9.3 Casket & OBC Price Lists & Statement of Goods and Services
Key Takeaways
- If individual casket prices are not fully listed on the GPL, show a Casket Price List (CPL) when casket discussion begins—and in any event before showing caskets—including retail prices, identifying descriptions, business name, caption, and effective date.
- If individual outer burial container prices are not fully on the GPL, show an Outer Burial Container Price List before showing containers, with required identifying information and the mandatory OBC legal/cemetery disclosure.
- Unlike the GPL, the CPL and OBCPL need not be given for the consumer to keep (though they may be); price cards on units alone are not a substitute for the lists.
- The Statement of Funeral Goods and Services Selected is the itemized written record of what this family selected, given at the conclusion of the arrangements discussion—not postponed until the funeral or a later mail-only delivery when arrangements were face-to-face.
- The SFGS must itemize goods/services and cash advances, show a total, and include required disclosures on legal requirements, embalming, and cash-advance service charges/rebates when applicable.
9.3 Casket & OBC Price Lists & Statement of Goods and Services
Quick Answer: Show the Casket Price List when casket discussion begins—before showing caskets. Show the Outer Burial Container Price List when OBC discussion begins—before showing containers. At the end of arrangements, give an itemized Statement of Funeral Goods and Services Selected that matches selections and prices, lists cash advances, states the total, and carries the Rule’s legal-requirement, embalming, and cash-advance disclosures. The GPL is the master menu for retention; the CPL/OBCPL are specialized merchandise tools; the SFGS is the family’s deal sheet.
Casket Price List (CPL)
If you do not place the retail price of each casket on the GPL, you must prepare a separate printed or typewritten Casket Price List.
Information Required on the CPL
| Element | Requirement |
|---|---|
| Business name | Funeral provider’s place of business |
| Caption | “Casket Price List” |
| Effective date | Date prices are effective |
| Prices | Retail price of each casket and alternative container regularly offered that does not require special ordering |
| Identification | Enough description to identify the unit (e.g., metal gauge or wood type, exterior appearance, interior fabric)—not photo or model number alone |
Special ordering means units not in stock and not part of regular offerings. You need not list every special-order possibility. Alternative containers offered for direct cremation belong on the CPL with caskets—not on a hidden separate list. Formats may include notebooks, brochures, or charts if clear and conspicuous. Photo books used for selection must incorporate CPL-required information and the heading.
When the CPL Must Be Shown
- Show the CPL to anyone who asks in person about caskets, alternative containers, or their prices.
- Offer it when you begin discussing caskets or alternative containers—and in any event before showing those items.
- Consumers must be able to see prices before browsing the showroom or hearing only oral prices.
- Individual price cards on caskets may be used only in addition to a CPL—not as a substitute.
- Unlike the GPL, you need not give the CPL for the consumer to keep (you may).
- If discussion begins at the funeral home, offer the CPL there—even if the family later goes to a manufacturer showroom. If discussion first begins at an outside showroom, offer the CPL when discussion begins there.
- Pre-need modifications that change casket selection also trigger showing the CPL.
Exam line: Families should not first learn casket prices by walking into a showroom and reading tags, or by hearing prices only after emotional attachment forms.
Outer Burial Container Price List (OBCPL)
An outer burial container is any container designed to be placed around the casket in the grave (burial vaults, grave boxes, grave liners).
If you sell OBCs and do not list each retail price on the GPL, prepare a separate Outer Burial Container Price List with:
- Business name;
- Caption: “Outer Burial Container Price List”;
- Effective date;
- Retail prices and identifying descriptions for regularly offered non-special-order containers;
- The mandatory disclosure that in most areas, state or local law does not require a container around the casket, but many cemeteries require one so the grave will not sink, and that either a grave liner or burial vault can satisfy those cemetery requirements (wording per the Rule; omit “in most areas of the country” only when appropriate under the Rule’s instructions for your jurisdiction).
When the OBCPL Must Be Shown
- Show it to persons who inquire in person about OBC offerings or prices.
- Offer it when OBC discussion begins—and before showing containers.
- Price cards alone are not enough; retention is not required (but allowed).
- You need not sell OBCs; if you do not sell them, you do not invent a list.
Truthfulness link: Never claim state law requires an OBC when it does not; never claim a particular cemetery requires one when it does not. If a cemetery truly requires a container, explain that fact and document legal/cemetery requirements on the SFGS when you tell a family they must buy an item for that reason.
Statement of Funeral Goods and Services Selected (SFGS)
The Statement of Funeral Goods and Services Selected (also called the itemized statement or “Statement”) is the written list of goods and services this consumer selected during the arrangements conference. It lets the family review choices and request changes.
