In light of recent regulatory events, the consumer media is turning to all of us and asking the question that everyone in the cremation industry hears most often:

A Chain of Custody procedure is never more important than in moments like these. Here, you can demonstrate your commitment to a family and leave them with confidence to trust you with the care of their loved one. But what do we mean by chain of custody? Every step of your work in the handling of each case must be documented accurately and carefully: custody, control, transfer, analysis, and disposition. CANA recommends crematory facilities make a description of the cremation practice, policy, and procedures available to the family. And, even more importantly, the policy must by followed every time, no exceptions.

Many forms are used to document the steps in the cremation process. It may seem that some of the forms repeat the same information, but it is important to maintain complete, accurate, and cross-referenced records. Your firm should have a comprehensive written procedure guide outlining the steps in the process from receipt of the deceased to return of the cremated remains, and it should include the associated forms, verification, and documentation required. Chain of custody documentation, including the ID tag, ensure the identity of the remains and provide objective evidence of identification post-cremation.

Keep in mind that state and provincial laws governing documentation and record keeping range widely, and every crematory operator must learn what laws specifically apply to their location(s).

But chain of custody goes beyond merely complying with regulations. A thorough and followed chain of custody demonstrates professionalism by establishing and adhering to policies and procedures consistent with industry best practices. Every step of the process needs to be performed in absolute accordance with policies and procedures that have been designed to prevent errors.

Once the remains are in the custody of the crematory, it is important to track and record every step of the cremation process. In the event that there are ever any questions about any case, you will be able to demonstrate that the remains were appropriately handled at every stage. Policies, procedures, forms and all of the paperwork in the world are worthless without compliance and consistency. Doing it the same way every time helps assure that mistakes are not made. If you never do it differently, you will do it right every time.

Documenting chain of custody is key to avoiding lawsuits for negligence in this area. Every step of the way must be recorded without exception, and the records must be archived and accessible if needed. Inaccurate, incomplete, or unfollowed documentation is worse than not having it.

Document retention and filing methods are important as well. If you can’t find something, even if it was filled out perfectly, it doesn’t exist.

Be thorough and complete with every entry every time. Write legibly when filling out forms. A document that you cannot read is worthless. If you leave a field blank it will raise a red flag. Was that field forgotten? Or was it really not applicable? If there is a space to record information and you either do not have that information or it doesn’t apply to this individual, mark that fact down in the space.

If you use a third party for your cremation families, you must still prepare chain of custody procedures and require the crematory you work with to meet or exceed your standards. Ask to see their policies and tour their facility. Conduct random checks of the crematory and audit their paperwork as you would your own. You must be able to stand by the practices of their crematory and clearly describe the chain of custody to the families you serve.

If you operate as a third party crematory serving funeral homes, you know better than most the complications that can occur when working with a remote facility. Not only should any crematory working as a third party maintain the standards described above, but you must maintain your policies and follow the procedures for your various clients. Holding their staff to the standards you hold your own requires diligence. Keeping open communication and maintaining transparency allows your clients and their families to rest easy with loved ones in your care.

Despite the importance of maintaining clear and comprehensive documentation throughout every step of the process, too many facilities make the same types of easily avoided errors. Overconfidence in experience, employees spread too thin, sacrificing thoroughness for efficiency, and choosing the company over compliance are common errors but indefensible. A key thing to remember about liability risk is how small, seemingly minor lapses can have huge consequences for the operator and the facility.

How do you know your chain of custody meets appropriate standards? Walk through your documentation with a hypothetical case (like the one below) and make sure you track the remains throughout the entire process: from when you first take custody of the remains until they leave your control.

Management should perform regular audits of the crematory’s record keeping to assure that all the procedures are being consistently performed. Because cremation has become the number one area of liability in the funeral profession, solid documentation accompanied by iron-clad policies and procedures are the best way to demonstrate the truth and ease the mind of a concerned family member.

