© 2017 Commonwealth Community Trust All Rights Reserved

Disbursement

Information

Manual

TABLE OF CONTENTS

Table of Contents ............................................................................................................ 1

Welcome ......................................................................................................................... 3

Key Terms ....................................................................................................................... 4

Responsibilities of the Trust Administrator ...................................................................... 7

Government Benefits: Supplemental Security Income (SSI) and Medicaid ..................... 7

Other Government Benefits ............................................................................................. 8

Reporting Requirements to Government Agencies Fulfilled by CCT ............................... 9

Helpful Information Regarding Reporting Changes to the Beneficiary’s Status to

Government Agencies for Medicaid and/or SSI Recipients ............................................. 9

Guidelines for Disbursements ....................................................................................... 10

The Disbursement Decision-Making Process ................................................................ 11

The Disbursement Request Process ............................................................................. 11

Guidelines to Complete the Payment Request Form .................................................... 11

How to Complete a Payment Request Form and Sample Payment Request Form ...... 12

Who Can Receive Funds .............................................................................................. 14

How to Submit a Payment Request Form ..................................................................... 14

September 2017

Turnaround Time ........................................................................................................... 14

Reasons a Disbursement Request Could be Denied or Require Further Discussion .... 15

Reasons a Disbursement Request Could be Delayed .................................................. 15

Examples of How Trust Funds Can be Spent ............................................................... 16

Home Purchase and Renovations ................................................................................. 18

I. Home Purchase ............................................................................................... 18

II. Home Renovations ........................................................................................... 19

Buying a Vehicle ........................................................................................................... 19

Care Provider ................................................................................................................ 20

Case Management Services ......................................................................................... 20

Vacation ........................................................................................................................ 21

Pre-Need Burial Arrangements ..................................................................................... 21

Travel ............................................................................................................................ 21

Budget Form and Objectives of the Trust Form ............................................................ 22

Family and Beneficiary Information Form for Third-Party Trusts ................................... 22

Parents’ Responsibility for a Minor ................................................................................ 22

Holiday Expenses ......................................................................................................... 22

Weapons, Alcohol, and Bail .......................................................................................... 23

Pre-Paid Credit Card (True Link) ................................................................................... 23

Tax Information ............................................................................................................. 24

Upon the Death of the Beneficiary of a First-Party Trust ............................................... 24

Upon the Death of the Beneficiary of a Third-Party Trust .............................................. 25

Closing the Trust ........................................................................................................... 25

How to Contact CCT ..................................................................................................... 25

2

WELCOME

Greetings,

We are pleased to welcome you to Commonwealth Community Trust (CCT) and want

you to have a positive experience. CCT is a nonprofit organization that administers

Pooled Special Needs Trusts and is governed by a volunteer Board of Directors. CCT

has provided trust administration services since 1990 and has established an

outstanding reputation for quality customer service.

We have a big job to do as the Trust Administrator and are charged with the

responsibility of making disbursement decisions. As such, we look forward to working

with the Advocate(s) to let us know what the needs of the Beneficiary are.

We ask that you recognize that a Pooled Special Needs Trust is not a checking

account, an ATM, a debit or credit card, or a money store. We do the best job that we

can within the constraints of our responsibilities as the Trust Administrator.

The purpose of this guide is to provide general information about the disbursement

process. Please keep this manual for future reference and do not hesitate to contact

CCT with any questions or feedback. Information is also available on our website,

www.trustCCT.org, under the “Disbursements” tab.

We look forward to working with you to enhance the life and well-being of the Trust

Beneficiary.

Sincerely,

The Staff of Commonwealth Community Trust

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© 2017 Commonwealth Community Trust All Rights Reserved

KEY TERMS AS USED BY CCT

Advocates(s): The Advocate(s) is authorized to make disbursement requests by

signing and submitting the Payment Request Form. If there is a need to change an

Advocate for the trust account, contact CCT.

Primary Advocate: Named by the Grantor, the Primary Advocate is responsible

for making requests for disbursements that are for the benefit of the

Beneficiary. The Primary Advocate will have access to financial statements and

can be the Beneficiary, a Guardian, Conservator, Power of Attorney, family

member, case worker, friend and/or someone who is familiar with the needs of

the Beneficiary. The Primary Advocate will receive financial account information,

tax documents, and other official correspondence from CCT.

