Draft guidance on funeral costs consultation: analysis of responses

Independent analysis of responses to our public consultation about draft guidance on funeral costs.

Definition of a Simple Funeral

Recognising that there has historically been some variation in what is offered by different funeral directors as part of a 'simple funeral', the draft guidance set out a standard definition of a simple funeral which was developed with input from appropriate stakeholders. The aim of having a single shared definition is to allow consumers to make more accurate comparisons between service providers (i.e. similar to those selecting a standard cremation, discussed above).

Necessary Elements

The proposed simple funeral definition set out in the draft guidance includes:

  • the funeral director's services;
  • attending to the necessary arrangements, such as completion of necessary certification, taking instructions and providing guidance on registration and legally-required procedures;
  • provision of the necessary staff for care of the deceased and support for the bereaved;
  • provision of an appropriate and robust lined coffin suitable for burial or cremation;
  • transportation of the deceased person from the place of death during normal working hours (normally within ten miles but taking into account local circumstances);
  • appropriate arrangements for the uplift of the deceased and care of the deceased person prior to the funeral, in appropriate facilities;
  • viewing of the deceased person, by appointment;
  • provision of a hearse or other appropriate vehicle direct to the nearest crematorium or cemetery at a date and time agreed with the funeral director and clearly described to the client;
  • the opportunity to hold a service at the cemetery or crematorium; and
  • if burial is specified (where this is available locally) this may involve an additional charge.

The definition does not include embalming, provision of a limousine or any third party fees or disbursements payable on the client's behalf (such as lair fees, interment fees and cremation fees, etc.).

Q7. Do you think that the simple funeral service definition set out in the draft guidance captures all of the necessary elements?

  Number Percentage
Yes 24 49%
No 20 41%
Don't know 3 6%
No response 2 4%
Total 49 100%

Just under half of all respondents said that they felt that the definition set out in the draft guidance captured all necessary elements. Almost an equal number said that it did not, and a small number were unsure. This question arguably presented the clearest split in opinion across the consultation and generated a significant volume of feedback.

Q8. If not, please provide suggestions for items that you think should be added or removed.

Among those who were not content with the definition, the main concerns were that there remained some ambiguity for service descriptions which may result in some elements still being differently interpreted by service providers, and the bereaved alike. For example, use of the terms 'necessary staff', or 'necessary arrangements'. These were subjective and so could lend themselves to different services still being delivered under the single 'simple funeral' definition, it was suggested. Terms such as 'uplift' may also need to be more clearly explained and one respondent also noted that the inclusion of additional costs for burial was unclear, as it did not specify exactly why this may incur additional costs.

Two organisations also commented that the definition may be unnecessary given that a legislated definition of a 'normal funeral' already exists in Westminster Statute, i.e. the Social Fund Maternity and Funeral Expenses (General) Regulations 1987. Others said that they operated using the definition of a 'simple funeral' set out in the National Association of Funeral Directors (NAFD) Code of Practice (although now removed), and felt that this was adequate[4].

Some respondents representing those in the industry also commented that, while they supported a unified simple funeral description, the definition seemed premature as the statutory code of practice was, as yet, unpublished. The code may make several of the included elements superfluous or add extra as yet unrecognised elements, it was suggested:

"We can comment that at present the proposed list, whilst honourable and acceptable may not be sustainable under the continued presence of this very guidance. The act of caring, washing, preparing, dressing and coffining a decedent has an intrinsic skill and value, to date ignored by this draft guidance. There is much more work to be completed before this element can be properly drafted and we recommend its removal until at least the statutory code of practice has been finalised."

Consequently, there were some respondents who were unprepared to provide a response to this consultation question at present.


Among those who provided specific comments, one area that caused particular concern was the transportation of the deceased person from the place of death during normal working hours (normally within ten miles but taking into account local circumstances). It was highlighted that, in some more rural areas, this may be problematic and more robust wording was required around the transportation of deceased in remote communities to take account of regions where the place of death routinely exceeds 10 miles. The current wording "taking into account local circumstances" was too vague, it was suggested.

