Funeral Director Registration Questions
1. I am a Type 3 Funeral Director, do I need to do anything different with my registration?
A: No, these changes do not affect your registration.
2. I hold a current embalmer registration and a current Type 4 or Type 5 Funeral Director Registration, do these changes impact me?
A: Yes, you will be converted (automatically) to a Type 6 Funeral Director and Embalmer Registration in the near future. This registration type combines the Type 1, 4, and 5 registrations and is designed to enhance employment options and reduce costs to registrants. You will still need to let the Board office know where you are working, but you will not need to maintain the separate embalmer registration. Unless you upgrade to a Type 3 (ownership) registration, you will not to change your registration types again.
3. I hold a valid Type 1 embalmer registration, but I have let my funeral director registration (any type) lapse, will I get a Type 6?
A: No, you must have a valid funeral director registration prior to being given a Type 6 registration. You will still be permitted to renew your Type 1 registration. If your last funeral director registration has been lapsed for more than a year, you must pass an examination prior to qualifying for a Type 6 registration.
4. I hold a valid Type 4 or 5 funeral director registration, but I have let my embalmer Type 1 registration lapse, will I get a Type 6?
A: No, legally you should not be renewing the funeral director registration because the law requires you to hold an embalmer registration to obtain a funeral director registration. The Type 6 will combine these registrations, however, you must meet the legal requirements for both to get a Type 6. Be advised that you will not be permitted to renew the Type 4 or 5 when it expires, you should not practice until you take the steps necessary to renewing the embalmer registration.
5. I just want to maintain (or obtain) my embalmer registration to do trade embalming, I don’t want a funeral registration, may I keep my Type 1 Embalmer registration?
A: Yes, the Board will allow you to keep your Type 1 registration, however, this will only occur on a case by case basis.
6. I have a Type 6 registration, may I perform funeral directing/arrangements/provide preneed services outside of a funeral home?
A: No, Type 6 funeral directors may not sign death certificates and may only perform other funeral services, such as the transport of bodies, when employed by a Type 3 Funeral Director at a properly licensed funeral home. The only exception to this is embalming, which may be performed at a funeral home on a contractual basis. Preneed work may only be performed after thirty days of employment with written authorization from the Type 3 Funeral Director.
7. May a Type 6 Funeral Director operate a funeral home in the absence of the Type 3?
A: Yes, with notification to the Board and only for thirty days. Additional time would require special Board approval.
8. If I get a Type 6 Funeral Director registration, do I still have to work full time, which was a requirement of my Type 5 registration?
A: No, you may work either part or full time and you can work as a part time employee for multiple funeral homes.
1. Did the regulations end lifetime apprenticeships?
A: Yes, apprentice registrations can only be utilized for a total of six years without special board approval. However, existing apprentices can renew their registrations until November 1, 2014. If an apprentice needs additional time for good cause, they may petition the Board, otherwise lifetime apprentices should consider becoming a registered funeral home assistant.
2. Do the changes impact how apprentices are supervised?
A: Yes, an apprentice embalmer must have same room supervision for the first fifty (50) dead human bodies they embalm. In addition, apprentices may perform the removal or transfer of a dead human body unsupervised only after their registered supervisor has personally accompanied the apprentice for the first twenty (20) removals/transfers performed during the course of their employment.
3. Did the education apprentices need change?
A: Yes, apprentices must complete OSHA training related to biohazards/blood borne pathogens prior to applying for registration and for each year so registered. Additionally, when they seek a funeral director registration, they must obtain an associates degree in mortuary science. Apprentices must still work full time.
Funeral Home Assistants
1. What is a funeral home assistant?
A: An individual registered under a type 3 funeral director to assist in removals and other general funeral home matters. This registration may be utilized on either a part time or full time basis. A funeral home assistant may work as an employee at multiple funeral homes.
2. May a Funeral Home Assistant embalm?
3. May a funeral home assistant make funeral or preneed arrangements?
4. What type of supervision must a funeral home assistant have?
A: Generally a funeral home assistant must be directly supervised by a registered funeral director, however, like apprentices, funeral home assistants may perform the removal or transfer of a dead human body unsupervised after their registered supervisor has personally accompanied the funeral home assistant for the first twenty (20) removals/transfers performed during the course of their employment.
5. What are the requirements for becoming a funeral home assistant?
A: A funeral home assistant must have completed an OSHA training related to biohazards/blood borne pathogens prior to applying for registration and for each year so registered. In addition, funeral home assistants must possess an associates degree in mortuary science or complete Board approved training in General Public Health, Ergonomics, and Funeral Service law and ethics. Employers may, with Board approval, design their own educational curriculum based on these subject areas to meet this requirement.
6. May a funeral home assistant offer their services as an independent funeral business?
A: No, a funeral home assistant must be registered to and work in the employ of a Type 3 Funeral Director at all times.
Funeral Home Licensure
1. Was there a change to the accessibility requirements?
A: No, the regulations now explicitly require adherence to 521 CMR (without grandfathering) instead of the ADA when there is a change of ownership, however, this is consistent with Board policy and does not represent a change.
2. Do non-LLC/LLP owned funeral homes need liability insurance?
1. May funeral homes serve refreshments?
A: Yes, in part, they may serve non-alcoholic beverages in areas apart from where dead human bodies are displayed.
2. May an apprentice or an unregistered individual register a hearse?
A: In general no, however, non-funeral businesses may register hearses for the sole purpose of leasing the vehicles to properly licensed funeral establishments. Otherwise, only registered funeral directors may register a hearse.
3. Does the Board prohibit business cards?
A: No, business cards may be used by any registrant so long as they include the name of a licensed funeral establishment and includes their registration type.
4. May I advertise services without mentioning a funeral home, such as offering the services of apprentices or assistants, or offering preneed contracts?
A: No, all such advertising must be linked to a validly licensed funeral home which must perform all funeral related services.
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