Secondary Advocate: It is important to have a Secondary Advocate as backup to

the Primary Advocate. The Secondary Advocate can receive financial account

information upon request, and will be contacted by CCT if the Primary Advocate

cannot be reached or to obtain any additional information, at any time.

Beneficiary: The Beneficiary of the Trust is the person for whose benefit the trust was

created.

Definition of Disability for Purposes of SSI and Medicaid: A trust fund is established

to benefit a child or adult that meets the following Social Security Administration’s

definition of disability.

A child with special needs who has a physical or mental condition that severely

limits their activities which has lasted or is expected to last at least one year or

result in death.

An adult with special needs who is unable to work because of their physical or

mental condition, which has lasted or is expected to last at least one year or

result in death.

A special needs trust helps protect the Beneficiary’s government benefits including SSI

and Medicaid.

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Discretionary: Disbursements are at the sole discretion of the trust administrator,

Commonwealth Community Trust (CCT).

Grantor: The following person or persons who establishes the special needs trust:

First-Party Pooled Special Needs Trust: The Grantor can be the Beneficiary of

the Trust or someone acting on behalf of the Beneficiary such as the parent(s),

grandparent(s), the Court or Guardian. The funds are the Beneficiary’s own

money typically from a personal injury award, Social Security back payment or

direct inheritance.

Third-Party Pooled Special Needs Trust: The Grantor is a third party, and the

funds are typically from a family member or friend.

Joinder Agreement: The legal document that allows the Beneficiary to have a sub-

account with a Pooled Special Needs Trust. The Joinder Agreement for CCT needs to

be completed and notarized.

Pooled Special Needs Trust: A special needs trust that is administered by a nonprofit

organization, and whose funds are pooled for investment purposes and to keep

administrative fees low. Financial records for each sub-account are maintained by the

Trustee (The Trust Company of Virginia). Comprehensive financial statements for each

sub-account are mailed quarterly to the Advocate or may be accessed at The Trust

Company of Virginia’s website (http://www.tcva.com/).

First-Party Pooled Special Needs Trust: Self-funded by the individual with

special needs as a result of a personal injury award, Social Security back

payment, direct inheritance or other reason. For a Beneficiary who receives

Medicaid, this is a Medicaid payback trust. At the death of the Beneficiary,

Medical Assistance Services will be repaid for its expenditures during the

Beneficiary’s lifetime. This type of trust must be irrevocable by law.

Third-Party Pooled Special Needs Trust: Established for a Beneficiary with a

disability is funded by a third party (the Grantor) who is typically a family member

or friend, and can be coordinated with an estate plan, life insurance policy, or

other qualified plan. This type of trust is sometimes referred to as a Supplemental

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Needs Trust, Purely Discretionary Trust or a family-funded special needs trust.

CCT's Third-party sub-accounts are irrevocable once funded, but remain

revocable until funded or until the death of the person making the will or trust.

Successor and Contingent Beneficiaries: The Grantor(s) designate Successor and

Contingent Beneficiary(ies) on the Joinder Agreement. This information can be updated

by the Grantor at any time. The Successor Beneficiary(ies) receives the percentage the

Grantor stated on the Joinder Agreement. Sometimes a Successor Beneficiary dies

before the Beneficiary. If a Contingent Beneficiary is named, that share will be

distributed to that Contingent Beneficiary(ies). If no Contingent Beneficiary is named,

the share of the Successor Beneficiary who died before the Beneficiary will be divided

amongst the other Successor Beneficiary(ies). An individual or charity can be named as

a Successor Beneficiary and/or Contingent Beneficiary. Naming CCT as a Successor

Beneficiary and/or Contingent Beneficiary, supports the organization’s mission to serve

people with disabilities.

Supplemental Security Income (SSI) and Medicaid Recipients: For Beneficiaries

who receive SSI or Medicaid, disbursements from the trust account must be for their

sole benefit, as defined by the Social Security Administration and the States’

Departments of Medicaid Services. If a trust pays for expenses that benefits someone

other than the Beneficiary, the Beneficiary’s SSI and Medicaid, or eligibility for these

benefits, would be put at risk These Beneficiaries cannot receive cash or checks. There

are many complex rules that have to be followed in order to protect these benefits.

