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WDEOTAPE TRADLWG + Page

SERIES

NFDA VIDEOTAPE

All licensed and unlicensed funeral home staff must comply with the requirements of the Federal Trade Commission Funeral Rule serving the public, whether at-need or preneed. This training program is designed for in-house staff training; however, it is suitable for individual

I I Participation of all in this compliance training program demonstrates attests to the funeral home's commitment to protect the rights, health, and safety of the it serves, its employees, and the public. The funeral home should maintain updated training records of all verifying participation in this and other compliance-related training.

I A licensed funeral director completes this training program and who wishes to receive continuing education credits for or for the Funeral Service Professional (CFSP) program must complete a GPL Videotape Question Set in addition to the quiz that is part of the videotape package.

CONTENTS

2. FTC FUNERAL RULE

3 . FTC FUNERAL RULE GENERAL PRICE LIST

(Answers provided in videotape)

4. TRAINING FORM

ATTENDANCE FORM

6. VIDEOTAPE: FTC COMPLIANCE: THE GENERAL LIST

All components except the videotape may be reproduced.

NFDA GPL

5.

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GROUP TRAINING GUIDE

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NFZ)A GPL VIDEOTAPE i'XAIMNG +

SERIES

PART I.

PART INDIVIDUAL STUDY GUIDE

At least one week in advance of showing the GPL videotape, distribute the FUNERAL RULE handout to all for review (in groups

individually). they will be given a ten question, multiple-choice quiz on the Funeral Rule as part of the videotape training.

2. Show the videotape, following directions provided on the tape. After about 15 you be directed to a) stop the tape, b) distribute the General Price List (at that time or before the videotape begins), and allow time for all staff to complete the 10 multiple-choice questions.

3. Upon completion of the quiz by all staff, restart the videotape: General Counsel Scott will explain the correct answers to the quiz during: the balance of the videotape.

4. Have each participant who has satisfactorily completed the quiz sign the 'Training Verification" Maintain this form in individual employee training

5. Have each participant sign the Attendance" form. Maintain this in individual employee training records.

CONTINUING EDUCATION CREDIT: Each participant who wants complete in addition to the that is part of the videotape the GPL Videotape

package. TO ORDER: call at 1-800-228-6332 or go online at

Recommendation: include this NFDA GPL videotape in the home's foruse with all new home

Page 3

FTC FTC Funeral

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GPL KCDEOTAPE TRAIMNG + Page

1. At least one week in advance of showing the GPL videotape, review the FUNERAL RULE handout. Take the ten question, multiple-choice quiz on the Rule in advance of viewing the videotape or as part of the videotape training.

2. View the videotape, following directions provided on the tape. After about 15 minutes, you will be directed to stop the tape in order to complete the General Price List Quiz.

When you have finished the quiz, restart the videotape: General Counsel Scott will explain the correct answers to the quiz the balance of the videotape.

Sign the 'Training Verification" to be maintained in your employee records.

5. Sign a 'Training Attendance" form to be maintained in your employee training records.

CONTINUINGEDUCATION CREDIT: Each participant who wants must complete the GPL Videotape addition to the quiz that is part of the videotape package. TO ORDER: call NFDA at 1-800-228-6332 or go online at

Recommendation: include this NFDA GPL videotape in the home orientation for use with all new home

NFDA 4

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GPL TRAlMh'G 4 Page 5

Important: FTC Funeral Rule Review is for information purposes and has not been or approved by the It does not in any way replace or the text of FTC

Practices Rule (16 CFR Part 453). Contact theFTC or legal legal about funeral service compliance practices. and its representatives are not responsible or its representatives' compliance with any local, state, or federal laws, rules, and regulations funeral You obtain a copy of the FTC Funeral Rule by contacting or an FTC regional

This is a selective review of the Rule with the express purpose of supporting the General Price List presentation.

REVIEW CONTENTS

1. General List Distribution 2. The GPL, Casket Price List, and Outer Burial Container Price List 3. Telephone Price Disclosure 4. Statement of Funeral Goods and Services Selected 5. Permission to Embalm 6. Avoiding Misrepresentations 7. Tying Arrangements

General Price List Distribution

provider is any person, partnership or corporation that sells or offers to sell services to the public. The FTC requires funeral providers to give a

printed or typewritten general price list for retention to those who inquire in person about the funeral goods, fimeral services or price of goods or services offered by the provider. The funeral provider must give the list upon beginning the discussion of any of the following whether the discussion takes place in the home or elsewhere:

1. the prices of goods or funeral services the overall type of funeral service or disposition, or

3. specific funeral goods or funeral services offered by the funeral provider.

