On the subject of funeral plans – your thoughts are invited

Like everyone else who responded to the Competition and Markets Authority’s consultation on whether to make a market investigation reference for the funeral market, we received an e-mail last week. The e-mail invited us to share our views on whether the said MIR should also cover the delivery of funeral services obtained via a pre-paid funeral plan.

And like everyone else concerned with the state of the current funeral market, we will be submitting our considered opinion on this matter. Which is that yes, there absolutely should be further scrutiny of the funeral sector with regard to the provision of funeral services arising from redemption of pre-paid funeral plans.

This blog has covered the subject of funeral plans on no less than 47 occasions over the years. And our opinion hasn’t changed. On the whole, and with the exception of the Good Funeral Guide Pre-Paid Funeral Plan (which isn’t like any other funeral plan we’ve come across) – we have little time for funeral plans.

We make no apology for again repeating the quote from Thomas Long in his and Thomas Lynch’s ‘The Good Funeral – Death, Grief and the Community of Care’ because it sums up pretty much what we think:

“The ‘buy now, die later’ brand of package deal has meant a lost connection between the sale of funerals and the delivery of them, and with it the loss of face-to-face accountability between buyer and seller that used to provide reliable consumer protection. Now the recipient of the services (the bereaved) and the provider of same (the funeral director) are both perilously out of the loop of the original transaction: a deal often brokered years before, between a commissioned salesperson and the now newly deceased. In such an environment there can be little real accountability.”

Notwithstanding this lost connection between the parties concerned with the funeral, in their consultation on scope of the proposed market investigation, the CMA notes the following:

‘In some respects, the position of the purchaser of a funeral plan from a plan provider may be similar to the purchaser of funeral services at need from a funeral director. In both cases, a lack of clear and comprehensive information about price, range and quality, combined with likely inexperience (as purchasing funeral plans or arranging funerals are generally infrequent purchases) mean that the customer is likely to lack the ability to assess properly the value for money of all the options offered.’

Definitely worth a closer look then.

The CMA’s invitation to offer a viewpoint isn’t restricted to just those who responded to their previous consultation, so if you have an opinion on whether the CMA should be looking at the services provided in ‘redemption of pre-paid funeral plans’, please drop them a line. You have around nine days in which to do so.

Postal address: Funerals market study team, Competition and Markets Authority, Victoria House, 37 Southampton Row, London WC1B 4AD

Email address:  funerals@cma.gov.uk

Here’s the content of the e-mail:

“In November 2018, the CMA consulted on its proposal to make a market investigation reference in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services (in both cases within the UK). The draft terms of reference excluded from the meaning of ‘services by funeral directors at the point of need’ both the provision of pre-paid funeral plans and the provision of services provided pursuant to prepaid funeral plans.  

The CMA has received representations, in response to this consultation, that the scope of the proposed market investigation reference should be extended to include the funeral services supplied by funeral directors in the United Kingdom arising from the redemption of pre-paid funeral plans.

The CMA is, therefore, inviting interested parties to provide views on whether, if the CMA decides to make a market investigation reference, the scope of the market investigation should include the delivery of such services. 

The consultation document can be accessed on the Funeral market study case page at: https://www.gov.uk/cma-cases/funerals-market-study

Comments should be provided to the CMA no later than 5pm 13 March 2019.

One of ours

We’re a bit late to the party, as this came out last week, but we were prompted by a comment from a regular reader on another blog post (thanks Andrew!!)

We were delighted to see one of our Recommended Funeral Directors featured in a documentary on ITV. Poppy’s Funerals were described as ‘female-led funeral directors out to buck several trends in male-dominated industry’. 

We like that!

Watch the full clip here.

Level playing field?

Here’s a curious thing.

The deadline to submit responses to the Competition and Markets Authority’s consultation on their proposal to make a market investigation reference was 5pm on Friday 4th January.

This is specified on page 132 of their Interim Report, in bold font: ‘Such comments should be provided no later than 5pm on 4th January 2019‘.

Like many others, the GFG absolutely busted our guts to get our response submitted in time. In fact, much of last week was spent ensuring that we provided a thorough and honest response to all of the questions asked. We thought that the deadline was just that – the latest time or date by which something should be completed.

But for some reason, it seems that at least one of the funeral trade associations have been given an extension, and are currently ‘developing their response’, according to their Facebook post today. Three days after the deadline.

We’re underwhelmed at this, to say the least.

Time to speak up

Dear Reader

Are you connected to funerals in any way?

Are you somebody who has an interest in what goes on in funeralworld?

Have you had to arrange a funeral, or had to think about funeral arrangements for someone close to you?

Or do you work in the funeral sector?

Have you seen or heard things that you know are just wrong?

Are you concerned about aspects of your work, prices that you can’t justify to clients, procedures that you have to follow that you find uncomfortable, things that have gone on behind the scenes that worry you?

Have you been a bit busy recently and not got round to responding to the consultation launched by the Competition and Markets Authority at the end of November?

YOU’VE ONLY GOT FIVE DAYS LEFT.

(We wrote about the CMA’s Interim Report on the blog here and here if you want to refresh your memory)

Comments are invited on the CMA’s provisional decision to make a market investigation reference (MIR) in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services in the UK.

Such comments should be provided no later than 5pm on 4 January 2019 to:

Funeral market study team

Competition and Markets Authority

Victoria House

Southampton Row

London

WC1B 4AD

E-mail: funerals@cma.gov.uk

This is hugely important. 