Trust Administrator: A non-profit organization, such as CCT, that administers pooled

special needs trusts. The Trust Administrator directs the distributions and administrative

issues of the trust.

Trustee: A bank or trust company (The Trust Company of Virginia), hired by the CCT

Board of Directors, that has the responsibility to manage and invest the trust funds. The

Beneficiary does not own the funds in the trust. The Trustee holds the legal title of the

trust funds for the benefit of the Beneficiary. The Trustee acts at the direction of the

Trust Administrator.

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RESPONSIBILITIES OF THE TRUST ADMINISTRATOR

CCT, as the Trust Administrator, has the responsibility to:

Act prudently

Answer the Grantor’s questions about the responsibilities of CCT and assist as

needed when completing the paperwork for setting up the trust

Communicate and share information with the Advocate(s), as described in the

Joinder Agreement

Review each disbursement request and make decisions

Keep accurate records for each Beneficiary

Ensure SSI and/or Medicaid eligibility are not jeopardized for a Beneficiary who

receives these benefits

Provide oversight to assure proper management of the Trustee’s fiscal

responsibilities to manage and invest the funds, disburse and provide access to

financial statements either electronically or by mail, and complete the annual tax

form (K-1)

Mail the annual tax report (K-1) to the Advocate(s)

Provide information to government agencies for beneficiaries receiving

Supplemental Security Income (SSI) and Medicaid

Collaborate, as needed, with attorneys, financial planners and family members in

setting up the trust

Review and accept New Joinder Agreements

GOVERNMENT BENEFITS: SUPPLEMENTAL SECURITY INCOME

(SSI) AND MEDICAID

One of the benefits of a Pooled Special Needs Trust is that the trust documents are

written to protect the Beneficiary’s SSI and Medicaid benefits and as such a Pooled

Special Needs Trust is not considered income or a countable resource. In order not to

jeopardize these benefits, there are restrictions as to how the funds can be spent.

Often, CCT is in a position of explaining what the government rules are for protecting

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benefits and what our responsibility is in these situations. It is extremely important to

keep in mind that as the Trust Administrator we are charged with protecting SSI and or

Medicaid benefits and this responsibility impacts disbursement decisions.

Please be aware of the following restrictions regarding disbursement requests for

a Beneficiary who receives SSI and/or Medicaid:

If an Advocate requests a disbursement from the trust to pay for food or shelter,

the disbursement will be denied because SSI pays for these benefits. If CCT

were to approve the disbursement in an emergency, then the Social Security

Administration (SSA) would count this disbursement as income and the

Beneficiary’s SSI would be reduced. If CCT approves such a request, we will

require the Advocate to sign a form acknowledging the consequences and that

CCT will inform the SSA of the disbursement. We consider this our fiduciary

responsibility.

If the Beneficiary receives SSI or Medicaid, the trust can only pay for items and

services that are for the “sole benefit” of the Beneficiary. Trust funds cannot be

used to purchase gifts for other people or for charitable donations. If there are

shared expenses, the cost must be shared among all users.

Household bills can only be paid for the home where the Beneficiary resides.

With appropriate documentation, the trust can either pay the vendor directly by

check or reimburse the third-party who paid the bill.

OTHER GOVERNMENT BENEFITS

In certain circumstances, having a Pooled Special Needs Trust may affect other

government benefits or eligibility for them. These include SNAP (formerly Food

Stamps), HUD housing, and Section 8 housing. A Pooled Special Needs Trust will not

affect eligibility for SSDI (Social Security Disability Insurance), Social Security, or

Medicare.

8

REPORTING REQUIREMENTS TO GOVERNMENT AGENCIES

FULFILLED BY CCT

A Beneficiary who receives SSI or Medicaid has certain reporting obligations regarding

the trust account. When requested, CCT provides the following information to the

following agencies:

HELPFUL INFORMATION REGARDING REPORTING CHANGES

TO THE BENEFICIARY’S STATUS TO GOVERNMENT AGENCIES

FOR MEDICAID AND/OR SSI RECIPIENTS

It is the responsibility of the Beneficiary or the Beneficiary’s representative to report

changes that may affect benefits. For more information, contact the following agencies:

Social Security Administration for SSI recipients:

https://www.ssa.gov/pubs/EN-05-10153.pdf

For Medicaid recipients, contact your local Medicaid office.

