Executive Summary

The FTC Funeral Rule mandates two distinct but related documents that often cause confusion among funeral directors: the General Price List (GPL) and the Itemized Statement. Understanding their fundamental differences is not just about compliance—it's about operational clarity and avoiding costly regulatory penalties. This article analyzes the critical distinctions between these documents, providing clear guidance for directors who need to maintain perfect compliance.

The Fundamental Difference: Purpose and Timing

General Price List (GPL): Pre-Selection Marketing Tool

The General Price List is fundamentally a marketing document designed for the pre-selection phase of arrangements. Its core purpose is to allow consumers to make informed decisions by comparing prices across different providers before committing to any services.

Key characteristics that define the GPL:

• Must be provided at the beginning of discussions about funeral goods, services, or prices
• Contains your complete range of offerings and their prices
• Includes mandatory disclosures about consumers' rights
• Must be offered to anyone who inquires, without requiring personal information in exchange
• Serves as a standardized price sheet for comparison shopping

Itemized Statement: Post-Selection Contract Document

In contrast, the Itemized Statement is a post-selection document that serves as a personalized contract between your funeral home and a specific client family. It details only the specific items and services they have selected.

Key characteristics that define the Itemized Statement:

• Provided after selections have been made
• Contains only the items and services selected by a specific family
• Must identify cash advance items separately and clearly
• Serves as a binding financial agreement
• Must be provided before the funeral or disposition of remains

Document Requirements: Content and Format

Common Compliance Violations and How to Avoid Them

Violation #1: Substituting One Document for the Other

The most common violation occurs when funeral directors attempt to use the GPL as an Itemized Statement, or vice versa. Each serves a distinct purpose, and they cannot be used interchangeably.

How to avoid: Maintain separate templates for your GPL and Itemized Statement. Never hand a family a GPL with items circled or checked off and call it an Itemized Statement.

Violation #2: Failing to Provide a GPL at the Right Time

The Funeral Rule is explicit: you must give a GPL to anyone who asks about funeral goods, services, or prices—before showing them caskets, urns, or discussing specific arrangements.

How to avoid: Train all staff to offer the GPL at the very beginning of price or service discussions, both in-person and over the phone. Create a standardized protocol for GPL distribution during the initial contact.

Violation #3: Incomplete Itemized Statements

Itemized Statements must clearly identify and separate cash advance items. Failing to do so is a common violation.

How to avoid: Create a structured template for Itemized Statements with distinct sections for funeral home services/merchandise and cash advance items. Include a statement explaining that cash advance items are paid on the family's behalf to third parties.

Violation #4: Outdated GPL with Current Prices on Itemized Statement

When prices change, some funeral homes update their Itemized Statement templates but forget to update their GPL, creating a discrepancy that violates the Rule.

How to avoid: Implement a formal price change procedure that includes updating both documents simultaneously. Use digital tools to ensure all price-related documents remain in sync.

Digital Implementation: Streamlining Both Documents

Modern funeral home management software can dramatically simplify compliance with the Funeral Rule's documentation requirements by:

• Automatically maintaining a current GPL in digital format
• Generating compliant Itemized Statements from selections made during arrangements
• Providing digital record-keeping of when GPLs were shared with families
• Ensuring consistent pricing across all documents
• Facilitating easy updates when prices change

Training Your Staff: Creating Clear Protocols

The distinction between the GPL and Itemized Statement must be understood by all client-facing staff. Implement the following training protocols:

1. Role-specific training: Directors, administrative staff, and answering service personnel should receive customized training relevant to their role in providing the GPL and Itemized Statement.
2. Document handoff procedure: Create a formal protocol for when and how to provide each document, with a checklist for staff to follow.
3. Compliance audits: Conduct quarterly internal audits of randomly selected files to ensure both documents are being properly used and retained.
4. Annual refreshers: Schedule annual training sessions focusing on real-world scenarios and common compliance pitfalls.

Practical Example: The Document Journey for a Typical Case

To illustrate the distinct roles of the GPL and Itemized Statement, let's follow their use throughout a typical case:

1. Initial family contact: Family calls to inquire about services. Funeral home offers to provide the GPL via email or in person.
2. First in-person meeting: Director provides printed GPL before beginning discussion about services.
3. Casket selection: Family is shown the Casket Price List (a companion to the GPL) before viewing caskets.
4. Arrangement conference: After selections are made, an Itemized Statement is prepared showing only their specific selections.
5. Review and signature: Family reviews the Itemized Statement, which becomes their contract, and signs it before the funeral services are provided.
6. Documentation: Both the acknowledgment of receiving the GPL and the signed Itemized Statement are retained in the case file.

How Sacred Grounds Software Simplifies Compliance

Maintaining proper separation between your General Price List and Itemized Statements shouldn't require complex systems or redundant data entry. Sacred Grounds funeral home management software was designed specifically to address the documentation requirements of the FTC Funeral Rule by providing:

• A unified price management system that ensures your GPL and Itemized Statements always show consistent pricing
• Automatic generation of compliant Itemized Statements based on family selections
• Digital GPL distribution with tracking for compliance documentation
• Customizable templates for both GPLs and Itemized Statements
• Automated audit trail of when documents were provided to families

By centralizing these critical compliance documents in one system, funeral homes can eliminate the common errors that lead to FTC violations while reducing the administrative burden on their staff.

Conclusion: The Strategic Value of Documentation Clarity

Understanding the fundamental differences between the General Price List and Itemized Statement is more than a compliance exercise—it's about operational excellence and consumer transparency. By maintaining clear distinction between these documents, funeral homes can:

• Reduce their regulatory risk and avoid costly penalties
• Provide a more transparent experience for client families
• Streamline their arrangement process
• Maintain cleaner financial records

The most successful funeral homes view these documentation requirements not as burdens but as opportunities to demonstrate their professionalism and commitment to ethical business practices.