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NFDA WDEOTAPE TRAINUVG +

Removal. If you ask a family for permission to embalm during the removal them that embalming is not required by law except in certain special cases, if any, your

request does not trigger the requirement to present the GPL. However, if any other arrangements are discussed at that time, immediately present the GPL to the family.

Note the points:

The FTC Funeral Rule applies to both at-need and preneed arrangements.

Any individual inquiring about arrangements, the overall type of service or disposition, funeral goods or funeral services or the cost of goods or services is

. entitled to receive a copy of the GPL. Do not wait after you have answered an individual's inquiries to give him or her a of the GPL. Present the GPL and then answer the questions.

Physically give the GPL to the individual with whom you are discussing funeral arrangements or prices. You cannot simply indicate that the list is available. If the individual to accept the GPL, keep it readily available for reference during the arrangement meeting. Do not place the GPL in a binder.

Any discussion about funeral arrangements, the type of service or disposition, funeral goods or funeral services or the cost of funeral goods or services triggers the requirement to give a copy of the GPL. Do not wait until after you have answered an individual's inquiries to give him or her a copy of the GPL. Present the GPL and then answer the questions.

The GPL must be distributed to making in-person inquiries (as explained above). Never refuse to give a GPL to anyone, including competitors, representatives of the media, a partnership, corporation, consumer group, association, memorial society, government agency, religious entity, etc.

If licensed personnel are not available to meet with a shopper, unlicensed personnel should be trained to give the GPL to the shopper.

The GPL must be given for retention. Therefore, the GPL should not be put into a binder or plastic laminate. It should be in a that a shopper or consumer can take when leaving

the funeral home.

Keep several copies of the GPL with you when making removals or if you anticipate meeting a family off the home premises. For example, if you are visiting a family at the residence, at the hospital, a hospice, nursing home, etc. to plan arrangements or discuss prices, distribute the GPL.

you routinely use a removal service, the removal service have a copy of the funeral home's GPL to distribute to family members who inquire about goods, services, arrangements or prices the removal.

GPL Page 6

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You cannot charge a fee for the price list or place conditions on giving to consumers that the Rule requires you to give. Do not ask an individual to the

If an individual wants to modify a preneed contract for funeral goods and a GPL must be given to the individual at the of the discussion.

At the conference, the director should distribute at least one copy of the GPL to the family. must be given as soon as there is any discussion of funeral arrangements, funeral goods, funeral services or prices.

On occasions when there may be doubt regarding the GPL, it should always be the home's practice to distribute the GPL.

2. CASKET PRICE LIST OUTER BURIAL CONTAINER PRICE LIST

If yon do not list the retail price of each casket or outer burial container on your General Price List, you must prepare separate printed or typewritten Casket and Outer Burial Container Price Lists that do.

You must show the Casket Price List and Outer Burial Container Price List to anyone who asks in person about the caskets or alternative containers (both on the CPL) or outer burial containers that you offer or who inquires about prices for these items.

You must offer the and OBCPL when you begin caskets (or alternative containers) or outer burial containers BUT BEFORE showing these items. Consumers must be able to look at the price lists before discussing their options or seeing the actual goods. Do not provide access to an individual to the area in the funeral home displaying caskets or outer burial containers you have first offered a CPL or OBCPL.

As with the GPL, you must show a and to anyone who wishes to modify the particular goods already purchased under a contract.

The Casket Price List and Outer Burial Container Price List do not have to be offered to individuals for retention. You may request the individual to return the list after the discussion terminates.

The Casket Price List and Outer Burial Container Price List can be in any form, including a notebook or on a chart, as long as the list contains the required information displayed clear and conspicuous manner.

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NFDA GPL MDEOTAPE TUAlNING 8

If you use a manufacturer's showroom or supplier's showroom outside the funeral home, you must offer the or when the discussion of begins. begin the discussion in the funeral home, you must offer the lists. discussion does not begin arrival at the manufacturer's or supplier's showroom, do not have to show the lists

and the discussion begins.

The Casket Price List must list all caskets the funeral home routinely offers for sale and descriie the exterior construction and interior each (the manufacturer and model number are not required to be listed). All cremation caskets and alternative containers should also be on the Casket Price List and not on a separate container list.

The Outer Burial Container Price List should not be referred to as the "Vault List." It should briefly describe the exterior construction of the vaults and grave that the funeral home offers for sale.

3. TELEPHONE PRICE DISCLOSURE

The Funeral Rule requires funeral providers to give consumers accurate information the funeral home's price lists and any other available information that reasonably answers their questions when they telephone the funeral home to ask about prices or offerings.