Medicaid SSA

The establishment of the trust at the time of enrollment

When requested by a public agency, a copy of the Joinder Agreement, any court orders, and financial statements that detail deposits and disbursements (the payee, date of disbursement, and purpose of the payment)

Notification upon the death of the Beneficiary of a First-Party Pooled Special Needs Trust who received Medicaid

When a Beneficiary receives a disbursement for food or shelter-related items

Varies by State

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GUIDELINES FOR DISBURSEMENTS

When CCT considers whether to approve a disbursement request, the following best

practices are used as a guide for decision-making:

For a Beneficiary receiving SSI and/or Medicaid, will the request jeopardize

benefits?

Is the request for the benefit of the Beneficiary?

Are there adequate funds in the trust to cover the request?

Is the request prudent?

For a Third-Party Trust, is the request consistent with the intent of the Grantor?

Is the request consistent with the Budget and Objectives?

THE DISBURSEMENT DECISION-MAKING PROCESS

Decisions about disbursements are made based on applicable laws and CCT’s policies

and procedures according to the following flow chart:

Advocate submits the Payment Request Form with supporting documentation

Client Services Team reviews the disbursement request

Executive Director provides oversight

In-house Counsel consults, as needed

Board of Directors’

Disbursement Committee

consults, as needed

Note: This committee is comprised of

trust and estate attorneys with expertise

in special needs planning.

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THE DISBURSEMENT REQUEST PROCESS

Requesting disbursements from the trust account is a multi-step process:

1. An Advocate requests a disbursement using a Payment Request Form that

requires backup documentation such as receipts, estimates, or invoices.

2. Requests are reviewed for appropriate use of funds based on best practices

criteria and are either approved or denied.

3. Denied requests are returned to the Advocate with a written explanation.

4. Checks for approved requests are mailed within 14 days of the date the request

is received by CCT.

GUIDELINES TO COMPLETE THE PAYMENT REQUEST FORM

o All requests for disbursements must be completed on a Payment Request Form and

be accompanied by supporting documentation that includes but is not limited to:

o Itemized receipts o Estimates o Invoices o Price quotes

o Documents must demonstrate that the items or services purchased were for the

benefit of the Beneficiary and did not include items or services that could jeopardize

SSI or Medicaid.

o Each Payment Request Form must be filled out completely and signed by an

Advocate.

o An incomplete Payment Request Form may result in processing delays or denial of

request.

o The Payment Request Form is available on the CCT website and can be submitted

online, by email, by fax, or by US mail. If you do not have access to the internet or a

printer, call CCT to request blank forms by mail.

o Allow 14 days from the date the request is received for processing and the check to

be mailed.

o Send copies of receipts or scanned images of receipts and not the originals. Original

copies of receipts are NOT accepted.

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HOW TO COMPLETE A PAYMENT REQUEST FORM AND

SAMPLE PAYMENT REQUEST FORM

To fill out a Payment Request Form, type or neatly print all of the following information:

1. Beneficiary Name: The full name of the Beneficiary. This is the person for whom

the trust was established and is intended to serve.

2. Account: The complete account number of the Beneficiary’s sub-account.

3. Make Payable To: The complete business name and address of the “Payee” (the

business, organization or individual to be paid).

4. Mail Check To: The complete name and mailing address of the Advocate. If the

check should go directly to the payee, check the box “Same as above.”

5. Account/Invoice Number: If applicable, write in the account number or reference

number for the check (e.g. utility account number or credit card number).

6. Amount Requested: The amount requested to be paid to the payee. CCT

reserves the right to approve a smaller disbursement amount than requested if

necessary.

7. Date Due: The date by which the payment must be received. Allow 14 business

days from the date the request is received at CCT for processing.

8. Payment For: State the purpose of the request (e.g. cell phone service, dental

check-up).

