Quality of earnings for a funeral home: what the buyer's accountant will test
By Jason Taken, Business Advisor, HedgeStone Business Advisors · Last reviewed · 7 min read
A quality of earnings (QoE) review for a funeral home tests whether reported earnings are real and repeatable. The buyer's accountant ties revenue to case records and deposits, rebuilds cash flow in a cash proof, checks how preneed is booked, prices payroll at market, and fixes cutoffs. SBA requires one for most acquisitions priced at $3 million or more.
Key takeaways
- Under SBA SOP 50 10 8.1, a QoE is required for initial acquisitions and business expansions priced at $3 million or more, and the lender must use QoE earnings for coverage.
- The required cash proof reconciles bank statements to the income statement and tax return for the trailing 12 months and the last two fiscal years.
- Case-level testing matches each call to its itemized statement, the GPL in effect, and a deposit.
- Preneed money booked as revenue when received, rather than when the service is delivered, is the most common funeral-specific QoE adjustment.
- A sell-side QoE cannot replace the SBA lender's report, but it lets a seller find and fix problems before a buyer does.
A seller’s recast tells the buyer what the business earns. A quality of earnings review is how the buyer finds out whether to believe it. For a funeral home, that means testing things a general accountant may never have seen: cash-advance pass-throughs, insurance assignments, preneed deposits, and a call count that should match the deposits to the dollar.
This guide walks through the tests in the order a buyer’s accountant usually runs them, and what a seller can do first. It sits in our valuation, finance, and tax hub.
What is a quality of earnings review for a funeral home?
It is an independent analysis of whether a business’s historical earnings are accurate, recurring, and likely to continue after a sale. It ends in one adjusted earnings figure that the buyer and lender will price and lend against.
SBA’s own definition is a useful benchmark. SOP 50 10 8.1 describes a QoE as “a financial due diligence report that examines the reliability, sustainability, and accuracy of a business’s historical and projected earnings.” Our definition of quality of earnings covers the terms that appear in a report.
Definition
Cash proof: A reconstruction of a business’s cash receipts and disbursements that reconciles bank statement data to the income statement and tax return for each period reviewed, used to find unreported income or undisclosed expenses.
When does a lender require a QoE?
SBA requires one for initial acquisitions and business expansions where the purchase price is $3 million or more. The threshold is measured before buyer equity, seller debt, or other financing is applied.
The rule arrived with SOP 50 10 8.1, which took effect October 1, 2026. Per SBA Information Notice 5000-880695, the new SOP governs applications that receive an SBA loan number on or after that date. Under it, the QoE must be independent, prepared for the lender, and “must not be prepared by or for the seller.” A buyer may commission one early, but the lender can rely on it only after its own approved vendor reviews it. The lender must then use QoE earnings when it tests debt-service coverage, and reduce the loan if coverage falls short.
Two details matter for funeral homes. Owner buyouts and ESOP deals are exempt. And the SOP waives the QoE for an acquisition of an owner-occupied special purpose property that is integral to the business, though the lender must document why the property qualifies. Whether a particular funeral home fits that exception is the lender’s call, so do not plan around it. Outside SBA, consolidators and private equity buyers commission their own financial diligence regardless of size.
How does the accountant tie revenue to the call records?
By matching every case in the test period to its contract, its price list, and its deposit. Revenue that cannot be traced to a call, or calls that cannot be traced to revenue, become adjustments.
The FTC Funeral Rule helps here. Under 16 CFR Part 453, providers must give each family an itemized Statement of Funeral Goods and Services Selected and keep a copy, along with each price list, for at least one year. Those records let the accountant check that what was charged matches the General Price List (GPL) in effect.
| Test | What is compared | What it often finds |
|---|---|---|
| Case completeness | Case list vs. death certificates filed, removal logs, and the calendar | Trade calls or shipping cases mixed into retail calls |
| Pricing | Itemized statements vs. the GPL in effect | Undocumented discounts or packages priced below the list |
| Collections | Statements vs. deposits and insurance assignment payments | Old receivables, write-offs, and assignments never collected |
| Cash advances | Amounts billed vs. amounts paid to third parties | Pass-throughs booked as sales, or undisclosed markups |
| Disposition mix | Calls by burial, cremation with services, direct cremation | Revenue per call drifting as mix shifts |
The last row feeds the second number in the Four-Number Funeral Home Valuation Screen, average revenue per call by disposition mix.
What does the cash proof show?
It shows whether money in the bank matches the earnings on paper. SBA requires the proof on both a trailing 12-month basis and for the last two fiscal years.
Funeral homes have unusual cash flows that make this test revealing. Insurance companies pay assigned policy proceeds weeks after a service. Trusts release funds when a preneed contract matures. Cash advances flow in and straight back out. Trade work for other firms may be paid in bulk. Each must be separated before deposits can be compared with revenue.