One respondent also commented that the definition should make clear that transportation of the deceased from the place of death should be in a suitable hearse, estate car or private ambulance, which is appropriately licensed, insured and maintained (i.e. adding greater clarity to the definition proposed). Others questioned if provision of a 'family car' to transport family members to funeral services should also be included routinely. This would apply to a large number of people living in households without access to a vehicle, and was especially important for those living in poverty in rural areas. The definition should again stipulate that this should be appropriately licensed, insured and maintained, it was felt.

One respondent suggested that a bereaved family should not be excluded from accessing the simple funeral by virtue of the fact that their relative died outside normal working hours, and so suggested removal of that restriction. Another also indicated that the funeral package should accommodate collection of the deceased at any time of day or night, as required (and not be constrained by working hours).

Viewing of the Body, Including Timings

Some organisations commented that they specifically welcomed the inclusion of viewing of the body as part of the standard service, however, there were some concerns that non-standard viewings (out of hours) may incur additional costs and the right to charge for this must be sustained:

"While supportive of the bereaved having the option of viewing the deceased, [organisation] also notes that the costs attached to such a service - which can include additional treatment and dressing of the body, the opening of premises after hours, and staff overtime - can be higher than consumers would expect. Considering this, [organisation] believes that the cost of a viewing should be transparent to the consumer and, while the service should be part of the simple funeral package, it should remain optional to the consumer."

Indeed, some comments were also raised in relation to any services provided outside of normal working hours, with a view that requests for 'standard' elements may rightfully and legitimately incur additional charges, and so be accepted as such. For example, viewing of the body as part of the standard package was acceptable, but not if viewing was requested at anti-social hours. One organisation commented that including 'out of hours viewing' as part of the definition of what is not included in a simple definition may help to reinforce this point.

One respondent commented specifically that viewing should always be offered and so agreed that this be included in the simple definition, but advised that funeral directors must use sensitivity and discretion to ensure that customers are always aware of what this may entail, and how the body may appear. It was important, respondents noted, that although offered as part of the simple package, the choice to view the body should always remain optional.

Celebrants and Services

There was some disagreement about whether a separate church or other service should be included within the simple funeral service definition, given that restricting services to only those at the cemetery or crematorium may reduce costs.

One organisation commented that, while they agreed that the proposed definition included "the opportunity to hold a service at the cemetery or crematoria", it may also be necessary to set out explicitly that this would not include an officiant and that 'service officiant' be added to the list of what is not included, for the avoidance of doubt. The same organisation also suggested that, where additional items are opted for by a consumer, these should be clearly itemised and separately costed on any quote provided:

"…where consumers choose to modify or upgrade a simple funeral package, the written estimate provided to the consumer should distinguish clearly between those services that are set as part of the simple funeral package and those services that are additional. This will help consumers understand the cost implications of any changes they wish to make."

Support for Bereaved

Another area of perceived ambiguity within the definition was "support for the bereaved". This could encompass a wide range of different service approaches and standards, it was suggested, and so needed to be more precisely defined:

"Many funeral directors take pride in the support they offer bereaved families, however, the levels of support and the methods of delivery differ from business to business. Often, funeral directors thread this support through all that they do, in their everyday interactions with families, and deliver this support in such a way that it is difficult to quantify in a service description."

The same organisation noted that services varied greatly in this regard and while some funeral directors may offer only limited in-house support from trained staff, many others will signpost the bereaved to appropriate external counseling and support services. A better understanding of the different practices that exists in this regard may need to be captured by the Scottish Government and reflected in the guidance, to ensure some parity across the field, it was suggested.

Additional Elements

Suggestions for specific additional items which should be covered by the proposed definition, or changes to extend the current definition (each put forward by only one respondent only), included:

  • bathing of the deceased (similar to the point made for standard cremations above, it was noted that the standard service should include bathing and the putting on of a new set of clothes a day or two before cremation, to accommodate the requirements set out by particular religions);
  • storage of the body in climate-controlled mortuary facilities;
  • the provision of an environmentally friendly option for a coffin (e.g. wicker or cardboard)[5];
  • the provision of pall bearers (unless the family wish to bear the coffin);
  • that the body of the deceased person must be stored in a refrigerated area or cold room in accordance with the relevant specifications (e.g. Health & Safety Executive, Environmental Health, industry guidance);
  • that religious wishes are catered for, for example, the opportunity to hold a service at the cemetery, crematorium or place of worship, including attending to the necessary arrangements, and contacting local faith groups where appropriate; and
  • explanation of who would be liable to pay third party fees (including the purchase of ground and lair fees, interment fees and cremation fees) if the client is unable to afford it (with a specific request that it be made clear that funeral directors should not have to carry this cost).

