The Funeral Rule : Use of Alternative General Price Lists for Special Groups

Here is a review of a few general price list (GPL) options you have available to you when working with certain special groups.  This is according to the Federal Trade Commission.  Within the requirements of the Funeral Industry Practices Rule (the Funeral Rule), are a few alternative price list options which can be utilized when working with government agencies; religious groups or societies; or, when serving the family of a deceased child or infant.  These alternative price list disclosures are highlighted below.  The permissible alternative methods are unique to each.  Remember that even if you use alternative price lists, you still must comply with all Funeral Rule provisions, including mandatory disclosures and itemized prices.

Government Agencies

Some funeral providers enter into agreements with government agencies to provide funeral arrangements for persons entitled to a government benefit. When engaging in such arrangements, you must follow all Funeral Rule requirements, including giving price lists to the government agent at the time you make or discuss such arrangements. You have two methods with which to comply with this requirement:

1. You can add the prices for these special situations to your regular price list; or
2. You can prepare a separate price list for these arrangements. If you prepare a separate price list, you need not make it available to anyone except the government agency or persons who qualify for the special arrangements.

Some government agencies choose to contract for funeral arrangements on a package basis. You may offer funeral arrangements to anyone — including a government agency — on a package basis, so long as the funeral packages are offered in addition to, not in place of, itemized prices.  A beneficiary of the government contracted funeral arrangement package is known as a “qualifying person”.  When a qualifying person makes inquiry about a package funeral arrangement, you still must provide the GPL, with itemized prices and disclosures, and comply with all other Rule requirements at this time.

Religious Groups and Memorial Societies

Some funeral providers enter into agreements with religious groups, burial societies, or memorial societies to arrange funerals for their members at special prices. You are free to make such arrangements, but you must still comply with the requirements of the Funeral Rule when doing so.

First, you must provide price lists to the representatives of these groups when they inquire about funeral arrangements on behalf of their members.  Additionally, if an individual group member makes an in-person inquiry about funeral arrangements, you must provide the individual with your price lists, as well. Even if a member chooses a package available only to society members, the member must have the opportunity to look at your price lists. You can either have separate price lists for qualifying members or include such prices on your regular price lists.

Services for Children and Infants

You can set different prices for funeral arrangements for children and infants. You can list the different fees in two ways. You can place these items on your General Price List, Casket Price List and Outer Burial Price List, along with your regular offerings; or you can prepare separate price lists for these arrangements. If you prepare separate price lists, you need not give them out to anyone except those persons inquiring about a funeral for a child or an infant.

If you work with any of these special groups, you may wish to review the price lists which you provide to their members or representatives.  If you are one of our Regulatory Support Services clients, let us know that you work with any of the groups we have discussed, and we will be happy to go over the price lists you provide to such groups and group members to assure that the list complies with the Funeral Rule.