You cap ask but you require callers to identify themselves (names, addresses or phone numbers) as a condition of providing the requested information. If they you must still answer their questions.

You cannot require consumers to come to the home in person to get price information.

You must give information to anyone making telephone inquiries about the funeral home's offerings or prices. You cannot to provide to anyone including competitors, representatives of the media, a partnership, corporation, group, association, memorial society, government agency, religious entity, etc.

If a funeral director is unavailable to provide the requested information to the telephone caller, non-licensed be trained to: a) provide the requested information the funeral home's price lists

or b) take a message and inform the caller that a director will telephone at a later time

with the requested information.

Note: funeral director calling back, he or she should return the call as soon as possible.

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NFDA GPL VWEOTAPE W N I N G

The Funeral Rule does not require you to mail or fax price lists to callers who request Funeral providers may also decline to give out price information to callers who telephone during hours. Those callers should be instructed to telephone the home during regular hours.

4. STATEMENT GOODS SERVICES SELECTED

The Statement of Funeral Goods and Services Selected is an itemized written list (statement) of the goods and services that the consumer has selected during an arrangement conference. It allows the consumer to evaluate his or her selections and to make any desired changes. A completed Statement of Funeral Goods and Services Selected must be given to consumer at the end of the arrangement meeting, whether at-need or preneed.

'List all of the individual goods and services that the consumer is purchasing together with the price for each item. You cannot 'lump together" goods and services that are listed separately on the GPL.

If you offer funeral packages (in addition to, not in place of, itemized prices of products and services as allowed by the Rule), the Statement must the package, listing individually each of the goods and services included in the package, and the package price. The prices of individual items in the package do not have to be listed.

Cash advance items must be listed separately on the Statement, together with the price of each item. exact of a cash advance item is unknown, a good faith estimate of the price must be included on the Statement. the latter case, be certain to explain to the consumer that prices for cash advance items are estimates and therefore subject to change.

funeral home charges for purchasing a cash advance item or if it receives and retains a rebate, commission or trade or volume discount for a cash advance item (whenever the funeral home pays the supplier less than it charges the family), the Statement must identify the marked-up cash advances using the following disclosure, word-for-word, exactly as the Rule prescribes:

"We charge you for our services in obtaining: [specify marked-up cash advance items]."

The Statement must include the following disclosure, word-for-word, exactly as the Rule

selected a funeral may require embalming such as a funeral with viewing, you may have to for embalming. You do not have to pay for did not approve selected such as direct cremation or immediate

. we charged you for embalming, we why

If the consumer chooses embalming, the home must list on the Statement the reason was selected.

Page 9

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The Statement must also include the following disclosure, word-for-word, exactly as the

are only for those items that you selected or that are required. required by law or by a cemetery or crematory use any items, we the reason in below: reason]

Note: If the consumer is compelled to purchase an item because of a legal, cemetery or crematory requirement, that requirement must be explained in writing on the Statement.

You must completely-fill out the Statement listing all items purchased and their respective prices. You should also list the total price of the goods and services purchased. If cash advance items are included and you do not know the exact cost of the as explained above, use your best estimate of the price.

5. PERMISSION TO EMBALM

Federal law does not require embalming under any circumstances.

A funeral home may only charge for embalming in one of these three circumstances:

1. State or local law requires embalming under the particular circumstances regardless of the family's wishes.

2. The funeral home has obtained express prior approval for embalming a family member or other authorized person.

3. All of the following

a. the funeral home is unable to contact a family member or other authorized person exercising due diligence (exhausting means known given the time

.constraints) and

b. the home has no reason to believe the does not want embalming performed and

the funeral home obtains subsequent approval. c.

The home must expressly request permission to embalm a family member or other authorized person 1) specifically asking for and obtaining permission, and 2) not misrepresenting when embalming is required. The permission does not have to be in writing as long as it is express approval, but it is recommended. Some states do require written authorization.

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In seeking subsequent approval embalming a body, the home must tell the family that if a funeral is selected where embalming is required (such as a funeral with formal viewing), a fee will be charged; but, if a funeral is selected where embalming is not required (such as a direct cremation or immediate no fee be charged.

funeral home cannot charge for embalming if the family chooses a where no embalming is required.

The reason for an fee must be explained on the Statement of Funeral Goods and Services Selected. a family is told that embalming is required for a reason, the specific reason should be listed on the Statement: simply noting consent" for embalming is not sufficient because it does not convey the actual reason.

