

We would also like to comment on the timeframe given for this call out – if the request for views is genuine then it would seem that an 8 day period over a bank holiday is way too tight a timeframe for people to hear about it, consider their position and then respond. Our own constraints and workload have meant that we have been unable to reply with a considered response within the stated timeframe.

  • Finally, since this is named as a consumer review group, it would be good to understand how and where the views of the consumer are represented within this group? We understand that consumer bodies will be consulted but surely there should be an independent consumer body on the steering group, working on this from the outset?

The changes that could take place as a result of any work being done in this arena are so important that we hope you therefore understand why we are asking these questions, and we look forward to hearing your responses.

Best wishes

Fran Glover and Carrie Weekes

Thoughts from an unaffiliated funeral director (ii)

Here’s another submission that squeaked in before the deadline set by the self-appointed Funeral Service Consumer Standards Review group to hear the views from funeral directors who choose not to belong to a trade association – from the fabulous Jennifer Uzzell, occasional contributor to the blog and one of the directors of Saint & Forster Funeral Directors Ltd in Darlington:

“Dear Mr Shand-Smith

In response to your request for views from funeral directors who are not affiliated to the trade organisations and who would like to add their views to your consultation, please see below. 

I am one of the directors of Saint and Forster Funeral Directors Ltd. in Darlington in the North East of England. 

The company was set up by my partner Keith Munt and myself 8 years ago

We are not members of a trade organisation as it is our belief that these organisations exist in order to promote the interests of their client businesses and that, where a difference exists, they will promote the interests of their clients above those of the bereaved. They are, therefore, not in a position to represent the interests of the bereaved, or to administrate any form of regulation that may be introduced. 

I note with concern that the FSCSR appears to be presenting itself as the body that represents the funeral service in general and will, in fullness of time, be responsible for regulation. As far as I can see, the FSCSR has no remit or authority to do this, and it seems to a number of us that you are positioning yourself to defend the actions of the larger corporations, even when their performance is very poor; and to regulate against the interests of small independent and unaffiliated companies even where they are ethical. Our failure to join any of the associations is ethically motivated and is in no way because we have anything to hide, or because we do not feel we would meet the criteria.

I also question what your motivation was in allowing such a small window of opportunity for unaffiliated FDs to reply to your request for their views. Either you are deliberately trying to limit the number of responses you receive, or we are very much an afterthought. Neither possibility is particularly encouraging. 

Much that has been presented recently, in terms of the need for regulation, has been about the need to protect the public from ‘cowboy’ ‘unqualified’ practitioners who are setting up businesses across the country. I do not doubt that a small number of such businesses exist. However, as the evidence presented by my colleague Louise Winter (with whom I am in entire agreement, and whose letter to you I attach below in its entirety) suggests, the majority of instances of malpractice or poor quality service seem to be traceable to larger corporations rather than to smaller independent companies. 

You ask specifically for my views on regulation, which I give below. 

I welcome regulation of the funeral service, with the following provisos:

  • Any regulation must be overseen by a body that can be shown to be truly independent. This should not be the trade organisations, the FSCSR, or any other body with a vested interest. 
  • Complaints should be handled by an independent ombudsman as they once were
  • Any system of regulation should not be limited to process (how bodies are stored, transported etc and how FDs are trained; important as these things are) but should also include an ethical element aimed at preventing the exploitation, financial or otherwise, of the bereaved. 
  • FDs should not be required to have a qualification, particularly if it is devised, administered and awarded by the NAFD. This is, again, a vested interest and also, to my knowledge, contains training that would be at odds with my idea of good practice. There is a disturbing movement in the world in general at the moment towards the perception that academic qualification with increasingly low standards are a guarantee of quality. 
  • With regards to the above, I would like to see FDs or businesses licensed according to what they can demonstrate that they can do in a system similar to the old NVQs, rather than requiring them to acquire an additional qualification. Again, this license must be administered by a truly independent body with no vested interests. 

Many companies, such as mine, have been set up by people with entirely adequate facilities. training and experience, but with a new vision of the quality, standards and emotional intelligence that the public should be entitled to expect from us. Any regulation must enable those companies to continue and to thrive and to provide a choice to the public. 

To conclude, I state again that I am entirely in agreement with Louise Winter of Poetic Endings, whose letter I attach in full here.  

Kind Regards, 

 

Jennifer Uzzell

 

Office Manager

Saint and Forster Funeral Directors Ltd

 

Letter to Lewis Shand Smith – 29th August 2019

The new kid on the block has gone

 

Remember these guys?