What follows is a case study of a cremation gone wrong. The case is an amalgam of true events which have occurred in businesses over the past several years.

The decedent is Peggy Jones of Anywhere, USA. Peggy died alone in her home in July at the age of 62. Although she was married when she died, Peggy had been separated from her husband for 20 years. At the time of her death, Peggy was living with Mr. Smith, her partner of 18 years. Mr. Smith was traveling overseas when Peggy died, and thus, her remains were not discovered until several days after her death.

Peggy’s remains were discovered when a neighbor noted an odor emanating from Peggy’s home. The local authorities were notified, who in turn contacted your facility regarding the death.

The medical examiner staff member was on scene when your removal team arrived. Having located Peggy’s driver’s license, the ME staff tagged the remains correctly, i.e., “Peggy Jones.” However, the remains were verbally identified as “Peggy Jonas.” The body bag contained a tag which also identified the deceased as “Peggy Jonas.” Finally, although her given name was “Peggy,” the ME staff prepared documents identifying the deceased as “Margaret” Jones. From the outset, Peggy’s remains had been identified in three ways - two of which were inaccurate.

LESSON
The easiest way to cremate the wrong remains is improper identification.

What should have happened . . .
The removal staff should have personally examined the remains to confirm the identification affixed thereto. If any discrepancy among the documents, bag and tag affixed to the remains existed, then that discrepancy should have been resolved prior at removal.

The remains were placed into refrigeration at your facility. The refrigeration log reflected that the remains of Peggy Jonas were placed into refrigeration at 8:42 a.m. Due to the uncertainty over the cause of her unattended death, Mr. Smith requested that a private autopsy be conducted by State U. State U logged the remains out of refrigeration at your funeral facility at 5:00 p.m. that same day, having presented documents identifying Peggy as M. Jones. State U logged Peggy’s remains back into your care the following morning at 8:00 a.m., again, as M. Jones.

LESSON
Each and every document must identify the remains correctly.

What should have happened . . .
You should have ensured that Peggy’s remains were identified correctly and in exactly the same way on each document making reference to them. Effective tracking and accurate cross-reference, is a must.

As it turns out, the language contained on nearly every cremation authorization form is true:

Of course, one would think that the statement goes without saying, and yet, every cremation customer is reminded of the permanence of the cremation process. What makes the phrase worth repeating here, however, is that too often cremation providers fail to recognize the weight of the statement. Failing to follow standard practices jeopardize the trust of the cremation-buying public, as well as your license to practice.

By now, you may be thinking: “Any licensee that would make the type of mistakes described in this case doesn’t deserve to serve the cremation buying public.” But, mistakes just like these can be made every day, not from malice but from negligence and ignorance. Keep current on your state’s requirements related to identification, authorization and disposition. Audit your procedures to make sure they are thorough and followed by everyone. Doing so will protect you and your families from the devastation which can be caused by a simple error.

A crematory operator is a vital part of the overall process of turning a dead body into a living memory for a family. It is absurd to think that any good operator would want to do anything less than a perfect job for the family of the deceased. After all, it’s more about the family than anything else, right?

Do you have a budget for training and development? If you do, is it only for mandatory training required for maintaining licensure? If you answered no to the first question, or yes to the second question, read on.

Sadly, most people only pay for continuing education classes only because they have to. As long as they have the credits they need, that’s all that matters. In that case, they look for the bare minimum – something that offers the least amount of work for the most amount of credits at the cheapest rate. You all know what I’m talking about. Those $50 online classes that get you 4 hours of continuing education credit. Four hours and $50 later, you haven’t actually continued your education or developed professionally because few people learn anything from a “class” where you read endless pages of content, or “watch” boring narrated slides while you’re really catching up on CANA’s blog.
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But what if the money spent on that required continuing education could actually help boost your bottom line? Successful companies know that training and development (T&D), as well as succession planning and anything related to workforce development, should be an integral part of your business strategy. Your people are your most important asset, so they should receive the time, energy and investment that shows it.