6. AVOIDING MISREPRESENTATIONS

The Funeral Rule specifically prohibits providers making misrepresentations to consumers in the six areas:

1. Embalming. Funeral providers may not: 1) represent that state or local laws require embalming when that is not the case; 2) fail to disclose that embalming is not required by law except in certain special cases, if any; 3) require embalming for direct cremation, immediate

or a closed casket without viewing or visitation when is available and state or local laws do not require

2. Casket for Cremation. Funeral providers may not: 1) represent that state or local laws require a casket for direct cremations, and 2) represent that a casket is required for direct cremation. The home is required by the Funeral Rule to make alternative containers available for direct cremations.

3. Burial Container. Funeral providers may not: 1) represent that state or local laws or regulations of particular cemeteries require the purchase of outer burial containers when that is not the case, and 2) fail to disclose to persons arranging funerals that state law does not required the purchase of an outer container.

4. Legal and Cemetery Requirements. providers may not represent that state or local laws, or particular cemeteries or crematories require the purchase of any funeral goods or services when such is not the case.

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YIDEOTAPE i?WATNG 4 Page 12

5. Preservative and Protective Value Claims. Funeral providers may not 1) represent that goods or services will delay the natural decomposition of human remains for a long-

term or time, and 2) represent that funeral goods have protective features or-.will protect the body gravesite substances when that is not the case.

The funeral home must avoid creating the impression that embalming will preserve the body and should not make claims regarding the ability of caskets and vaults to protect the body from gravesite substances. The home should not make warranty claims, although it should display the (if any) made by manufacturers of caskets and vaults.

6. Cash Advances. Funeral providers may not 1) represent that the charged for cash advance items is the same as the cost to the provider when such is not the case, and 2) fail to disclose to persons arranging that the price being charged for a cash advance item is not the same as the cost to the provider for the item when such is not the case.

TYING ARRANGEMENTS

One of the principal objectives of the Rule is to allow consumers to select the particular goods and services that they wish to purchase. An tying arrangement exists if a funeral provider requires a consumer to purchase unwanted or unneeded items in order to obtain the items he or she does want to select.

ALLOWABLE FEES. The Rule expressly prohibits funeral providers charging any fee as a condition of furnishing any funeral goods or services, except for the following fees:

The non-declinable Basic Fee. 2. The fees for the goods and selected by the consumer.

and 3. The fees for the funeral goods and required to be purchased by law, the

cemetery or the crematory as identified and explained on the Statement of Funeral Goods and Services Selected.

EXCEPTIONS TO CONSUMER'S RIGHT TO CHOOSE. The Rule allows three exceptions to the consumer's right to choose only the goods or services wanted, a s follows:

1. The non-declinable Basic Fee, 2. Funeral goods and services required to be purchased by Iaw, the cemetery or the

crematory, and

3. Impossible, impractical or excessively burdensome requests; however, a funeral provider cannot a request simply because it does not like it or approve of it.

4. A funeral provider also does not have to comply with a request for an item that is not normally offered.

NFDA GPL

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Standards the exact determination of an impossible, impractical or burdensome request imprecise. Some have been established, however, through the development of Funeral Rule and court rulings. follows:

a. Funeral providers should never refuse service to a family that indicates it will be using third party merchandise caskets or vaults). No type of fee for handling third party merchandise may be charged to the family the funeral home, and although the family may be asked to sign an indemnification it cannot be required to do so.

b. a consumer wishes to purchase a casket or vault from your funeralhome but wishes to use another funeral home for all other goods and services, your funeral home may to sell to the consumer.

c. a consumer wishes to purchase all goods and another funeral home but wishes to use your home for the visitation and ceremony only, your funeral home may refuse the request.

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NFDA GPL VWEOTAPE TR41MNG 14

7-

SERIES

Page of

DIRECTIONS. Read the following questions carefully. Choose the best answer and mark it in the space provided, based on in the Funeral Rule handout

1. While you are removing a body a private residence, the adult daughter of the decedent asks you if the family may have the visitation at the residence rather the funeral home. Does this question trigger the requirement to a General Price List to the daughter?

A. Yes, because she inquired about a specific B. No, because in asking the question she did not commit to purchasing the service. C. No, because the question was not asked the funeral arrangement

conference.

Your home utilizes an independent contractor for all weekend and night removals. Does the funeral home have to supply the contractor with copies of its General Price List for the contractor to to family members who may ask about fimeral goods or services during the removal?

No, because the removal personnel are independent contractors who are not under your control.

B. Yes, because you routinely use the removal service. C. Yes, but if the personnel are licensed directors.

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NIiDA WDEOTAPE T R 4 1 . G 15

3. You believe a competitor may be calling your fimeral home about your prices for the purpose of undercutting your prices. You therefore instruct your funeral home staff not to provide price over the telephone unless the caller identifies herself. Is this a practice under the Funeral Rule?