The National Federation of Funeral Directors – they of the combative Managing Director who regularly took umbrage with Charles – have a look at blog posts from the past here and here and here and here to refresh your memory.

They were the self styled “Consumer Driven Funeral Industry Governing Body committed to “increasing consumer choice and cost transparency within the funeral industry; and to the modernisation, development, and on-going commercial welfare of its funeral director and subsidiary business Members.”

And their mission was to “modernise, develop, enhance, and protect the funeral industry, and to provide consumers with a greater, more informed, choice when faced with the costly and emotional task of arranging a funeral.”

Have a click on this link:

They’ve gone. Vanished. Vamoosed.

The NFFD is no more.

So, if you come across this symbol on a funeral director website then it sadly doesn’t actually mean anything.

 

We’re trying to work out what’s happened, not least because the NFFD strongly endorsed Safe Hands Funeral Plans – have a look here.

We bet Dr. Hilary Jones is feeling a bit silly now.

Thoughts from an unaffiliated funeral director (i)

 

After yesterday’s deadline for unaffiliated funeral directors to make contact with the FSCSR came and went, we thought we would share some of the thoughts from some of the people who managed to scrabble together a response to the request within the time frame offered.

Given that all responses were received by the FSCSR Secretariat, which is operated by the two funeral trade associations, these responses are hardly confidential, and all concerned are happy for their comments to now be in the public domain.

We begin today with the letter sent by Ru Callender, from The Green Funeral Company

Dear

My partner and I have been independent self taught undertakers and celebrants for the past twenty years. We run The Green Funeral Company.

We set up as a direct result of the dissatisfactory funerals I was subjected to throughout my childhood and twenties at the hands of the very corporate organisations which appear to be covertly represented here.

I discovered the work of The Natural Death Centre charity, which back then was a radical movement to empower the public and force funeral directors to show a little transparency.

It taught me, as you all know but I doubt much of the public do, that a family are not required by law to use a funeral director. They can do pretty much everything themselves, and we have indeed advised and supported many families to do exactly this, as well as providing a much more integrated and participatory service for the families who do chose us.

The reason this is possible is simple; dead bodies are not complicated, or as much of a health hazard as is generally perceived. You can disrespect them, but you cannot hurt them.

The real skill of funeral directing lies with how you treat the living.

 And no amount of spot checks or being part of a trade body will ensure that the living are treated well. This requires emotional intelligence, which is teachable to a degree, but is unlegislatable.

We believe regulation will destroy some of the best funeral directors in the country while appearing to ‘solve’ a problem in the eyes of the public, that doesn’t actually exist.

The problems that actually exists in the funeral industry are:

An emotional disconnect between individual funeral workers and the families they are serving, mainly in large corporate chains, and a lack of support for these workers when it comes to the complexities of the psychological stresses involved with the job.

A financial beholdenment to shareholders within the corporate sector above all else.

 The overmarketing of funeral plans as a tactic to secure future business by the large corporations forcing smaller funeral directors to follow suit in a manner which brings the moral tone of our work down in the eyes of the public through tasteless emotionally bullying adverts on daytime television.

 And most obviously, our crematoriums are with a few very notable exceptions no longer fit for purpose, environmentally, practically, spiritually or financially.

They have inappropriate outdated designs and short time slots and are mainly worked around the on time traffic of too many funerals per day.

These are the issues which are affecting the quality of funerals in the UK today.

Let me elaborate on my first point, about the emotional labour required to do this job properly.

By disconnect I mean that often with the larger chains, the people who pick up the body are not the same as the person who makes the arrangements, who is not the same as the person officiating on the day.

This lack of continuity reduces the dead person to a logistical problem, storing them in large central warehouses in identical coffins, and takes any emotional and narrative stake away from the people at the sharp end of the job.

They are as much a victim of the lack of joined up thinking as are families.

With no real training in the dynamics of shock, grief and bereavement and the impact these have on funeral workers, you have people on very low wages collecting bodies in the middle of the night walking into people’s houses in the middle of the night to collect their dead father asking “Where is it?” This happened to friends of mine.

We are not members of any trade organisation for many reasons, but largely because trade organisations in any industry largely exist to serve their members, while giving the public a veneer of accountability.

The funeral trade organisation offer cheaper insurance, a few quid off this and that, and are completely obsessed with selling pre paid funeral plans, most of which don’t significantly help the funeral director.