It could completely change the landscape of the funeral sector for the benefit of people who need to arrange funerals. And that, effectively, will be all of us.

Please, make sure that the CMA hears from people from all walks of life who have an interest in how the funeral sector is currently operating.

If you have relevant experience or thoughts on the proposed investigation into the funeral sector, then make your voice heard. 

If you don’t take the time to write and tell the CMA what you think, the responses received will be dominated by replies from corporate funeral operators and trade associations.

Your experience matters. 

Your opinion matters. 

You are the people the CMA need to hear from. 

It’s time to speak up.

The full interim report and details of the consultation can be downloaded here, along with the findings of the research commissioned by the CMA to understand the behaviour, experiences and decision making of people who had recently engaged the services of a funeral director.

The report is a lengthy document but well worth reading – if you haven’t got time to do so, then here is a precis of what the CMA is inviting comments on:

The CMA considers that this interim report identifies significant concerns about the effectiveness of competition in relation to the supply of funeral services at the point of need and the supply of crematoria services in the UK.’

‘The CMA welcomes representations from interested parties on the provisional decision set out in this document. The CMA wishes to stress the importance of the consultation process in assisting the CMA’s decision making and urges interested parties to engage with the consultation. Respondents may wish to reply in relation to the supply of services by funeral directors at the point of need, in relation to the supply of crematoria services, or both. In doing so, respondents may wish to consider the following questions:

Do you consider that the CMA’s analysis is correct with respect to the suspected features of concern in the supply of:

  • services by funeral directors

‘8.31    Based on the evidence and our analysis set out in section 4, our provisional view is that there are reasonable grounds for suspecting that one or more of the following features or combination of features prevents, restricts or distorts competition in the supply of services by funeral directors at the point of need in local areas:

  1. Customers’ vulnerability and difficulty in engaging at the point of need.
  2. Customers’ unresponsiveness to measures of price and quality; they largely choose a funeral director on the basis of recommendation or personal experience.
  3. Customers’ inability to assess certain aspects of quality and the value for money of all options offered given funerals are an infrequent purchase and customers are often inexperienced.
  4. Lack of transparency: reluctance of firms to publish / disclose clear prices (including online) or to provide comprehensive information on quality and range.
  5. Point of sale advantage: ability of suppliers to largely control the decision-making process leading to the sale and its outcome.
  6. Ineffective self-regulation in respect of information transparency – no mandatory publication of online prices, absence of publication of inspection reports.’
  • crematoria services 

8.33    Based on the evidence and our analysis set out in section 5, our provisional view is that there are reasonable grounds for suspecting that one or more of the following features or combination of features prevents, restricts or distorts competition in the supply of crematoria services in local areas:

  1. Customers’ vulnerability and difficulty in engaging at the point of need.
  2. Customers’ unresponsiveness to measures of price and quality; they largely choose a crematorium on the basis of location or personal experience.
  3. Low numbers of crematoria providers in local areas.
  4. High barriers to entry arising from the planning regime and high fixed costs, which limit the number of crematoria in each local area.’

Do you consider that the CMA’s analysis is correct with respect to the reference test being met in relation to the supply of:

  • services by funeral directors at the point of need (see paragraphs  8.12 to 8.37) and
  • crematoria services (see paragraphs 8.12 to 8.37)?

Do you agree with the CMA’s proposal to exercise its discretion to make a reference in relation to the supply of services by funeral directors at the point of need and the supply of crematoria services (see paragraphs 8.38 to 8.96)?

Do you consider that the proposed scope of the reference as set out in the draft terms of the reference in Appendix F, would be sufficient to enable any adverse effect on competition (or any resulting or likely detrimental effects on consumers) caused by the features referred to in paragraphs 8.31 and 8.33 to be effectively and comprehensively remedied?

Do you consider that the features which the CMA has identified that may prevent, restrict or distort competition are capable effectively and comprehensively remedied by UILs (undertakings in lieu of a MIR)?

Do you have any view on our current thinking on the types of remedies that an MIR should consider (see paragraphs 8.66 to 8.86)? Are there other measures we should consider? 

Funeral director services:

  • Transparency remedies
  • Changes to the regulatory framework
  • Establishment of a regulatory body
  • CMA-led price regulation

Crematoria

  • Establishment of sectoral regulator or price regulation
  • Guidance to local authorities
  • Changes to the planning system

Other possible remedies

The CMA would particularly welcome any specific evidence from respondents in support of their views.

In addition to the above, the CMA would also welcome evidence and views on the following matters:

  1. Quality of care of the deceased: we have received anecdotal evidence that there may be varying standards of care being applied by funeral directors and would like to understand how widespread such issues may be. We would therefore like to hear from people who have witnesses standards of care which they considered to be unacceptably low.
  2. Issues specific to religious groups that are not covered in this report: we have focused our work on the transactional aspects of funerals involving funeral directors and crematoria. We believe that the issues we have identified in relation to those specific aspects would essentially be similar across all faiths (to the extent that the way they organise funerals involves transactions with funeral directors or crematoria. We are keen to find out whether we may have overlooked any issue of relevance and will seek to engage actively with the representatives of the major faiths.

Our intention is to publish on the CMA’s website an aggregated and anonymised summary of submissions from individuals, although if you prefer, you can indicate that you would prefer for your response to be published in full.