A. Yes, because you have the right to ask a caller to identify him or herself as a condition of receiving price information over the telephone.

B. Yes, because you do not have to provide price information over the telephone to a competitor.

C. No, because while you are permitted to ask a caller to identify him or herself, you cannot to provide price information over the telephone if the caller does not choose to identify him or herself.

D. No, because the Funeral Rule does not permit you to ask a caller to identify him

home has adopted a policy that licensed personnel should distribute price lists to consumers. Therefore, if a

4. director is not available, the receptionist

inform a shopper return at a later time or to schedule an with a funeral director in order to receive a General Price List. Is this policy

A. No. When a director is the receptionist should the GPL and answer any questions the have about funeral goods and

B. No. The receptionist should be instructed to distnbute the GPL, but may also be instructed to decline answering questions long as the consumer is informed of when he or she will be able to meet with a funeral director.

C. may be instructed not to price lists to consumers as Iong as they consumers when a funeral director be available to meet with them.

5 . At the very beginning of the arrangement conference, a member of the distributes to the family an information packet the home containing, among other things, a However, when making arrangements with the later, the funeral director forgets to refer to the GPL included the packet. Has the fimeral director violated the Funeral Rule?

No, the fimeral director has complied with the rule since, the GPL was given to the prior to any discussion of goods and services.

B. Yes, because a director is required physically hand the GPL to a and cannot comply with the Funeral Rule simply by placing the GPL inside an packet.

the GPL with the family when

GPL + Page

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VWEOTAPE TRAINING + 16

--

6. An elderly woman has prearranged and paid for a funeral with a visitation. she dies, her daughter comes to the funeral home to the preneed arrangements. In discussing the visitation with you, she decides against holding visitation. Do you now have to present her with the GPL?

A. No, because the daughter is not purchasing any additional items. B. Yes, because the GPL must be given to any consumer who is preneed

arrangements. Yes, because the GPL must be given whenever a changes preneed arrangements by the selection of goods and services previously

7. At the beginning of an arrangement conference, you are obtaining information from the family for the obituary. When the family that the decedent was a veteran, you

then that they are entitled to a at the local veterans' Does this disclosure trigger the requirement to immediately distribute the GPL to the family?

A. No, because discussions with family members regarding veterans' benefits and other preliminary maters do not trigger the requirement to the GPL.

B. Yes, because the director was involved in a of goods that are available to the

C. the funeral home also sells markers.

8. During the arrangement conference with a family, one of the family members asks an alternative container may be used instead of a casket for a direct cremation. You have previously distributed the GPL to the Does the question about an container now require you to also distribute the Casket Price List?

A No, because alternative containers do not have to be listed on the Casket Price List. No, because the consumer did not ask to see the alternative container.

C. Yes, because upon any discussion of caskets or alternative a Casket List must be presented to the consumer.

9. The funeral home places all of its price lists in a three-ring binder which is presented to families at the beginning of an arrangement conference. In addition, the funeral home prints its GPL on a one-page brochure that is available on a table in the main entranceway of the

home. Does this price list distribution policy comply with the Funeral Rule?

A. No, because the GPL must be given to consumers for retention, and in this case receive the GPL enclosed in a binder.

B. Yes, since consumers receive price lists to any of goods or services. C. Yes, because in addition to the binder, the GPL brochure is in a form that consumers may

take with them and it is readily available to consumers.

NFDA GPL Page

FTC FUNERQL RULE QUIZ 4

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NFDA MDEOTAPE l X 4 I . G + Page 17

Page 4 of

10. A family member out of town,who will not be able to attend the makes all the funeral arrangement. with you over the telephone. Are you required to send that individual a GPL and Statement of Goods and Selected?

A. Yes. You must send the GPL to the consumer because there was a discussion of goods and services, and you must send the Statement of Funeral Goods and Services Selected since the consumer arranged the funeral.

B. No-since no face-to-face meeting took place the consumer, the Funeral Rule does not require you to send either the GPL or the Statement to the consumer.

C. No. You are not required to send a GPL because there was no face-to-face discussion with the consumer. However, since the consumer arranged a a Statement should be mailed to the promptly.

GPL

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CPL KDEOTAPE TMINING + P a ~ e 18

DIRECTIONS: Each participant must sign this

The funeral home should maintain records to verify that the training has been completed. Maintain this in individual employee training records.

Date of Training:

Location:

I have completed the above compliance training program and I am knowledgeable its contents.

Participant Signature:

Date Signed:

NFDA