And the majority of the members of the largest trade body, the NAFD, are from the various Co-op’s who dominate the agenda to suit them, and use their enormous clout to produce endless press releases about changing trends in funeral music ignoring the bigger changes that have been created by small radical undertakers like ourselves,

When we make a mistake, as inevitably in the past twenty years we have, the buck stops with us. We are the complaints department as well as everything else. We are accountable, and own our mistakes and rectify them without the need for an intervening trade body. This is simple good and ethical business. People stand and fall on their reputation.

Don’t get me wrong, funeral directing is an extremely hard job, physically, psychologically and emotionally, and if you are doing it and it is not your vocation, then you will burn out.

Obviously we do not accept the widespread cultural belief that funeral directing is somehow exploitative, there are lots of fabulous undertakers, both independent and within some of the larger chains quietly and sincerely giving of themselves, but there are enormous corporate behemoths hiding behind a lot of good will and misunderstandings of the general public, and this regulation will only benefit them, while punishing the cutting edge creativity of many independents.

Forcing regulation on the industry will shut the door on ordinary members of the public participating in their own bereavement experience, and will close down the visionaries of this industry, all for the sake of convincing the public that they are protected, and has been tried by vested interests in the industry for over 100 years, with the same agenda; the shutting down of small independents.

I’m late, I’m late, for a very important date

 

Eight days ago (three of which were over a bank holiday weekend), funeral directors who don’t belong to either of the funeral trade associations were invited to get in touch with the Funeral Service Consumer Standards Review – the self appointed body founded by Dignity PLC that is looking at ‘quality, standards and outcomes for funeral service consumers’.

The independent chair wrote on the FSCSR website “If you are a member of SAIF or NAFD, then they have a seat at the table to represent your views – but we really want to make sure that non-trade association affiliated funeral directors also have the opportunity to express their thoughts.

So, if you are a funeral director who is not a member of a trade association and would like to contribute your views on how to improve funeral care (or express your specific concerns about current standards, or possible regulation in the industry), then please get in touch with contact@fscsr.co.uk by Friday 30 August.”

This invitation was also tweeted out to the 71 followers of the FSCSR account. 

So, unless non trade association affiliated funeral directors happened upon the FSCSR website (why would they?), or followed the FSCSR Twitter account (followers seem to be organisations, heads of organisations and a smattering of individuals) then non trade association affiliated funeral directors are largely, we would guess, unaware of this opportunity to have their voices heard by those who comprise the FSCSR.

This is unfortunate.

Because in due course, and before the CMA comes up with their findings from their Market Investigation into the funeral sector, the FSCSR will be seeking “to identify the extent to which the recommendations of HM Inspector of Funerals could be usefully implemented as a statutory system in the rest of the United Kingdom. The FSCSR’s findings and any recommendations will then be presented to Government stakeholders.”

Hmm.

The self appointed group has set up two working groups – one of which has been working for some time on ‘a) a robust and comprehensive code of practice for the funeral directing profession (output 1); and b) an agreed list of premises inspection requirements, to be enforced by both major trade associations (Output 2), and the other particularly focusing on ‘how transparency in relation to services offered, the standard of those services and pricing could be improved‘. (This second FSCSR group, the ‘transparency working group’ has not as yet identified the members who are sitting on it. Which is ironic)

Both working groups are chaired by the former Inspector of Funerals in Scotland, Natalie McKail.

Ms McKail actually left post in June this year.

The post of Inspector of Funerals in Scotland is currently vacant.

There is no HM Inspector of Funerals in England, Wales or Northern Ireland. And now neither is there one in Scotland.

The citation of Ms McKail’s role as a member of the FSCSR Steering Committee in this document  on the FSCSR website, dated July 2019 and noting her as ‘HM Inspector of Funerals’ is therefore factually incorrect and somewhat misleading. 

Anyway, we digress.

Non trade association affiliated funeral directors who are tempted to get in touch with contact@fscsr.co.uk might be interested to note that they will be in fact be sharing their thoughts with the FSCSR Secretariat, which is helpfully being provided by the two funeral trade associations which they have chosen not to join.

(We know of at least one non trade association affiliated funeral director who was not willing to be identified in their letter to the independent chair of the FSCSR as they were concerned about confidentiality, given that the e-mail was landing in an inbox at NAFD).

They might also want to get their skates on. As today is the 30th August and the deadline set for contacting the FSCSR.

Despite the group having been formed in November last year, and the work to attempt to put right the mess that is funeral world having been ongoing since then.