9. Beneficiary Receives: Indicate the Beneficiary’s Medicaid status and SSI status

at the time the Disbursement Request is submitted. Check the Yes box if the

Beneficiary receives Medicaid/SSI benefits; check the No box if the Beneficiary

does not receive Medicaid/SSI. If the Beneficiary receives SSI, check the box

indicating the request does not include payment for food, shelter, or

reimbursement to the Beneficiary.

10. Requested By: The printed name and signature of an Advocate. CCT may

require a second signature for some disbursement requests.

11. Contact Information: The phone number or email address at which the Advocate

can most easily be reached during business hours (9:00am – 5:00pm EST

(Easter Time), Monday through Friday).

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12/2016

Payment Request Form

Directions: Complete entirely and sign. Requests must include an invoice, copy of receipt, or price quote. Incomplete requests will result in delayed processing time. Requests require up to 14 days for processing. Please plan accordingly.

*BENEFICIARY NAME: John C. Smith *ACCOUNT: 123456789

*MAKE PAYABLE TO:

Name: ABC Phone Company

Address: PO Box 123456

Street Address or P.O. Box

Richmond VA 23242

City State Zip Code

*MAIL CHECK TO: ☐ Same as above OR

Name: Mrs. Sally Smith

Address: 456 Main Street

Street Address or P.O. Box

Richmond VA 23242

City State Zip Code

ACCOUNT/INVOICE NUMBER (if applicable): INV9874568589

*AMOUNT REQUESTED: $ 35.26 DATE DUE: 3/15/20147

*PAYMENT FOR: Phone bill

*Does the Beneficiary receive: Supplemental Security Income (SSI)? Yes ☐ No

Medicaid? Yes ☐ No

*SSI Recipients Only: Please check that this request does not include payment for food, shelter or reimbursement: Signer certifies the following: 1) I am authorized to make disbursement requests on behalf of the Beneficiary, 2) the

requested disbursement is for the sole benefit of the Beneficiary, 3) I will pay back to the trust any expenses found to be duplicates, not for the benefit of the Beneficiary, or incurred after the death of the Beneficiary, 4) I will follow SSI/Medicaid rules for reporting changes to the Beneficiary’s financial situation within 10 working days (SSI/Medicaid recipients only).

*Requested By: Sally Smith

1/5/2017 (Print Name) (Signature) (Date)

(If 2nd signature is required)

(Print Name) (Signature) (Date)

*CONTACT INFORMATION Telephone: 804-555-8545 Email: sallysmith@trustCCT.org

Contact CCT immediately about any changes to SSI/Medicaid benefits or about changes to any contact information for either the Advocate or Beneficiary.

Requests can be submitted to CCT via mail, fax, or email to the attention of Payment Request Processor: CCT, P.O. Box 29408, Richmond, VA 23242 • fax: (804)740-6065 • PaymentRequest@trustCCT.org

OFFICE USE ONLY Request Granted: ☐ Yes ☐ No Reason:

Authorized By: Date Authorized:

SAMPLE

Advocate Signature is Required

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WHO CAN RECEIVE FUNDS

Funds can be disbursed to the following with appropriate documentation:

A vendor (e.g. Telephone Company) or service provider (e.g. Caregiver).

An Advocate who has purchased goods and services on behalf of the

Beneficiary.

A credit card company for goods and services purchased on behalf of the

Beneficiary. (Include copies of itemized receipts and a copy of the credit card

bill, with the payment page.)

A pre-paid True Link Visa credit card (See section “Pre-Paid Credit Card”).

IMPORTANT: Please be aware that a check must be used for the full amount issued. It

is illegal to make alterations to a check.

HOW TO SUBMIT A PAYMENT REQUEST FORM

By Mail

CCT Attn: Payment Request Processor P.O. Box 29408 Richmond, VA 23242-0408

By Fax

804-740-6065 If you need to confirm that CCT received a Payment Request Form sent by fax, please call CCT on the same day that the fax is sent.

By Email paymentrequest@trustCCT.org You will receive a reply email within two (2) business days.

Submit online to CCT https://trustcct.seamlessdocs.com/f/paymentrequest You will receive an email confirmation and reply within two (2) business days.

TURNAROUND TIME

Disbursement requests are processed within 14 days of the date of receipt at CCT.