Two respondents also suggested that that the deceased person should be dressed appropriately in a gown or shroud or clothing provided by the family and that the definition should include this.

Others suggested that 'additional' or 'optional' items should be for individual funeral directors to offer at their own discretion, and without constraint and the guidance should actively promote the wide range of products and services available.

One respondent indicated that they did not feel that clients should have to pay more for a simple burial if burial was specified, and so felt that this should be removed from the definition. Another indicated that they were unsure why an additional charge for this service element would be required.

There was also some disagreement around whether embalming should or should not be included in the definition. While one individual expressed a view that it should be included, several organisations welcomed the fact that it was not. One stressed that it is specifically prohibited in cases of infectious disease and where natural burial is proposed and so would not be appropriate as standard.

Other Comments on the Definition

On a more general note, some suggested that the definition was repetitive in places and could be better structured, to separate out services provided by the funeral director (i.e. transportation and handling of the body) and other costs (i.e. provision of a coffin, provision of a hearse, and local authority or crematorium fees, etc.):

"This would help make the actual cost more easily understood and may also align the layout and understanding to that of a social (National Assistance Funeral) interment undertaken by a local authority."

Other organisations indicated that, while they welcomed the definition of a 'simple funeral' to allow consistency and comparability across the sector, they felt it was important that funeral directors should not be mandated to provide a pre-set low-cost funeral package.

On a related note, several organisations noted that cultural and religious variations may mean that a 'simple funeral' is not appropriate or applicable to some customers and so the optional provision of a 'simple funeral must be at the discretion of each funeral business (with the facility to adapt or refine it to include other faith groups, as appropriate). This should be clearly stated in any guidance from the Scottish Government, it was suggested.

Another organisation noted that the draft guidance for funeral directors could be modified to explain that, while funeral directors may allow modifications to the simple funeral, in doing so, they must clearly note this to the consumer and provide clear and transparent pricing in that regard, i.e. "Any available amends should be clearly defined, including the cost implication."

One respondent again suggested that the term 'simple funeral' may be viewed by some to be derogatory and that the term 'standard funeral' (similar to 'standard cremation') may be more appropriate[6].

Although not answering the question directly, another respondent suggested that a clear definition of a 'direct' funeral may also be needed within the guidance and they provided an example of what this may include and not include. Providing clarity around a direct funeral was needed, they felt, to ensure that the deceased was appropriately cared for in such cases (i.e. "the absolute need to bring the deceased into the care of the funeral director, in appropriate facilities".)

Finally, although again not answering the question directly, one third sector advice organisation welcomed the acknowledgement in the consultation paper that consumer enquiries around funeral costs and what they entail is currently limited, and so welcomed a clear definition which may encourage people to attempt to get quotes from more than one funeral director, and to compare like with like when assessing which providers offer best value for money. The same organisation also commented that they were pleased to see that the costs of any additional aspects or alternations to a simple funeral be should be proportionate to the request - these should also be made clear to the consumer, it was stressed.

One individual suggested that the definition was bureaucratic and unnecessary as it did not contribute to reducing actual costs in any way. An alternative would be to present advice on the legal minimum cost to process a funeral, it was suggested:

"Many people either in grief, a lack of confidence, poverty or understanding of the legal requirements may be agreeing to funeral plans based on misinformation or an assumption that certain costs must be applied to funerals when in fact there is a process which can accommodate a less costly process which people are not fully informed of at point of contact with public servants or private companies."

Presenting the basic legal costs would, perhaps, remove or reduce some perceptions among the wider public that private and statutory providers were focused only on profit, it was suggested. Again, this was a lone view.

Overall, there was a mix in responses to this question, but a shared sense that greater clarity was required and that the current definition was not ready to be operationalised.


Email: funeralpoverty@gov.scot

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