Or, they might do exactly what we have done, and make contact with the CMA directly to express their thoughts about the funeral sector in general, and why they have not chosen to be part of a trade association.

One progressive funeral director has done both – you can read the letter that Louise Winter sent to the independent chair of the FSCSR yesterday here: Letter to Lewis Shand Smith – 29th August 2019

Go on, make a cup of tea and have a read.

You’ve got less than 12 hours to respond anyway.

And we think Louise has said it all.

The CMA is looking at informal arrangements

 

Last week, some of Team GFG hosted an extremely interesting meeting in central London, details of which will be shared in due course.

Among our guests were a number of representatives from the Competition and Markets Authority, the body currently carrying out the market investigation into the funeral sector. 

They have asked that we share the appeal below for any information that blog readers might have:

“Do you know of any organisations (care homes, hospices, hospitals etc.) that have a formal or informal arrangement with a funeral director which means that the funeral director provides services without the consent of the deceased’s family?

This could, for instance, include arrangements for the deceased to be transported to a funeral director’s premises on the organisation’s instruction, rather than that of the deceased’s family.

If so, the Competition and Markets Authority (CMA) is interested in hearing from you.

The CMA would like to understand how common these arrangements are. It may then make appropriate follow-up enquiries with the organisations concerned to explore the impact these arrangements may be having on customers.

If you would like to help the CMA, please follow the link to a short Survey Monkey questionnaire, prepared by the CMA, to provide details of these organisations.

Responses will be anonymous, will only be seen by the CMA and will be held securely and confidentially.  

Clicking on the following link (which will be open until Friday 6 September 2019) will take you to the CMA’s questionnaire: 

https://www.surveymonkey.co.uk/r/9S3D6NS 

Consistent and transparent

 

Did you see this article in Monday’s Times?

Restaurant style ratings to combat funeral rip-offs’, the headline screams.

It’s behind a paywall, but we can precis it for you. Here’s a direct quote:

“Funeral directors are to be given restaurant-style ratings as the industry battles accusations of over-charging and inconsistent standards.

Classifications based on clarity of prices, conduct of funerals, vehicles and staff training, and mortuary and refrigeration facilities will be issued to thousands of funeral parlours based on inspections of their premises.

Those given the lowest ratings are likely to be ‘reported to their local authority for investigation under consumer protection law.”

The Times article references the new group appointed by the industry to address inconsistency in standards and the lack of transparency in fees, which, it states, is going to produce ratings that funeral directors would have to display in their premises and on their websites, similar to those issues by the Food Standards Agency for restaurants, hotels, supermarkets and care homes.

“Its chairman Lewis Shand Smith, former head of the dispute resolution body Ombudsman Services, told The Times it wanted a tougher code for practices such as collection of the body, care of the deceased and conduct of funerals. It also plans a charter mark system and common inspection regime for the sector in England.

“There is an awareness growing that standards may not be the same across the industry,” Mr Shand Smith said. “The industry itself is concerned that the few can bring the whole industry into disrepute and it is time to correct that.”

It’s unfortunate that the first main press coverage of the work of the FSCSR appears to have got its facts almost completely wrong.

Yesterday, an e-mail was sent out by the FSCSR Secretariat to those involved in the various working and steering and reference groups.

It said: “The article states that the FSCSR will “produce ratings that funeral directors would have to display in their premises and on their websites, similar to those issues by the Food Standards Agency for restaurants, hotels, supermarkets and care homes”.  This is not entirely accurate.

To be clear, no decisions about final project outcomes have yet been made. The possibility of recommending a ratings system may well be discussed by Working group B (the transparency working group) when it meets for the first time on 2 September but nothing has yet been discussed or agreed by any FSCSR working group or committee.”

Who is this FSCSR, we hear you ask?  The Funeral Service Consumer Standards Review? Who are these people? And how can they have had such a catastrophic first introduction to the public?

Readers of the Funeral Director trade magazine will have had a sneak preview of the FSCSR last month. And they have a website, which you can find here.

Names of those on the FSCSR Steering Committee and the FSCSR Working Group A are listed, although, ironically, the members of Working Group B, tasked with looking at transparency, are not yet in the public domain. This is apparently because of GDPR.

 You can read all about the group in their ‘Background Document’. The timetable looks like everything has happened in just the last couple of months, although we understand conference calls and work have been underway since January this year.

Oh, and as yet, no correction to the Times article appears on the new FSCSR website, even though they have a News tab. We’re sure it will, if the facts are so wrong.

Anyway, back to Mr Shand Smith, the independent chair of the FSCSR.