Checks are mailed from Richmond, Virginia, on Mondays, Wednesdays, and Fridays,

and may take 2-3 business days or longer to arrive via the US postal service. We ask

that you take this processing time into consideration and plan accordingly. Submit bills

as quickly as possible to allow for the turnaround time.

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REASONS A DISBURSEMENT REQUEST COULD BE DENIED OR

REQUIRE FURTHER DISCUSSION

There are a number of reasons why a disbursement request might be denied, such as:

Request is for items or services that would jeopardize SSI and Medicaid, such

as:

o Food, including meals at local restaurants

o Shelter expenses (rent, mortgage, property taxes, heating fuel, gas,

electricity, water, sewer, and garbage collection)

o Request is for cash or check to the Beneficiary

o Reimbursement of the Beneficiary’s debit card or checking account

o Purchase of money orders, gift cards, or charitable donations

Request is for items or services that represent a potential safety risk to the

Beneficiary (e.g. weapons, ammunition, alcohol, illegal drugs) and/or others

(bail).

Request is for more funds than remain in the trust account.

Request is for items or services that do not represent a prudent use of the trust,

or are inconsistent with the Budget and Objectives for the trust.

If there is concern about the intent of the Advocate, a case manager may be

hired to evaluate the situation and make a recommendation to CCT.

If the request is denied, CCT staff will return the Payment Request Form to the

Advocate with a written explanation.

REASONS A DISBURSEMENT REQUEST COULD BE DELAYED

There are a number of reasons why a disbursement request might be delayed, such as:

An invoice or receipt was sent without a Payment Request Form.

The Payment Request Form is difficult to read or incomplete.

The Payment Request Form was not signed by all Advocates, if more than one

signature is required.

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There is missing or insufficient supporting documentation.

The supporting documentation is not legible.

The Advocate delays responding to questions about the request.

When CCT has questions about a request, every attempt will be made to contact the

Primary Advocate(s) at least twice by phone, email, fax, or US mail. In addition, we may

contact the Secondary Advocate(s). If the Advocate(s) do not respond to our requests

for clarification within one week, we will return the Payment Request Form by mail and

(1) we will explain in writing why the request was denied and/or (2) ask the Advocate(s)

to resubmit it.

EXAMPLES OF HOW TRUST FUNDS CAN BE SPENT

The following are some examples of goods and services that can be paid for using a

Pooled Special Needs Trust. This is not a complete list. If you have questions about a

specific purchase, please call CCT before you buy. We are happy to help determine if

the purchase can be made using the trust.

Medication and Devices: The trust can provide funds for

prescription and nonprescription medication not paid for

by Medicaid, eye glasses, hearing aids, prosthetic

devices, and expenses for maintenance of these devices.

Medical Services: The trust can provide funds for services that are not paid for

by Medicaid such as dental care, eye exams, and hearing exams.

Assistive Technology: The trust can provide funds for technology such as

iPads, computers, and Text-to-Speech (TTS) or speech synthesizers.

Vehicle: The trust can provide funds for the purchase of a car (typically titled in

the name of the Beneficiary). A lien by CCT is required for

vehicles at the time of purchase.

Home Furnishings: The trust can pay for home furnishings

without affecting SSI or Medicaid.

Education: The trust can provide funds for vocational and computer training and

educational expenses such as tuition, books, and supplies.

16

Household bills: The trust can provide funds for phone, cable, and internet

service bill, car and renters’ insurance and storage units.

Clothing: The trust can provide funds for the Beneficiary’s

clothing.

Housing: The trust can provide funds for the purchase of a

home under certain circumstances.

Home Modifications: The trust can provide funds for home

modifications such as ramps and rails to accommodate the

Beneficiary.

Home repairs and upkeep: The trust can provide funds for

housecleaning services, lawn cutting, household cleaning

items, and paper products.

Care providers: The trust can provide funds for skilled

nursing care providers, companion services, and travel

companions if the Beneficiary requires assistance due to

a medical condition or disability.

Vacations: The trust can provide funds for travelling, including food and shelter

expenses, if the Beneficiary will be away from home temporarily. With a doctor’s

recommendation, it can also pay for a caregiver to accompany the Beneficiary.