Timing and Delivery
| Setting | SFGS timing |
|---|---|
| In-person arrangements | Give a completed Statement at the end of the arrangements discussion |
| Not compliant | Waiting until the funeral day, or only mailing later after a face-to-face conference concluded without giving the Statement |
| Phone arrangements | Give the Statement at the earliest opportunity; if the consumer later finalizes in person, provide the GPL and complete the Statement when arrangements are finalized |
| Never visits before disposition | Still provide or send a completed Statement as soon as possible |
The Rule does not dictate when payment must be collected—that is between firm and customer—but it does dictate itemized documentation timing.
Cost Information on the SFGS
- List each individual good and service purchased with its price.
- Do not collapse GPL categories into vague buckets like only “Services,” “Facilities,” and “Automotive.”
- If the family selects a package after itemized prices were offered, describe the package, list included goods/services individually, and state the package price.
- List each cash advance separately with its price (or a good-faith estimate if the exact amount is unknown, with actual charges provided before final payment).
- Provide the total cost of arrangements selected (goods/services plus cash advances).
Cash advances are third-party items obtained on the consumer’s behalf or described as cash advances/accommodations/disbursements—commonly cemetery or crematory charges, clergy honoraria, flowers, musicians, obituary notices, death certificates, public transportation, pallbearers, gratuities, and similar items.
Required SFGS Disclosures (Three)
Use the Rule’s prescribed wording concepts:
- Legal requirements — Charges are only for selected or required items; if law, cemetery, or crematory requires an item, explain the reason in writing on the Statement.
- Embalming — If a funeral may require embalming (e.g., with viewing), the consumer may have to pay for it; the consumer does not have to pay for unapproved embalming if arrangements such as direct cremation or immediate burial are selected; if embalming was charged, explain why on the Statement.
- Cash advance items — If you charge for obtaining cash advances or receive/retain a rebate, commission, or trade/volume discount, disclose that you charge for your services in obtaining the specified cash advance items, next to the cash-advance list.
Consumer Signature Practices
The federal Rule focuses on providing the completed itemized Statement with required content; it does not turn the SFGS into a substitute for every state-required authorization form. Professional practice and many state rules still favor signatures acknowledging receipt of the Statement, authorizations (embalming, cremation), and contracts. For NBE:
- Treat the SFGS as the itemized selection document given at conference end.
- Do not assume a signature alone cures missing itemization or missing mandatory disclosures.
- Keep a copy for the one-year recordkeeping period (and longer if state law or firm policy requires).
Relationship: GPL, CPL, OBCPL, and SFGS
| Document | Role | Retention to consumer? | When |
|---|---|---|---|
| GPL | Master itemized menu of services/goods prices + mandatory disclosures | Yes—must offer to keep | Start of triggering face-to-face discussion |
| CPL | Detailed casket/alternative-container prices | Not required (may offer) | Before showing/discussing caskets |
| OBCPL | Detailed outer burial container prices + OBC disclosure | Not required (may offer) | Before showing/discussing OBCs |
| SFGS | What this family selected and the prices/totals/disclosures for that transaction | Yes—give completed statement | End of arrangements |
Flow: GPL opens transparency → CPL/OBCPL support merchandise selection → SFGS locks the deal in writing.
Scenarios
Scenario A — Showroom first: A counselor walks a family into the casket room before any price list. Violation pattern. Offer CPL (or full casket prices on GPL) before showing units.
Scenario B — Package-only Statement: SFGS shows one line: “Traditional Package $8,999.” Violation pattern if it fails to itemize components as the Rule requires when packages are used.
Scenario C — Cemetery vault rule: Cemetery requires an OBC. Explain the cemetery requirement (not “federal law”), show OBCPL before models, and write the cemetery requirement on the SFGS if you stated the item was required.
Scenario D — Pre-need casket upgrade: Survivor wants a different casket than the 1995 contract. Show GPL and CPL, then complete a new itemized Statement for changes.
Scenario E — Cash advance estimate: Obituary cost unknown at conference. Enter a good-faith estimate on the SFGS; provide actual charges before final payment.
NBE Traps for This Section
| Trap | Correction |
|---|---|
| CPL can wait until after emotional showroom tour | Before showing caskets |
| GPL and CPL have identical retention rules | GPL must be for keeps; CPL/OBCPL need not be |
| SFGS can be mailed after the funeral as the primary delivery after a face-to-face conference | Give at end of arrangements discussion |
| Cash advances can be buried in a non-itemized “misc” total | List separately; disclose markups/rebates when required |
| Price tags on vaults replace the OBCPL | Lists required (unless full prices on GPL) |
| SFGS is the same document as the GPL | GPL = menu; SFGS = this family’s selections |
Bottom line: CPL and OBCPL protect informed merchandise choice before display. The SFGS turns choices into an itemized, disclosed, totalled written statement at conference close. Together with the GPL, they form the Funeral Rule’s complete paper path from inquiry to agreement.
When must the Casket Price List be offered if the firm uses a separate CPL?
How does CPL/OBCPL retention differ from GPL retention under the Funeral Rule?
When should the Statement of Funeral Goods and Services Selected be given after an in-person arrangements conference?
Which SFGS practice is consistent with the Funeral Rule?