He appeared on BBC Radio Kent earlier yesterday, not exactly refuting the McDonalds’ style star system idea – listen here from 1:47.

When asked about the star system, he said, “I know the suggestion has been made, and the organisation that I’m kind of leading at the moment, we are looking at various ways of making the standards transparent to the public… these discussions are at a very early stage.”

And about the FSCSR: “They started this at the end of last year, they came together and recognised that there was a need, and the industry itself was raising questions about how it could do things better, and so they got together in December and decided to carry out an inquiry that would lead to a number of recommendations. And it’s widespread, it’s the two main trade associations, but a lot of independents as well, people who have an interest in the industry.”

OK, let’s clear up a few things here.

The FSCSR came into being as a direct result of an initiative by Dignity PLC, who are super keen on being seen as good guys by the CMA. (And by their shareholders too probably, given that the share price has now sunk below £5, somewhat of a drop from the 2016 high of £28.71. Luckily, Dignity directors sold £15 million worth of shares before the slump began – see our blog post here )

The inaugural roundtable meeting at Westminster last December was organised and funded by Dignity, as referenced in the Chief Executive’s statement on page 18 of their Annual Report and Accounts 2018: “We therefore continue to lead the call for change as we seek a regulated market that will be good for clients and society. Dignity is working collaboratively with industry partners and other stakeholders to improve standards across the sector. At the end of 2018 we initiated a round table discussion and invited the CMA and other representatives from the funeral sector, co-operating together to try and find a solution.” 

And far from there being a ‘lot of independents’ involved with the FSCSR, as cited by Mr Shand Smith yesterday on the radio, there are just two independent funeral directors, both invited by a phone call from a representative from Dignity at the last minute before the December meeting, when it was suddenly realised that no unaffiliated independent funeral directors had been asked to participate.

We have been assured by the one of the NAFD representatives on the FSCSR that ‘all Steering Committee and working group members were appointed independently, either by Lewis (in respect of Steering Committee members), the Steering Committee and the Working Group Chair, Natalie McKail’, and that ‘both FSCSR Chairs are completely independent and that all participants appear to have come to this project with the right intentions.’

This is good to know.

We know that both of the independent funeral directors invited to take part in the work of the FSCSR have done so with the absolute best of intentions, and with the hope of positively influencing the work under way. They have also both made it very clear to the FSCSR that they represent only themselves, and not any other independent funeral business.

And we also know that both independent funeral directors called strongly from the start for the both Good Funeral Guide and the Natural Death Centre charity to be included in the discussions.

One would have thought that inviting the two organisations that actively work on behalf of bereaved people to inform a group brought together to look at things from the perspective of ‘funeral consumers’ would have been a bit of a no-brainer.

But no invitation was forthcoming.

The independent funeral directors continued to press the case for the GFG and the NDC during calls and by e-mail over the next seven months  We know this because we stayed in contact with them.

We waited. And waited. But we heard nothing.

Then, on August 1st, an e-mail arrived from someone at the NAFD, with an attached letter written on behalf of Mr Shand Smith. We had been invited to the party at last.

We were asked to take a place on the FSCSR Stakeholder Reference Group, (the SRG) with the task of ‘informing, guiding and underpinning’ the work of the FSCSR.

We had a think about it, and then we politely declined, observing that ‘For the Good Funeral Guide to have been invited at this late stage to sit on a ‘Stakeholder Reference Group’ with a stated purpose of informing, guiding and underpinning work which has been underway for months can only be an afterthought. We would expect that ‘informing, guiding and underpinning’ a project would be a requirement from the start.’

We also pointed out, “The issues under scrutiny by the CMA have arisen entirely due to poor practice within the funeral sector, and we consider it is the sole responsibility of those party to the poor practice to attempt to redress this.

The Good Funeral Guide has been wholly critical of poor practice and lack of transparency in the funeral industry for many, many years, and we see no merit in our being involved in the sector’s attempts to pre-empt any recommendations in the CMA’s Final Decision report expected next year.”

In a comprehensive e-mail response received yesterday from the Secretariat of the FSCSR, we were advised that the door was still open for us should we change our minds, and that “the fact that GFG was not approached to sit on a working group does not mean that your opinion isn’t valued by the project… Those making working group appointments simply had to make decisions about who would bring most value to the groups based on the information available to them.”

And

“I do hope you will take us up on this offer. It would be really good to have the benefit of your experience and perspective on the SRG.”