Family Travel: The trust can provide funds for a family member or Advocate to

visit a Beneficiary who resides in a long-term care facility for the purpose of

supervising their medical care and living arrangements.

Mileage: The trust can reimburse for mileage while the

Beneficiary is in the car for medical visits, school, and work.

Pre-Need Burial and Funeral Expenses: The trust can

provide funds for a pre-paid burial or cremation as long as

payment is made before the death of the Beneficiary.

Case Manager: The Trust can provide funds for an assessment of the

Beneficiary’s needs and living conditions.

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HOME PURCHASE AND RENOVATIONS

Before using the trust to purchase or renovate a home, it is extremely

important that the Advocate contact CCT for information and

guidance.

I. HOME PURCHASE

The Advocate must contact CCT before making a commitment for the purchase of a

home to determine what documentation you will need to provide before a disbursement

can be approved for an Adult Beneficiary.

A home purchased with the Beneficiary’s trust funds is owned by the Beneficiary.

CCT does not own the home.

The home purchase must be for the sole benefit of the Beneficiary – if others live

in the home they may be required to contribute toward the home’s purchase or

pay rent.

The trust can pay for maintenance and furnishings without affecting SSI or

Medicaid.

An appraisal must be done to establish Fair Market Value (FMV) of the home.

If the Beneficiary receives SSI:

1. Before a disbursement for a home purchase or a shelter-related expense is

approved, CCT requires that the Advocate sign an acknowledgement stating

that they are aware of the potential impact on the Beneficiary’s SSI benefits,

and that CCT will inform the SSA regarding the disbursement.

2. A home purchase can result in a reduction in benefits. Purchasing a home

may be in the long-term best interest of the Beneficiary and worth the impact

to SSI.

CCT requires that Beneficiaries must be 18 or older for their trust to be used for

home purchases.

It is important for the Advocate to provide a budget that documents the

Beneficiary’s ability to manage ongoing costs, such as property taxes, repairs,

and general upkeep when requesting a disbursement to purchase a home.

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The Advocate may wish to consult with an attorney to discuss purchasing a

home using trust funds.

II. HOME RENOVATIONS

Contact CCT before making a commitment for home renovations to determine what

documentation you will need to provide before a disbursement can be approved.

Renovations can be approved for a home owned by the Beneficiary.

Modifications to home where Beneficiary plans to reside long-term to

accommodate the Beneficiary’s disability will be considered.

In certain situations for renovations to a home that the Beneficiary does not own,

CCT requires a Deed of Trust against the real property in favor of the Beneficiary

so that if the house is sold, the amount spent on the renovation, or a percentage

of the home’s value, would be owed to the sub-account.

BUYING A VEHICLE

Before using the trust to purchase a vehicle, it is important

that the Advocate contact CCT for information, guidance and

to determine what documentation is required before the

disbursement can be approved.

SSI and Medicaid rules allow a Beneficiary to own one vehicle without affecting

benefits.

Fair Market Value (FMV) must be established.

The vehicle must be titled or co-titled in the Beneficiary’s name.

Proof of insurance is required.

CCT will obtain a lien on the vehicle at the time of purchase. The lien will be held

until the vehicle is sold, no longer operational or there are no longer any funds in

the Beneficiary’s sub-account. If the vehicle is sold, funds from the sale are owed

to the Beneficiary’s trust account.

If owned with another individual, the use and benefit to each owner must be

considered in determining the Beneficiary’s percentage of ownership.

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It is important for the Advocate to provide a budget documenting that the

Beneficiary will be able to afford ongoing costs such as insurance, repairs,

maintenance, and gas.

CARE PROVIDER

Before using the trust to hire a care provider, the Advocate must

contact CCT.

The trust can be used to pay wages to care providers or

companions when the Beneficiary requires assistance related

to their disability.

If the care provider is employed through an agency, the trust can pay the agency

for costs not covered by Medicaid, Medicare, or private insurance.

Hiring a private care provider may place the Beneficiary in the position of being

an employer with a tax liability.

If the care provider is not employed through an agency, the Advocate will need to

sign the Caregiver Agreement Form that states that CCT is not the employer.

Before payment can be made from the trust to a private care provider, the care

provider will need to submit an IRS form W-9 to CCT.