The SOP also requires the QoE to reconcile accountant-prepared statements, tax returns, internal statements, and IRS transcript data. A gap between the internal P&L and the tax return is not fatal, but it needs a written bridge.
How is preneed accounting tested?
The accountant checks when preneed money is recognized as revenue and whether trust and insurance income will continue. Getting the timing wrong can make a year with heavy preneed sales look far more profitable than it was.
Large operators defer that revenue. In its FY2025 Form 10-K, Service Corporation International says revenue from preneed sales “is deferred until” the merchandise is delivered or the services are performed, and that unfulfilled insurance-funded contracts are not on its balance sheet because the contract is between the customer and the insurer. Many small firms keep cash-basis books, where a preneed payment can land in revenue the day it arrives. A QoE moves it out.
The accountant will also separate insurance commissions and trust income from operating revenue and ask whether each continues after closing. Our guide to how preneed trust earnings and insurance commissions affect value covers those lines, and the backlog’s funding is tested separately in preneed diligence.
What payroll and owner-compensation tests come up?
The SOP lists them: the report must document every add-back and adjustment, including “above- or below-market owner compensation, related-party transactions, deferred maintenance,” and cash-versus-accrual differences.
In a funeral home, that usually means pricing the owner’s and family’s roles at market wages, adding on-call pay that was never recorded, normalizing rent paid to the owner’s real estate entity, and rejecting “one-time” repairs that recur. Our guide to funeral home add-backs sorts which items usually survive.
Why do cutoffs and accruals matter?
Because a cash-basis funeral home records revenue when it is collected, not when the service happens. Moving cases into the right period can shift earnings by tens of thousands of dollars.
A service in late December paid by an insurer in February belongs to December’s year. Inventory bought in bulk before year-end should not hit cost of goods all at once, and expenses prepaid in December for the coming year belong to that coming year. Expect the accountant to rebuild each period on an accrual basis before comparing years. Receivables at closing are settled separately in the working capital true-up.
Worked example: from seller's EBITDA to QoE EBITDA (illustrative)
Made-up figures for a firm priced at $3.2 million, so an SBA QoE is required.
- Seller’s adjusted EBITDA, trailing 12 months: $710,000
- Preneed payments booked as revenue when received, moved to deferred: −$52,000
- Insurance assignment receivables over a year old, written off: −$11,000
- Market wage for a family member taking unpaid night calls: −$24,000
- One-time insurance recovery in other income, removed: −$30,000
- QoE adjusted EBITDA: $593,000
At the 1.25:1 minimum coverage, the $117,000 reduction lowers the maximum annual debt service by $117,000 ÷ 1.25 = $93,600, and the loan shrinks with it.
Is a sell-side QoE worth it?
Often, for larger firms or messy books. It cannot stand in for the SBA lender’s report, but it lets the seller find the problems first and fix or explain them on the seller’s schedule.
- Close the books monthly, with cash advances, trade work, and preneed in separate accounts.
- Build a case list for three years that ties to deposits and itemized statements.
- Reconcile the preneed register to trust statements and insurer confirmations.
- Write a bridge from the internal P&L to each tax return.
- Document every add-back with a source record.
Our due diligence workstreams show where the QoE sits among the buyer’s other reviews.
Frequently asked questions
How is a QoE different from an audit?
An audit gives an opinion on whether financial statements follow accounting standards. A QoE asks a narrower, deal-focused question: what does this business sustainably earn, and will it keep earning that under a new owner? It adjusts for owner pay, one-time items, and cash-versus-accrual timing, which an audit does not set out to do.
Who pays for the QoE in an SBA deal?
The lender orders it, but SBA lets the out-of-pocket cost be passed to the borrower, and money the buyer spends on it can count toward the equity injection. Sellers usually pay nothing for the buyer's QoE, though they spend real staff time answering requests and producing records.
Can a funeral home under $3 million skip a QoE?
An SBA lender is not required to order one below that price, but it still verifies the seller's figures against IRS transcripts and must justify every adjustment it makes. Consolidators and private equity buyers often run their own financial diligence at any size. Plan as if your numbers will be tested either way.
How long does a funeral home QoE take?
It depends on the quality of the records more than the size of the firm. Clean monthly statements, a case list that ties to deposits, and a reconciled preneed register move quickly. Missing statements and a cash-basis ledger with preneed mixed into revenue slow every step, and delays can push back the closing date.
Sources cited
- SOP 50 10 8.1: Lender and Development Company Loan Programs — U.S. Small Business Administration
- SBA Information Notice 5000-880695: Issuance of SOP 50 10 8.1 — U.S. Small Business Administration (via Coleman Report)
- 16 CFR Part 453: Funeral Industry Practices — eCFR / Federal Trade Commission
- Service Corporation International FY2025 Form 10-K — U.S. Securities and Exchange Commission