We intend to publish all responses from business and other organisations on the CMA’s website, except those responses marked as confidential. Respondents may request that their response be kept confidential. If you would like your response to remain confidential, clearly mark it to that effect and include the reasons for confidentiality. Please restrict any confidential material to the appendices to your response.

We will redact, summarise or aggregate information in published reports where this is appropriate to ensure transparency whilst protecting legitimate consumer or business interests.’

We have a chance to make a change. Right now.

Do you want to improve things for bereaved people? Do you want to be a responsible citizen who stands up for what they know is right?

Then find ten minutes to tell the CMA what you think.

Thank you.

Well said Louise!

The CMA interim report on the funeral industry is taking time to digest across funeralworld.

 It’s not surprising, it’s a chunky document. And it’s possibly proving quite indigestible for some, particularly the PR teams at Dignity, Co-op and Funeral partners.

The essential conclusion is – the funeral sector is not functioning well. Competition is not working effectively, price rises can’t be justified, and bereaved people are at risk of being exploited.

AT LAST!!!!

Finally, an official body is seeing what we have been pointing to and writing about for years.

And an official body with clout. The CMA proposes to make a Market Investigation Reference (MIR) into both the funeral market and the cremation sector.

This in turn could lead to recommendations to government to impose transparency requirements, changes to the regulatory framework regarding funeral directors or the establishment of a regulatory body, with the possibility of CMA-led price regulation.

The interim conclusion found that:

  • The extreme 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. This is true in relation to funeral director services, and, to a lesser extent, funeral services.
  • In addition to large annual price increases, the supply of funeral services is characterised by large price differentials between suppliers, including within local areas. Such wide price differences appear hard to explain on the basis of cost, range, quality and brand differences between suppliers.
  • The yearly high price rises implemented by the major suppliers have directly boosted their profit margins for a persistent period of time, The EBITDA margins of Dignity have been well above international benchmarks, while those of Co-op and Funeral Partners are at the higher end of them.
  • When considering these profit margins alongside long-term policies of large price rises unrelated to underlying cost pressures, it seems clear to us that this is a market that is not functioning well, to the detriment of vulnerable consumers.

Andrea Coscelli, chief executive of the CMA, said: “People mourning the loss of a loved one are extremely vulnerable and at risk of being exploited. We need to make sure that they are protected at such an emotional time, and we’re very concerned about the substantial increases in funeral prices over the past decade.

“We now feel that the full powers of a market investigation are required to address the issues we have found. We also want to hear from people who have experienced poor practices in the sector so that we can take any action needed to fix these problems.

The two funeral directing trade associations don’t fare too well either, in particular the NAFD who nominates itself as ‘the Voice of the Profession’. Among their members they number Dignity, Co-operative Funeralcare and Funeral Partners Ltd. The three companies mentioned directly by name as profiting substantially from yearly high price rises are members of the NAFD.

“We recognise that trade associations bring a number of benefits to their members and may also be of benefit to consumers. However the evidence we have seen indicates that the two trade associations have fallen short of bringing about the level of transparency that is necessary to facilitate consumer choice. The evidence also indicates that the trade associations’ focus on supporting the commercial interest of its members may have been detrimental to competition, as illustrated by the approach taken to matters relating to online price transparency and the development of online comparison tools.”

So, all not so rosy for the Voice of the Profession, despite the NAFD PR statement in response which oddly seemed to have missed the point made by the CMA about their failings (it’s at point 4.101 on page 64).

This morning, BBC Radio 4 Sunday programme invited the current president of the NAFD to debate funeral costs with Louise Winter, founder of Poetic Endings (GFG Recommended funeral director and member of the Good Funeral Guild).

Listen here from 35 minutes 44 seconds.

It was an interesting few minutes.

We’d like to suggest that the NAFD explores the meaning of ‘debate’ as opposed to bulldozing through a discussion without drawing breath and requiring the other person to have to interrupt to make their point. Talking for over half of the allocated eight minutes is not good manners.

Here are a few excerpts:

From the NAFD representative in response to the suggestion of price capping:

“In some cultures, there is a necessity to spend money on a funeral as a mark of respect for the person who has died so you have to be very careful about making sweeping statements..”

Louise’s response: “That does not give the big corporates whatever price they want, well above the inflation rate every year, with their sole intention being to make as much money as possible for their shareholders. The people who are doing this are members of your organisation, your trade association, which supposedly exists to protect bereaved people and to help them have the funeral they want. It’s not. It’s just protecting the funeral directors and the costs that they are charging.”

NAFD response: “We protect bereaved people by giving them access to standards that can be guaranteed and a scheme of independent redress should something go wrong..”

And Louise cut in with “And outrageous prices, with no transparency, with only a third of your members putting their prices online”.

Worth a listen!

Funeral trade association calls for regulation

The National Society of Allied and Independent Funeral Directors has today issued a press release stating its position on the subject of regulation.

SAIF members received an e-mail yesterday advising them that ‘after careful consideration we have decided that regulation across England and Wales is a good thing and welcome it’. 

The ‘careful consideration’ appears to have been carried out by the SAIF executive committee.  SAIF members were not consulted before the statement was announced and the consultation is apparently to follow.

Now, while it’s quite possible that all of the more than 870 members of SAIF and additional 100 associate members will all unanimously agree that regulation of some kind is required in the funeral industry, if we were a member of an association that was representing our business (we’re not by the way) we’d rather like to have been asked first about our opinion on such an important subject. 

