The Missouri State Board of Embalmers and Funeral Directors will meet in a few weeks, and the topic of fees may be on the agenda. The staff broached the fees topic at the spring meeting, but the matter was tabled for subsequent discussion. Fees and the preneed examination process go hand in hand, and so we anticipate the industry will press the staff for an explanation about the exam budget. The industry desire will be to cut the $36 per contract fee, but the staff will likely counter that until every seller has been examined, the on-site audits (The On-Site Audit: getting to know your business) will dictate against any reduction in the contract fee. While the on-site audit may fulfill an important function in communicating record keeping issues to licensees, can the document production request and the desk audit process be revised to expedite the on-site audit? Could the seller’s renewal report also be revised to better serve the examination process while reducing the record keeping required of licensees and trustees?

Under Missouri’s prior law, the seller’s renewal report served primarily to compute the $2 per contract fee. While the renewal report continues to serve that function (albeit at a much higher rate), the report also provides individual contract data (ostensibly as base data for financial examinations). The reporting period for this data is tied to the Division of Professional Registration’s licensing schedules and fiscal year. In doing so, the Division only affords the industry 60 days in which to ‘close its books’ and update individual contract data. When one peruses the list of State Board discipline actions, there are a significant number of suspensions for late seller filings. Missouri having the shortest data turnaround window among the Midwest states must play a role.

In contrast, most states seek contract data on a calendar year because that period coincides with tax reporting and standard trust reporting. Trustees also produce tax ledger statements that are calendar year based. Utilizing existing accounting records not only reduces the trustee’s record keeping, it could help standardize Missouri’s examination process (one element in reducing costs). One must also question the need for fiscal year data when the seller has to provide a current contract report for the document production request.

The Division’s single document approach to the seller renewal is also unnecessarily burdensome to the industry. While the seller and the trustee need to collaborate with regard to individual account administration, the trustee will be the sole source of certain data the Division seeks. The process could be simplified if the trustee were allowed to certify the aggregate trust information by a separate form that contemplates the calendar year trust reports. Banks are notoriously slow, and the single form format puts the licensee at risk due to no fault of his own.