The National Association of Funeral Directors, which represents almost 4,000 UK funeral homes, has set out its concerns about the proposed changes of Death Certification in a response to the Department of Health consultation which closed overnight (15 June 2016).

The NAFD’s response has been prepared in close consultation with the Society of Allied and Independent Funeral Directors and can be viewed as an authoritative response on behalf of the profession. The NAFD has also worked with Cruse Bereavement Care to ensure the needs of bereaved people are reflected in its response.

In the NAFD’s view the draft regulations, set out in the consultation are hurried, not adequately trialled and not well explained. The Association does not believe that there should be a fee for the proposed Medical Examiner’s service, as it amounts to a tax on all bereaved people.

Jeremy Field, President of the NAFD, who has been involved on the stakeholder group relating to the reforms said: “The NAFD would welcome any new legislation that improves the experience for bereaved people in the immediate aftermath of a death. NAFD has been contributing to reports on the outdated and occasionally inadequate nature of the laws in England & Wales surrounding death and funerals for decades. However, the NAFD feels the reform, which may well be needed, is being rushed and will not achieve its aims and so, in its current form the NAFD is unable to support the reforms as set out in the consultation.”

From the NAFD’s perspective there remain a number of significant issues which still need to be properly addressed:

  • The fee. The NAFD believes that there should be no fee. In the event that the proposed fee is implemented the NAFD has confirmed that its members are not currently willing to collect the fee on behalf of Local Authorities.
  • Verification. Despite efforts on behalf of Department of Health (DoH) and the British Medical Association (BMA) the NAFD is not clear on who is qualified to verify the fact of death, nor where and when verification should take place.
  • Access to information. The NAFD is extremely concerned that key documents such as the important Equality Analysis, were not provided via the consultation web portal – only on request. The NAFD also believes that there are potential equalities implications that have not been acknowledged within the Equalities Impact Assessment.

Continued Mr. Field: “The NAFD has considerable concerns that the potentially adverse impact on bereaved families of a system that has not been properly trialed have not been taken into account. We are particularly concerned that the views of bereaved people have been limited to contributions made in stakeholder meetings (of which there have been none for 3½ years) and first hand anecdotes recounted by those closely involved in the project. In our own work to develop a response to this consultation we have sought input from Cruse Bereavement Care, which shares many of the NAFD’s concerns about the proposals.”

“In conclusion, the NAFD is concerned that the proposals, in their current form, may not achieve their aims and may even prove easier for someone with the correct connections to abuse the system – thereby negating the argument that another Shipman scenario could be prevented.”