At the GFG we have long taken a stance that regulation of the funeral industry needs to be carefully considered and crafted, and definitely not determined by the trade associations involved. Trade associations are exactly what the name implies.

Any decision on regulation should be led by the interests of the bereaved person, a consumer focus that trade associations are, by definition the exact opposite to. Trade associations represent the interests of their members. Full stop.

Regulation of the funeral industry needs to be informed by wide input, including the funeral world, ideally by seeking the views of every person or company involved with providing assistance of some kind with funerals. However, currently, nobody knows exactly how many funeral director companies are currently operating, whereabouts they are or who is running them. There is no central register of any kind.

At the same time, the UK government is currently paralysed in every area other than those directly involved with the imminent withdrawal from the EU. Attempting to introduce regulation of the funeral industry in the current climate would, we gently suggest, likely mean that government would hand over the critical work of framing the regulation to the funeral industry trade associations hovering helpfully in the wings with their suggestions.

Incidentally, for ‘regulation’, replace with ‘whole tranches of licensing, required training, standards of premises, membership of associations’ and so forth, all providing new layers of bureaucracy, all coming at a cost (to be passed on to whom?), all adding to the end result of – what?

More passionate, creative, intelligent people starting up small companies to serve bereaved families in the best possible way? We doubt it.

Read the press release from SAIF below.

Independent funeral directors call for regulation of profession in England, Wales and Northern Ireland

England, Wales and Northern Ireland should follow in Scotland’s footsteps and introduce regulation of the funeral profession.

This is the position of the National Society of Allied and Independent Funeral Directors (SAIF) – the voice of independent, family-owned funeral directors across the UK.

It makes SAIF the first significant funeral trade association in the UK to back statutory regulation of funeral directors.

The association has also urged its members with websites to display their prices online as soon as possible to help bereaved consumers better understand possible costs involved with a funeral.

It could also mean families get a better deal, with research consistently showing that independent funeral directors’ prices are consistently lower than large groups, like Co-op Funeralcare, Dignity and Funeral Partners.

SAIF’s position on regulation is in response to the positive and proportionate way in which regulation is being introduced in Scotland, and comes in the wake of a small number of worrying cases in which funeral directors have fallen short of standards to which trade association members subscribe.

Terry Tennens, Chief Executive of SAIF, said it was high time all bereaved people across the UK were guaranteed a minimum set of standards from the professionals taking care of them at life’s most difficult time.

“Currently, anyone can set up a funeral directing business and there is no requirement for them to work to a minimum set of standards. Trade associations require their members to abide by a code of practice, but membership is voluntary and we are seeing too many cases of firms who don’t belong to an association operating in an unacceptable way,” Terry said.

He added: “All other care industries are regulated, so there is no reason why funeral directors to whom people turn in great distress should not be subjected to similar rules. The vast majority of SAIF members share concerns about standards and support regulation of the funeral profession.” 

In respect of online pricing, Terry said SAIF’s leadership was set to discuss a commonly agreed set of funeral elements that would appear on a price list, to better help consumers make like-for-like comparisons. A price list should also include options for a simple or basic funeral and a traditional funeral, along with additional items such as flowers and orders of service. This could eventually form part of the association’s code of practice.

Despite concerns about poor practice, bereaved people should be reassured that the overwhelming majority of independent funeral directors operate to high standards. However, one firm operating below par is one too many.

Regulation of the funeral profession should be proportionate and informed by all stakeholders, with the views of independent funeral directors carrying as much weight in any process as those of the large corporates and cooperatives. 

SAIF’s call for UK-wide regulation of the funeral profession comes ahead of the findings of a Competition and Markets Authority (CMA) study of the funeral market.

A proportionate regulatory regime could address some of the transparency issues being examined by the CMA and ensure clients of all funeral directors are getting a good deal.

SAIF is to consult its members and the wider funeral profession on areas of focus for any possible regulatory regime which are likely to include:

  • Price transparency – this would include a commonly agreed set of criteria for standard elements of a funeral and clarity around any special offers. SAIF is extremely concerned about Co-op Funeralcare’s recent price match announcement and feels families are being misled by a time-limited offer, which will only be honoured if deemed “feasible”. These types of hard-sell tactics could lead to additional distress for bereaved people if Co-op Funeralcare decline to match what a family felt was a genuine price.
  • Care facilities – all funeral directors should possess or have access to well-appointed care facilities, including a mortuary with spotless refrigeration units and a clinical-standard area for embalming and care of the deceased.
  • Transparency of ownership – the large chains and co-operatives have a habit of buying independent businesses and continuing to trade under the name of the previous owner. Bereaved people need to be given much clearer information by the large firms as to who is delivering the funeral in such circumstances.
  • Financial stability – the distress caused to families if a funeral director goes into liquidation is immense. Any regulatory system should protect bereaved people from the closure of a funeral business, ensuring alternative provision is made in a timely manner and families are not left to fend for themselves, as seen recently in Rochester, Kent.
  • Record keeping – one of the keys to a well-run funeral is a water-tight record keeping system, which prevents any possible mistakes around identity of the deceased and ensures the safe return of any property belonging to families.
  • Regulation that works across jurisdictions – with many funeral directors often finding themselves operating across borders, allowances should be made for any differences in regulatory regimes.

Following a consultation exercise, SAIF is to write to the Westminster Government, Welsh and Northern Ireland assemblies, stating its position on regulation of the funeral profession across all jurisdictions. 