We appreciate the appeal to re-consider, and assurance of independence and lack of pressure or influence, and that there was “no intention of claiming that SRG members have somehow endorsed the FSCSR project. In the spirit of transparency, we simply want to list the names on the FSCSR website as consulted parties. We would also be happy to openly publish, unedited, any written GFG response to FSCSR documents on the FSCSR website.”

But, our decision stands.

There are plenty of people already working on this. We are content to wait and see what they come up with.

Also, the FSCSR budget appears to be limited – for the work involved at least. We’ve been told more than once that “this is a project with a limited budget and a very ambitious timeframe.” In fact, this was given as the reason for not involving the GFG from the outset.

Despite the group being “funded by the funeral industry through the NAFD, with additional financial support from Golden Charter, Funeral Zone and Ecclesiastical Planning Services.”

One would have thought that for such apparently imperative cross sector working, adequate funding would have been found from the organisations involved. It can’t be costing that much to have a few meetings and create a website.

Oddly, the Times on Monday wrote about the “£2 billion-a-year funeral industry” and noted that “the industry has agreed to spend millions of pounds to publicise the charter marks and ratings system for funeral directors who signup.”

Millions of pounds to publicise something that’s been put together on a limited budget with a very ambitious timeframe?

Perhaps they got that all wrong too.

Hospice Funerals – an update

 

Back in November 2017, a bright new star rose in the world of funerals.

St. Margaret’s Hospice in Somerset joined forces in partnership with Howard Hodgson’s Low Cost Funerals to form Hospice Funerals LLP in what they described at the time as ‘one of the biggest developments in the funeral market‘.

According to the same announcement, entering the funeral market was the brainchild of Ann Lee, Chief Executive of St. Margaret’s Hospice.

Encouraged by Mr Hodgson, Ms Lee shared her vision of a franchise operation with attendees at the 2017 Hospice UK conference, and in January 2018 the much heralded first Hospice Funerals branch was opened in Taunton.

Here at the GFG, we had some misgivings about the concept, and we wrote letters to the trustees of all hospices in the UK laying out our concerns – you can read the letter here.

It may be that our warning was heeded, or it may be that trustees of other hospices already shared our concerns about the wisdom of St. Margaret’s Hospice’s vision for the future – either way, in early 2018 Hospice UK issued a statement about their position on the concept, and it appears that there were no takers for the idea of getting on board with the Hospice Funerals scheme.

Notwithstanding, the enthusiasm continued, and in a progress report on March 1st 2019, Ms Lee noted “After a successful first year for our Taunton funeral home, we are recruiting to cope with growing demand and are already working on expansion plans to reach more people in our patch.

St. Margaret’s Hospice Funerals is on track to become an established revenue stream for our charity.” 

Is it?

Let’s look a little more closely.

A browse through Hospice Funerals LLP’s filing history at Companies House shows a flurry of appointments, cessations and terminations of appointments, with Low Cost Funerals terminating their involvement as of 28th March this year.

Hospice Funerals LLP now has a somewhat circular list of officers – Hospice Funerals Trading Ltd, and St. Margaret’s Funerals Ltd.

Both HFTL and SMFL list just one officer – Hospice Funerals LLP. Follow the links and you get back to where you started. No names, no pack drill.

It looks like the partnership between St. Margaret’s and Low Cost Funerals didn’t make it to the sunny uplands of the ‘marriage made in heaven‘, as it was described in a comment when the franchise scheme was launched. Nor does it appear to have been ‘genius‘, as described by a CEO of another hospice.

The micro company accounts of Hospice Funerals LLP can be viewed here. We had to read them twice to make sure we had understood the numbers correctly.

In the period to 31 October 2018,  it appears Hospice Funerals LLP spent an eye-watering amount of £329,567 on administrative expenditure! 

This figure includes £41,731 on conference costs, £71,191 on legal costs, £36,342 on travel, accommodation and subsistence and £23,848 on marketing.

The net profit for the period is shown as (£320,862). For anyone unfamiliar with accounting, the brackets indicate a minus number. So, a loss.

These accounts for Hospice Funerals LLP were published on 31 July 2019.

On the same day, St. Margaret’s Hospice announced plans to close the in patient hospice ward in Yeovil.

The Yeovil unit was built after an appeals committee was founded to raise £4.5 million in 2001. It originally had 16 beds and was officially opened in 2004, complete with state of the art facilities and equipment. The people of Yeovil and the surrounding areas have reacted with fury, calling the decision ‘disgusting’. A Facebook group called “Save St. Margaret’s Hospice Yeovil’ has attracted over 13,000 members in a week.

