Funeral GPL checker and upsell shield

01Problem

Families buy in shock, on a 24–72 hour clock, from the business that has the body. NFDA’s 2023 General Price List Study (press Dec. 8, 2023; still the latest complete public median series as of Oct. 30, 2026) put a funeral with viewing and burial at a median $8,300, $9,995 with a vault, and a funeral with viewing and cremation at $6,280 — excluding cemetery plot, opening/closing, and marker. NFDA’s 2026 Cremation & Burial Report (press Oct. 28, 2026) projects a 64.3% U.S. cremation rate; CANA reports 62.8% for 2025. The FTC Funeral Rule, 16 CFR Part 453, is still the 1994 text. Civil penalties are $53,088 per violation at 2025 FTC levels, which remain in force for 2026 because OMB cancelled the 2026 inflation adjustment (M-26-11; FTC 91 FR 2026-18853, Sept. 15, 2026). Online posting of the General Price List is still not federally required.

02Intake

Who has legal authority to control disposition under the death-state next-of-kin statute.
Disposition goal: direct cremation, cremation with memorial, immediate burial, full funeral with viewing, green burial, donation.
Veteran / spouse-of-veteran status; DD214.
Faith requirements (timing, embalming, closed casket, tahara).
Where the body is now (hospital morgue, ME, home) and any hold.
At least three funeral homes; GPLs (PDF or photos); phone-quote notes on the same 10 lines.
Casket/urn source (funeral home vs. third party).
Cemetery contract if any (plot deed, vault rule, opening/closing, endowment care).
Pre-need contract, trust or insurance, trustee/insurer, account number, irrevocable?
How many death certificates, obituary, clergy, other cash-advance items.

03Playbook

01
Death is not an emergency for shopping. If the person died in a hospital, ask whether the body can stay in the morgue for a couple of days while you call (ProPublica / Joshua Slocum, Sept. 9, 2022). Call at least three funeral homes before authorizing removal. 16 CFR 453.2(b)(1): they must give telephone callers accurate information from the price lists. Callers need not give a name first. FTC’s 2023 undercover phone sweep (278 homes; staff report Nov. 20, 2024) found 7% gave no prices in business hours, 26% none after hours; at least 33% quoted packages without itemized prices; 39 warning letters (Jan. 25, 2024). A home that refuses phone prices is a Rule violator; hang up.
02
Ask every home for the same itemized lines, not a package name. “Direct Cremation, All-Inclusive” is a shopping phrase, not a legal term. On the phone get: non-declinable basic services fee; transfer/removal; direct cremation with purchaser-provided container and with alternative container; whether the crematory fee is inside that price; refrigeration per day; embalming; viewing; ceremony; hearse; lowest casket; alternative container; immediate burial; cash-advance estimates. FCAPA’s June 2020 Philadelphia survey found direct cremation from $750 to $4,340 “for the same exact thing” — a 2020 local range, still the right illustration of spread.
03
In person, take the GPL to keep at the start of any discussion of prices, type of funeral, or specific goods/services (453.2(b)(4)). A binder they will not let you walk out with is noncompliant. See the Casket Price List and Outer Burial Container Price List before anyone walks you into the showroom (453.2(b)(2)–(3)).
04
Buy only what you select. 16 CFR 453.4: no tying. The only non-declinable funeral-home fee is the basic services fee (plus items actually required by law, identified in writing on the Statement). Packages are legal as extra information (453.2(b)(6)) if you can still itemize and decline. NFDA 2023 cremation-table basic-services median $2,495.
05
Direct cremation cannot be conditioned on a casket. The home or crematory must offer an alternative container (unfinished wood, fiberboard, composition) (453.4(a); 453.1(a)). Third-party casket or urn: the home cannot refuse it and cannot charge a handling fee. A “won’t be responsible for damage” warning on a Costco/online casket is policy, not a legal handling fee; inspect on arrival and photograph.
06
Embalming is almost never required by law. 453.3(a): it is deceptive to say the law requires embalming when it does not. FTC: no state law requires routine embalming for every death; some states require embalming or refrigeration if the body is not buried or cremated within a set time; funeral-home viewing policies are not law. 453.5: no embalming fee unless (1) law requires it regardless of funeral choice, (2) prior approval expressly for embalming, or (3) they could not reach family after due diligence, had no reason to think the family objected, and later get approval after disclosing that a fee is charged only if you select a service that requires embalming. Federal law does not require embalming under any circumstances (FTC Complying guide).
07
Cash advances. Death certificates, crematory fee, clergy, flowers, obituary, escort. If the home keeps a commission, rebate, or volume discount, the Statement must disclose “We charge you for our services in obtaining: (specify)” (453.3(f)). Ask for the third-party invoice. FCAPA 2020 Philly crematory fees ran $200–$495 and were often outside the quoted “direct cremation.”
08
Cemetery is a different industry. The Rule covers funeral providers (goods and services). Standalone cemeteries, monument dealers, and casket stores are outside it. Outer burial containers are not required by state law anywhere in the U.S. (FTC; 453.3(c) disclosure). Many cemeteries require a liner or vault so the grave will not sink — that is cemetery policy. Price plot, opening/closing, vault, endowment care, and marker separately. For eligible veterans, price a national or state veterans cemetery first (free plot, opening/closing, grave liner, government marker, perpetual care, flag, honors). The family still pays the funeral home.
09
Negotiate once you have competing GPLs. ProPublica/Slocum script (advocacy, not a legal right): “We would love to give you our business. Can you meet your competitor’s price? If you can’t lower your prices, we’ll have to have the body removed to a different place.” You may move remains; the first home bills only for services already authorized (transfer, refrigeration).
10
Get the Statement of Funeral Goods and Services Selected at the end of arrangements (453.2(b)(5)): each selected item and its price, specifically itemized cash advances (or a good-faith estimate plus actuals before the final bill is paid), and total cost. Do not pay until that paper is in your hands. Providers must keep price lists one year after last distribution and each Statement one year from the arrangements conference (453.6).
11
Stack benefits. SSA lump-sum death payment $255 (42 U.S.C. 402(i)), generally to a spouse who lived in the same household, else an eligible child; apply within two years (Form SSA-8). VA burial allowance (va.gov updated Oct. 7, 2026; 38 CFR 3.1700–3.1713): service-connected death on/after Sept. 11, 2001 up to $2,000; non-service-connected death on/after Oct. 1, 2026 $1,032 burial + $1,032 plot (on/after Oct. 1, 2025 and before Oct. 1, 2026: $1,002 + $1,002). File VA Form 21P-530EZ; NSC burial-allowance claims generally within 2 years after burial.
12
Pre-need is state law plus the Funeral Rule on the goods/services sale. 453.8(c) excludes the business of insurance. Size the contract to real GPL prices; an inflated irrevocable pre-need is often a gift to the state, not the heirs (NY GBL 453 leftovers go to the county). Home funeral / family rights: Funeral Consumers Alliance (2024) lists nine states that restrict families from independently caring for their own dead by requiring a funeral director for some step: CT, IL, IN, IA, LA, MI, NE, NJ, NY. A home vigil is legal in all 50 states per FCA.
13
Report. ReportFraud.ftc.gov; state funeral board; state AG. Keep the GPL, Statement, and phone-quote notes.

04Checklists