To SAIF – an open letter from a member

An open letter to SAIF, the National Society of Allied and Independent Funeral Directors from Cara Mair, Director, ARKA Original Funerals, sent 4th May 2018.

Dear all at SAIF

I write this to you as a longstanding member of SAIF, in the hope that you will not see this letter negatively, but more as a positive tool to allow you to look at how SAIF can move forward. I hope that this letter will begin a dialogue on how the training that you offer can be more inclusive and how, at the heart of this training, should be the empowerment of the community that we serve. Where we find ourselves today in this fast-changing society let us be the disruptors and not the disrupted. To be truly bold and take leadership in this area and create a legacy that other independent funeral directors can build upon.

I have worked in the funeral world since 1998, beginning my days as a chauffeur/bearer at the Co-op in Brighton. After that experience, I trained as a freelance embalmer and worked with many funeral directors across the South East. My first hand experience of working in this secretive funeral world was dismal and I was adamant that I would stay in this profession and make a difference. In November 2003 ARKA Original Funerals opened in Brighton and since then things have changed in the funeral world and there have been many reasons for this. From The Natural Death Centre and The Good Funeral Guide showing how we as a community can be more involved. To forward-looking, inclusive funeral directors such as ARKA, Green Funeral Company etc and of course technology allowing the public to be far more informed re choice and insight into the funeral process. All of these factors have been key to increasingly making a difference ensuring that funeral directors are held more accountable for the way that we work. I also believe that there are many things that would not have changed in the funeral industry if it were not for pioneers like those mentioned above.

With twenty years’ experience, I know of many people and organisations working within this industry who could put a comprehensive training programme together that would benefit us all. There is more and more discussion about how being more involved with the care of the deceased can help people through the grieving process. The communities that we serve should have the right to be supported in caring for their dead and not be ‘protected’ by the ‘professionals’.

I attended the AGM of SAIF in Brighton in March this year. The whole experience was very disappointing. There was also much disgruntlement about how SAIF was representing us all. To focus on pre-paid funeral plan selling as a way to secure your business in the future is an extremely narrow viewpoint. This is such a blinkered vision of how things could proceed. These plans are marketed so aggressively and instead of empowering the public to take control of decisions (as they’re so often marketed as) they are instead further disempowering people and misinforming many. This whole process is contemptible scare mongering and I am sure that you know that you will not keep up with the big boys in this area.

What I find so disheartening was how you totally dismiss the progressive movement that is happening, both with new independents opening up and also individuals supporting funerals in new ways. To move SAIF forward and to mark independent funeral directors distinctly apart from the corporates is to be outstanding in the quality of support we can offer in the way that we work and present ourselves. To work in a refreshing empowering way that the corporates cannot compete with.

The training that you offer, as you are probably aware, is out of date. You focus on what you can sell rather than what you can give. You come from a stance of protecting yourselves rather that empowering others. Your training should include how we communicate to the public by looking at changing the use of the language that is bandied around and more insight into how we can offer permission to people to be involved in looking after their own dead.

There is really nothing that sets you apart from the corporates in the public eye. You dress the same. You put false value in things such as cars. You are secretive. You pay no importance to the collection and ‘care of the deceased’.

I propose to you that your training should be developed to include a natural way of looking after a body and to become more creative in looking at the role of the Funeral Director in the 21st century. Here’s how it could be achieved.

Each organisation should have a representative who would be knowledgeable, capable and willing to support families with a more hands on approach in looking after their dead. This representative could also support the other staff that you have to ensure that the environment is supportive and safe.

Believe me, this will not only help your organisation, but will also give much more work satisfaction to the people that are involved in your company and you will feel prouder of the support that you can offer.

This letter comes from a place of caring and of concern that what you stand for will rapidly disappear if you do not drastically change what you are doing and how you represent others. I ask that you seriously consider the points I have raised and not hide from what needs to happen.

I am up for a conversation, to go through these points and to find some solutions as to how you will still exist in a more empowering way for both the public and your members within this fast-moving landscape.

I very much look forward to hearing from you.

Yours sincerely,

Cara Mair

Director, ARKA Original Funerals

The NAFD has a new CEO

 

 

 

We were pleased to receive an e-mail recently advising us that the National Association of Funeral Directors has appointed an interim CEO, some four months since the role became vacant.

It’s been quite a while without a steady hand at the NAFD tiller, and taking on the tasks that would normally be the responsibility of the CEO must have been immensely demanding on the current president, Alison Crake, her vice presidents and the officer team. We’re sure that they are all very pleased to have the esteemed Graham Lymn come on board to step into the empty CEO shoes, albeit temporarily.

As part of his role, Mr. Lymn will be assisting the Officer team with recruitment of a permanent incumbent and providing an extensive handover, enabling the new recruit to quickly understand the unique challenges of the funeral industry.’

We presume that this won’t take up all of Mr. Lymn’s time over the next six to nine months, so, from an interested outside observer’s point of view, we’d like to offer some suggestions of other areas that we think would be really productive for him to focus on, to help make the ‘Voice of the Profession’ relevant in today’s rapidly changing world of funerals.

 

  • The All Party Parliamentary Group for Funerals and Bereavement. Open this up to others, not just the NAFD and their paid secretariat, Brevia. In an age when there are so many challenges facing bereaved people and the funeral profession, it is completely wrong that the only group in Parliament discussing these subjects is controlled and dominated by a single organisation, representing the interests of funeral directors. There needs to be collaboration with a wide range of stakeholders to ensure bereaved people are better served.