What do successful companies do? They make a Competency Model – they outline all of the knowledge, skills and abilities (KSAs) a person needs to be successful in a given job or job area. Training dollars are focused on filling the gap between the skills employees have and those they need; since the competencies are tied to business goals, you are spending money on personnel (read: professional) development that will directly impact the bottom line.
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These competency models are also used in succession planning and career growth. When you have them available for all positions, employees know what is expected of them, especially if they want to be promoted or move to a different position in the company. When hiring new employees, the models help you identify what training you may or may not need to provide if you hire a particular person

If improving your bottom line isn’t enough motivation to focus on T&D, maybe keeping qualified employees will. Are your employees getting poached by other firms because of the industry’s talent shortage? Continued opportunities for development and advancement keeps employees engaged and reduces turnover.

What about the retirement of the Baby Boomers? It’s no secret that a skills gap exists between what employers need and the skills many of our future employees have. If you’re facing the looming retirement of experienced staff, getting new employees in and up to speed quickly is essential. That means starting now with comprehensive succession and T&D plans.
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“But wait!” you say. “Paying for classes is one thing. But the travel expenses, lodging and food, in addition to the lost work time, it all adds up!” Yes, it does, and I have several responses. First, the long-term payoff of having well-trained staff more than covers the classes, the travel expenses and the lost work time (or it should, if you choose quality training programs). Plus, the commitment you demonstrate to your employees makes them feel valued and that you are invested in their future. Second, properly trained and qualified staff generally leads to lower legal risk, which is priceless – ask anyone who has been sued.
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So how can you provide quality education in a more budget friendly way? Online programs are a great option since they eliminate the travel.

I earned my Master’s Degree in 2005 and the program was entirely online; it was cutting edge for its time. I remember having to watch video lectures every week for class, mailed to me on VHS tapes, and promptly falling asleep on the couch within 20 minutes. BORING! Don’t get me wrong, the program was tough, and I put the work in to prove I was worthy of the degree (just ask me about my work product sample!). But studies show, and my personal experience agrees, an interactive online learning experience is more effective. It wasn’t available back then, but we’re capable of this now, 13 years later, with all the technology advancements.

Unfortunately, if you want to take quality online education that actually increases the bottom line, you may struggle to find it. Remember that $50 class for four hours of credit? That’s not the quality I mean. Research shows that lectures aren’t effective for adults to learn, yet it continues to be the delivery mechanism of choice—especially for online courses—because it’s easy for those putting the presentation together.

Truly valuable online opportunities can be rare. Maybe that’s why there are still states, like Pennsylvania, that don’t accept continuing education credits obtained through online or distance learning methods. They know that there haven’t been many—if any—truly effective online programs available. CANA is changing that.

CRITERIA
Though it can be costly and time intensive and requires a unique skill set to develop, the use of online education that is designed following best practices is now an expectation within the most successful companies. Unfortunately, there are still many industries that lag behind in this area—ours being one of them. This is why it’s important for CANA to set the standard. Our association needs to show what quality online continuing education looks and feels like.
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But how do you know if you are investing in quality education, especially when it’s offered online? There are three key criteria to consider before purchasing an online course.

• Learners should be active participants in the learning experience. Notice I don’t use the word attendee or registrant. The word learner implies that participants are actually going to contribute something and not sit passively.
• The course should include a combination of video, images, animations, and audio and should not simply be a narrated slide deck.
• Most importantly, it should require the learner to think and to do. This helps them process the information and think about how they will apply it to their daily tasks. That’s where we see the return on investment.

Next time you think about using any education, but especially online education, think quality and return on investment. Let that be your guide to selecting courses that will work for you and your staff.

Not sure how to get started developing a defined professional development plan for your employees? I’d love to talk to you. Call 312-245-1077 or email me [email protected] and I'll work with you to achieve your goals.