Full details of the planned closure can be found here, along with background information explaining why the hospice was unable to offer staff a cost of living pay increase earlier this year.

It gives us no pleasure to bring you this update today.

 

Called to account

  In a blistering attack on the funeral industry in America this week, Michael Waters wrote in Washington Monthly:

‘The cost of death services has long exasperated Americans. In December 1856, a New York Times editorial argued that “nobody that is not comfortably off in this world’s goods can afford to die” because “to pass into the hands of the undertaker is positive bankruptcy.”

A century later, Bill Davidson noted in a 1951 Collier’s article that “while the cost of living has risen 347 percent in the last 122 years, the cost of dying has rocketed as much as 10,000 per cent.”

Not much appears to have changed in the intervening years since that 19th century New York Times piece, either in the USA or here in the UK. The high cost of funerals is a regular subject of newspaper columns and articles and the causes much debated.

The finger of blame is frequently pointed at the larger players in the funeral sector, while they, in turn justify their higher prices by claiming to provide better quality service. Indeed, a whole report emphasising quality and standards was commissioned by Dignity from Trajectory last year, making much of the fact that price was far less important than quality of service. And Dignity’s Corporate Profile publication (downloadable here) mentions the word ‘quality’ no less than 67 times, stating bravely “Our vision is to lead the funeral sector in terms of quality, standards and value-for-money.”

Hmmm. We’re not so sure that Dignity’s quality of service is justified by the prices they charge. Which appear to vary tremendously between branches, as noted in our blog post here.

Exceptionally high quality service is offered by all of the funeral directors on our recommended list, and not one of them charge the same amount for their services as the Dignity do for an equivalent funeral.

Fortunately, as noted in a series of GFG blog posts since first mentioning it last June, the Competition and Markets Authority are currently carrying out a Market Investigation into the funeral sector, and on Wednesday this week, the first working paper was published, outlining their approach to profitability and financial analysis. 

It is unlikely to be have been met with delight at Dignity PLC which evolved from SCI ownership through a management buyout in 2002. (Yes, that’s the same Service Corporation International mentioned so unfavourably in the Washington Monthly piece; the largest deathcare corporation in North America that, according to one study, charges prices that are 47 to 72% higher than other funeral homes and cemeteries.)

Nor at Co-operative Funeralcare and Funeral Partners Ltd – named alongside Dignity as the three largest providers of funeral services in the UK, and all being treated in the same way by the CMA (much to Funeral Partners’ annoyance, as can be seen in their response to the CMA’s Issues Statement here – ‘It is simply not meaningful to include Funeral Partners as the third of a group of supposed ‘large funeral directors’ and as such, it is submitted that there is no basis on which Funeral Partners should be subjected to any remedy which is not applied to the market as a whole.’)

Detailed financial information requests (going back five years and forecasting for a further year) have been sent to all three companies, with Dignity also receiving a similar detailed request with regard to their crematoria services.

From the CMA working paper –

Paragraph 25: ‘Our market-wide profitability assessment for funeral director services will focus on two groups of firms: 

(a) The three largest providers of funeral director services in the UK, namely Dignity Plc (Dignity), Co-operative Group Limited (Co-op) and Funeral Partners Limited (Funeral Partners). In the UK, these firms have an estimated combined market share of approximately 29%, based on number of deaths.

(b) A representative sample of branches in the remaining 71% of the market, which is composed of smaller providers.’

The CMA tell us at Paragraphs 29 – 30:

‘…we propose to collect data over a five-year historical period from 2014 to 2018, for both funeral director services and crematoria services (referred to as the “Relevant Period” in the rest of this working paper).

Where our profitability analysis is used to estimate detriment and therefore the proportionality of remedies, we propose to consider whether historical (or backward-looking) profitability is a good estimate of prospective (or forward- looking) profitability. We are therefore also collecting forecast information.

The largest providers of funeral director services and crematoria services told us that as part of the ordinary course of business they forecast detailed information for one financial year ahead. We are therefore collecting forecast data for 2019, giving us a total time period of 2014 to 2019.

NB Paragraph 13 of the working paper advises: ‘The Market Investigation Guidelines (the Guidelines) state that: ‘Firms in a competitive market would generally earn no more than a ‘normal’ rate of profit – the minimum level of profits required to keep the factors of production in their current use in the long run, i.e. the rate of return on capital employed for a particular business activity would be equal to the opportunity cost of capital for that activity.’