 

  • The NAFD Code of Practice. Develop a code of practice that truly benefits clients of NAFD members. Areas to cover? A clear stance on price comparison websites, and a definition of a ‘simple funeral’ that all members should be required to offer as a start.

 

  • The NAFD complaints procedure: Give teeth to this for clients who have been poorly served by members. How many companies have had their membership suspended or revoked after serious complaints? If this sanction is not ever applied, then the complaints procedure is pretty pointless.

 

  • Show leadership. Stop sitting on the fence on big issues, whether relating to transparency of ownership, new entrants to the sector (e.g. local authorities and hospices), direct cremation specialists or funeral poverty. Also, members having prices available online – the NAFD stated hope for 70% of NAFD members to have some or all their prices online by 2019 is pitiful, it should be 100%, this year.

 

  • Introduce external expertise on its executive committee to help it develop a conversation with the wider public and understand the world beyond the narrow focus of practicing funeral directors.

 

  • Develop a new vision for the Social Fund Funeral Payment. Repeated statements calling for an increase in the payment may ease the association’s conscience but do nothing to help people struggling to pay for a funeral. A new solution is needed. The NAFD is well-placed to lead on this.

 

  • Look at membership fees. Expecting a self-employed celebrant to pay the same full fees for supplier membership (currently £455 p.a.) as coffin manufacturing companies and large groups of private cemeteries is completely unrealistic. To build a broad supporter base, engaging individuals from all areas involved with provision of funerals, a tiered system of membership fee is long overdue. Alongside this, monitoring the unauthorised use of the NAFD supplier logo by individual members of organisations (who haven’t paid for the membership themselves) would also be welcomed.

 

  • Introduce an assistance fund. A levy on NAFD membership and income from other events such as NFE could pay into an assistance fund for families struggling to meet the cost of paying for a funeral. (This could be administered by a new member of staff, whose salary could be found by ending the payment to Brevia for running the APPG secretariat and opening attendance to other organisations who could contribute towards the funding of the APPG.)

 

  • Create a robust framework that would safeguard the association and its staff and members from falling victim to personal agendas and vested interests. For example, putting a limit on terms for voluntary officers to prevent trenchant points of view dominating the association’s conversations with external parties.

 

 

 

Collaboration not competition.

According to Twitter, the website and an e-mail bulletin sent out yesterday, the Good Funeral Awards will be taking place this year in Bournemouth in September.

We think it worth noting that the Good Funeral Guide is no longer involved with these events and will not be attending.

We ended our involvement with the awards as joint organisers last year, having been very much part of the awards since they began in 2012.

The decision was taken for various reasons, but in essence, we feel that the time for competing against one other in funeralworld has come to an end and that progressive, intelligent people working together and collaborating in best practice is the way forward.

Across the UK, good people serving bereaved families face the relentless pressure of large corporates seeking ever larger ‘market share’, the growing issue of unregulated funeral planning, negative media coverage of the funeral industry, the race to the bottom in pricing, ‘ ‘disruptive’ online ‘experts’ adding their two penn’orth to information in the public domain – and the ongoing stress of working daily directly with death and the aftermath.

We feel that all who are trying to improve the way we do funerals in the UK are stronger together, supporting each other and sharing fellowship, rather than competing against each other, and allowing themselves to be set apart by judgements of who is the best in each field.

We also feel that the role of the GFG is done when it comes to awards within the funeral industry.

We want to concentrate on what we think essential. Reaching out from inside the funeral bubble of talking to each other about each other and actually talking to the people who matter most. The public.

The role of the Good Funeral Guide is, and always has been, to support, empower and represent the interests of dying and bereaved people, and we will continue to do our best to do so in the future, rather than getting sidetracked with event planning.

To the trustees of all hospices in the UK

 

Last weekend, we despatched letters to the boards of trustees of every hospice in the UK to share our concerns about the new franchise offer that was launched at the Hospices UK conference the previous week.

Our misgivings about this venture are shared by a number of individuals and companies who gave permission for their names to be added in support. The letter is published in full below, together with the names of those who agree with us.

 

The Chair of the Board of Trustees

SAMPLE Hospice

December 1st 2017

HOSPICE FUNERALS: THE GOOD FUNERAL GUIDE COUNSELS CAUTION

Dear Trustees of SAMPLE Hospice

We write regarding the recent launch of Hospice Funerals LLP, of which you may well be aware. Should you not have heard of this new venture, it is a joint collaboration between St. Margaret’s Hospice Ltd. in Somerset and Memoria Ltd., owner /operator of a number of crematoria around the country and of Low Cost Funeral Ltd.

Hospice Funerals is offering all UK hospices the opportunity of a becoming a partner in their franchise funeral director scheme by becoming a ‘Hospice Provider’, entitled to operate exclusively within a defined area, offering undertaking services branded under the hospice name. For full details, please see the Hospice Funeral website https://www.hospicefunerals.co.uk/

The Good Funeral Guide wishes to draw the attention of the Board of Trustees to the very serious concerns that we have about this proposed new revenue stream generator, despite the public proclamations of how this will address the issue of funeral poverty and ‘bring choice, quality and affordability to families in our communities.’