The CMA’s sampling approach to gathering data from 100 small independent funeral companies is set out in paragraphs 86 – 10 of the paper, and takes quite a different format, acknowledging that these are ‘predominantly small (often family-run) businesses, which may not have full time accountants or bookkeepers.’

Now, we aren’t privy to figures from the Co-op or Funeral Partners, as this information is not in the public domain, but as a listed company, Dignity helpfully provides the public with updates on their success. Their annual report and accounts for 2018 can be downloaded here. And from the CMA’s own findings in their Final Report and decision on a market investigation reference:

‘6.112 It seems clear that the vulnerability of customers has been a major factor in enabling suppliers to charge high prices in the sector for the past 15 years, rather than underlying cost pressures, and it appears to us that Dignity’s pricing policies have acted as the engine of these price rises, with others in the market appearing to follow its lead.’

We’re looking forward to reading about the CMA’s findings when their forensic investigation into the figures is concluded and their Provisional Decision report is published early next year. Even with redacted numbers represented by pictures of scissors, it should be illuminating. Indeed, if we were inclined to a flutter at the bookies, we’d have a fiver on the largest providers not quite making the mark when it comes to only earning a ‘normal’ rate of profit.

The campaign is underway

This has popped up on social media by the main funeral directing trade association, the NAFD. (That’s the one that the big, powerful corporates all belong to, not the other one that represents independent funeral directors, for anyone unfamiliar with the world of funerals).

Well, well, well. It was only a matter of time.

There must have been a lot of meetings of important men in suits trying to work out what to do about a tricky problem, as outlined by Dignity CEO Mick McCollum back in early 2018. 

A report from CityWire warned, “Shares in the business are down 60% since early November, when boss Mike McCollum warned of increasing competition in the funeral space.

In this morning’s statement, Dignity said that over the last 18 months it had ‘consistently alerted the investment community as to the increasingly competitive environment in which it operates’.

‘Customers are increasingly price-conscious and in an over-supplied industry, are shopping around more,’ it said.

Increasing competition. Like that’s a bad thing in a sector dominated by three huge companies built by buying up small independent businesses and industrialising what should never have been industrialised?

Oh, sorry, the increased competition means less market share for those men in suits and the shareholders that they serve.

And so here’s their solution. More of the smoke and mirrors, as so eloquently described by a GFG Blog reader here.

Dignity PLC, (whose management are so concerned about the state of the funeral industry that they and their spouses managed to offload millions of pounds of shares just before the value plummeted by half – see here) are the new nice guys in town.

They had a go last year and we didn’t pick it up – we don’t read the Daily Mail here at GFG Towers, but there was this swipe at ‘cowboy funeral directors’ s when they put out one of the expensive reports they publish every now and then to reassure their shareholders.

We did note that ‘The key message of Dignity being the saviour of standards in the funeral industry has been planted‘ in our blog post here last summer.

But we’ve been quite busy with other stuff, so we perhaps haven’t kept as close an eye on this Transformation Plan as we should have done.

“Ask us anything”, says Andrew Judd of Dignity, in his shirt sleeves, looking super friendly. If you really want to watch it, the YouTube link is here.

OK Andrew, here are a few questions, starting off with one we still don’t know the answer to:

Why do branches of Dignity funerals within just a few miles of each other charge such different prices for exactly the same services? (Refresh your memory here about how two different communities in London appear to be charged very differing prices by two Dignity branches trading under their original names.)

And for anyone struggling to know what questions might elicit really useful information from any funeral director, here are a few that you might want to ask before parting with your money:

Who owns this business? Is it still owned by the family whose name is over the door?

Who will be looking after us and assisting with the funeral arrangements? Will it be the same person throughout? Will they come to the ceremony with us?

Who will be looking after the person who has died? Can I meet them before engaging you?

Where will the person who has died be looked after? Can I have a look at the mortuary by appointment?

Can we come and help get our relative ready for the funeral? Can we wash and dress them ourselves? Will they stay here on these premises?

Can we come and visit them whenever we want? 

Can we look after them at home and just use your expertise for advice? How much would that cost?

Can we supply our own coffin? Is there an additional charge for this? If so, how much?

Can we arrange our own transport for the coffin? Is there a charge for this? If so, how much? And why?

Can we carry the coffin ourselves? Are the costs reduced if we don’t need your staff to carry the coffin at the funeral? If so, by how much? If not, why not?

Am sure we could think of more, but please add your thoughts in the comments – got to dash this morning.