As a trusted, not for profit, social enterprise company, wholly independent of the funeral industry, that has for years supported, empowered and represented the interests of dying and bereaved people living in the UK, we would be delighted to see a truly ethical, community focused undertaking service evolving from the hospice movement; indeed, we have a blueprint guide to how to set up such a model on our website which we developed in partnership with the Plunkett Foundation several years ago.

Unfortunately, this new model proposed by Hospice Funerals does not, in our opinion, fall into the category of an ethical, community focused service, despite the marketing hype.

THE COMMERCIAL RISK

  1. It is a franchise operation, which is intended to utilise ‘brand recognition’ of the hospice name to leverage advantage over existing providers of undertaking services in the franchise catchment area (defined by Hospice Funerals) and by ‘disrupting the market’, in the process conveniently increasing the numbers of cremations carried out by the crematoria owned by Memoria Ltd.

The Good Funeral Guide is not aware of the successful application of any franchise model to the business of funerals. Franchise operations are best suited to selling merchandise, not personal service. The franchise model proposed by Hospice Funerals is wholly unproven.

  1. Figures provided by Hospice Funerals indicate an extremely optimistic analysis of the potential income of a ‘Hospice Provider’. Their analysis suggests that a single unit operation offering funeral packages at their pre-specified prices, requiring a capital input of £110,00, would generate £356,500 through sales of 100 ‘at-need’ funerals and 46 pre-arranged funerals in year one, yielding profit of £26,656. Year three sales are projected as comprising 200 ‘at-need’ funerals, 120 pre-arranged, generating £212,964 profit.

The Good Funeral Guide contends that these figures are misleading, to say the least.

The ‘funeral market’ is, by admission of the directors of Memoria Ltd, already saturated with providers. In the town of Taunton, where the first Hospice Funerals unit is scheduled to open in early 2018, there are currently twelve funeral directors catering for the needs of local bereaved families. This in an area with a population of 109,000 (the borough of Taunton Deane) and an average UK death rate of 9.4 per 1,000.

Figures quoted by the representatives of Hospice Funerals at the launch of the scheme last week cited the average cost of funerals in some areas as being ‘well over £6,000’.

This figure was derived from the Royal London National Funeral Cost Index 2017 and was arrived at by adding the cost of a burial in a specific London Borough, Kensal Green, (£9,809) to the cost of a cremation in the same borough (£3,223) and dividing in two.

It is mysterious that the Royal London Report didn’t allow for the fact that almost 80% of UK funerals are cremations. A more accurate average would be to factor in the percentage split of types of funeral, (20 x £9,808 + 80 x £3,223, divided by 100), which would result in an average cost of a funeral in the most expensive location in the UK being £4,504, not the much more alarming figure of £6,516 quoted in the report.

Note: all monies that will be paid into a Hospice Funerals pre-arranged funeral plan will be held in a Royal London whole-of-life policy, indicating a close and perhaps unquestioning relationship between the two bodies.

Directly related to the above ‘average cost of funerals’, the prices of the funeral packages offered by Hospice Funerals range from £1,295 for an unattended service at a Memoria crematorium to £3,500 for a traditional service with a hearse and bearers at a crematorium of your choice.

In comparison with the inflated figures quoted as the cost of an average funeral, this might seem to be a wholly worthy attempt to address funeral poverty, as it was described at the Hospice Funerals launch, yet the prices of their funeral packages are equivalent with, and in some cases higher than, those currently charged for comparable services by most independently owned funeral directors.

As an example, two Good Funeral Guide Recommended Funeral Directors in the Taunton area (where the first white labelled Hospice Funerals unit will start operating in 2018) are both lower priced for the same traditional funeral service, with all third-party costs included:

Wallace Stuart Lady Funeral Directors (Bridgwater) £2,630.00

Crescent Funeral Directors (Taunton) £3,000.00

Hospice Funerals £3,500.00

The Good Funeral Guide is concerned that the figures quoted by Hospice Funerals could erroneously lead hospices to think that they would have a straightforward price advantage over competitors in offering a local undertaking service, when this would simply not be the case.

THE REPUTATIONAL RISK

We also consider the employment of the name and reputation of hospice, both specifically in the use of the individual name of a local franchisee, and nationally in the use of the company name ‘Hospice Funerals’, to be a calculated, and indeed one could say cynical, attempt to persuade the public that this new undertaking model is simply an extension of the highly reputable and locally supported end of life care provided by their cherished local hospice.

The fact that it is in fact a white label operation, maximizing the use of the ‘brand name’ of the hospice in each area, controlled by Memoria Ltd, who have divided the UK into ‘catchments’ of 100,000 people (and who are proffering these 650 areas for sale at £10,000 p.a. franchise opportunities to hospices as a means of securing their much-needed income) seems to be lost somewhere in the marketing spin.

We would suggest any hospice considering entering an arrangement of this kind notes the following:

  • Other franchisees could give the brand a bad reputation
  • All profits (a percentage of sales) are shared with the franchisor.
  • The franchise agreement will include restrictions on how you can run the business. You might not be able to make changes to suit your local market.
  • You may find that after time, ongoing franchisor monitoring becomes intrusive
  • The franchisor might go out of business.

Reputational damage to individual hospices signing up to this opportunity could potentially be catastrophic. Legacy donations and in memoriam fundraising could be seriously impacted if families elect to use a hospice funeral home, as they could consider they have done their ‘giving back’ to the hospice through their payment of the fees involved with the funeral.

The move from being perceived as a deserving recipient of gifts and donations to being seen as a money-making business entity, competing with established, trusted and well-liked funeral providers, is a subtle but potentially disastrous one, impacting on the public perception that a hospice is a wholly altruistic organisation.

Comments on our blog post about the advent of Hospice Funerals have been overwhelmingly against the idea of hospices entering the supplying of funeral services.

Phrases used include ‘unethical’ (several times) ‘goes against every principle a hospice should stand by’, ‘will negatively impact their charitable and bequest income’, ‘conflict of interest’, ‘risk losing this public support’, ‘at what point does care and support for the dying and impartial advice given to a family suddenly at sea after a death turn into a sales opportunity?’

On social media, there has been a similar reaction. Questions have been asked about the arms-length relationship between a hospice and its funeral home – how will this work in reality? What will be the impact on the current relationship with local undertakers when the hospice enters the marker as a direct competitor? How will the new hospice funerals service be promoted to the community, and how will this be reacted to?

It seems to us that hospices will be carrying all of the risk in the hope of optimistically calculated but completely unproven rewards.

If SAMPLE HOSPICE is considering partnering with Hospice Funerals, we would counsel strongly that the trustees take heed of our concerns before making your final decision to risk your donated funds to venture into competition against the local funeral directors who work so closely with you to look after the families of those whose lives end in your care.

The Good Funeral Guide is supported in our misgivings about the wisdom of this new venture by the individuals and organisations listed below, some of whom may be known to you as local, independently owned undertakers who share our fears about this seductive offer being touted to hospices around the UK.

Should you wish to contact me directly about this I would be more than happy to discuss our collective concerns further. My e-mail address is fran.hall@goodfuneralguide.co.uk.

Fran Hall

CEO Good Funeral Guide CIC

On behalf of the board of directors of the Good Funeral Guide and the undersigned supporters.

 

A Oliver & Sons Funeral Directors

A.W. Lymn – The Family Funeral Service Ltd

Adrian Pink – Town & Country Funerals

Alistair Turner Funeral Directors

Allistair Anderson & Hasina Zaman – Compassionate Funerals

Amanda Pink – Evelyn’s Funerals

Andrew Dotchin (Reverend)

Andrew Smith Funeral Service

Angie McLachlan MA; BA Hons, BIE

Anna Briggs – Independent Officiator of bespoke funeral ceremonies

Anne & Simon Beckett-Allen – Rosedale Funerals

C Waterhouse & Sons

Carrie-Ann Rouse – Rouse & Co. Independent Funeral Directors

Carrie Weekes & Fran Glover – A Natural Undertaking

Claire Turnham – Only With Love

Claire Young – Young’s Independent Funeral Services

Clare Brookes – VW Funerals

Colin Liddell – Liddell Funeral Services

Coles Funeral Directors

David Hardie & Son Funeral Directors

David Holmes – Holmes & Family

Don O’Dwyer – O’Dwyer Funerals

E A Dodd & Son

Edward Towner – Arthur C. Towner Ltd

Emma Curtis – Secular Minister, Celebrant & Grief Counsellor

Eric Massie Funeral Directors

Gail Willington – Elizabeth Way & Company

Gordon Tulley & Alison Finch – Respect Woodland Green Burial Parks

Heathfield Funeral Service

Jacob Conroy & Sons Funeral Directors

James L Wallace Funeral Directors

Jane Morgan – Jane Morgan Ceremonies

Jeremy Neal – Rotherham Funerals

Jo Loveridge – Albany Funerals

John Beattie & Sons Funeral Directors

John Pinder – W. E. Pinder & Son Ltd

Judith Dandy – Dandelion Farewells

Judy Mansfield – Cherish Ceremonies

Karen & Julian Hussey – A. G. Down

Leverton & Sons

Louise Winter – Poetic Endings

Lucy Coulbert – The Individual Funeral Company & Coulbert Family Funerals

Like & Liz Farthing – Farthing Funeral Service

Maggie Brinklow & Tony Killen – Margaret Rose & Bespoke Funerals

Malcolm Jones – Molyneux Jones Family Funeral Directors

Mark Binnersley MPRCA Communications Consultant

Martin Stibbards – S. Stibbards & Sons

Matthew Lucas Funeral Directors

Michael & Clare Gamble – Michael Gamble Funeral Directors

Nick Armstrong – Armstrongs Funeral Service

Nikki Hill – Bright-Hill Funerals

Overmass & Chapple

Paul Burrows Gibson – Veterans Funerals UK

Paul Sullivan – Sullivan Funeral Directors

Peace Funerals

Peter Grenfell Funeral Directors

Poppy Mardall – Poppy’s Funerals

Philip & Sallie Evans – Sussex Funeral Directors

Rosalie Kuyvenhoven – Rituals Today

Robert Samson Funeral Directors

Rupert Callender – The Green Funeral Company & Callender, Callender, Caughty & Drummond

Saint & Forster Funeral Directors

Simon Helliar-Moore & Robert Helliar-Moore – Crescent Funerals

Simon Smith – Green Fuse, Heart & Soul Funerals

Southgate & Roberts

Tim Coombe – Senior Anatomical Pathology Technician

Tim Purves – William Purves Funeral Directors

Tilly Munro – Community Funeral Specialist

Toby Angel – Sacred Stones Ltd.

Tom Woodhouse Funeral Directors

Wallace Stuart Funeral Directors

W G Catto Funeral Directors

W G Potter

Wood & Hay Funeral Directors