If the trust pays the care provider more than $600.00 in a calendar year, CCT will

file a form 1099MISC with the IRS. This will notify the IRS that the care provider

has received payment for which taxes may be owed.

CASE MANAGEMENT SERVICES

CCT may, at our discretion, initiate case management services that are paid for by the

Beneficiary’s trust. The assessment can be initiated for various reasons and can help

with the following:

Provide an assessment of the needs of the Beneficiary and how the trust can be

of benefit to the Beneficiary

Determine whether the Beneficiary has a need for temporary or ongoing case

management services

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VACATION

Contact CCT in advance to discuss payment for a vacation or travel.

For SSI recipients:

SSI rules allow the trust to approve funds for food, transportation, and shelter

expenses for the Beneficiary and a companion. Documentation from a medical

professional is required in order for the trust to pay for a companion.

PRE-NEED BURIAL ARRANGEMENTS

Upon the death of the Beneficiary, no further disbursement requests will be

fulfilled. Making pre-need arrangements for a Beneficiary can help loved ones during a

difficult time, and provide family members with peace of mind, knowing that this decision

has been made and paid for. Pre-need burial arrangements must be made and paid

for prior to the death of the Beneficiary.

For Medicaid and SSI recipients: In order to protect the Beneficiary’s benefits, pre-need

funds should be paid directly and irrevocably to the funeral home. Contact CCT and a

funeral home of your choice for more information.

TRAVEL

Reimbursement for mileage and travel expenses can paid with the following restrictions:

The trust can reimburse mileage to an individual who drives the Beneficiary to

school or to medical/health-related appointments, or visits the Beneficiary in a

hospital or nursing facility.

CCT reimburses at the IRS reimbursement rate for medical mileage (rate subject

to change). This rate includes gas and wear and tear on the vehicle.

The trust can also pay/reimburse for public or other transportation expenses

when appropriate.

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BUDGET FORM AND OBJECTIVES OF THE TRUST FORM

The confidential information provided to CCT in the Budget Form and Objectives of the

Trust Form is used to understand the intent of the Advocate(s). These forms are

designed to foster conversation about the Beneficiary’s needs as they relate to the trust,

and can be revised as the Beneficiary’s needs change.

For A First-Party Pooled Special Needs Trust: We ask the Advocate(s) to

complete these forms when the account is first established.

For a Third-Party Pooled Special Needs Trust: Once the trust is funded, we

ask the Advocate(s) to complete a Budget Form and Objectives of the Trust

Form.

These forms can be updated annually or as the needs of the Beneficiary change.

Please call if you would like assistance with developing a budget or have questions

about these forms.

FAMILY AND BENEFICIARY INFORMATION FORM FOR THIRD-

PARTY TRUSTS

For a Beneficiary with a Third-Party Pooled Special Needs Trust, we request that the

Grantor(s) provide their vision for the trust and information about the Beneficiary using

the Family and Beneficiary Information Form. This information is confidential and helps

us understand the Grantor’s wishes for the trust. This form can be updated, as needed.

PARENTS’ RESPONSIBILITY FOR A MINOR

Parents and Guardians of a Minor Beneficiary have the responsibility to provide for

food, clothing, shelter, and school supplies. Parents wishing to use their child’s trust for

these items should contact CCT.

HOLIDAY EXPENSES

Advocates wishing to use trust funds for Christmas presents, birthday presents, or other

holiday expenses should contact CCT first.

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WEAPONS, ALCOHOL, AND BAIL

CCT does not approve requests for the following items. Contact CCT with questions.

Weapons, weapons accessories, or ammunition such as guns, knives,

compound bows, bullets or other similar items

Alcohol of any kind

Illegal and recreational drugs

Bail or bonding

Items and services that are illegal to purchase or possess

PRE-PAID CREDIT CARD (TRUE LINK)

A pre-paid True Link Visa credit card funded with money from the Beneficiary’s sub-

account is offered as a courtesy, with specific restrictions, to make it easier for

necessary purchases and emergencies. The following restrictions apply:

All purchases must be for the benefit of the Beneficiary.

The card must be used as a credit card. No PIN purchases, cash withdrawals,

cash refunds or cash back from purchases are allowed. If a purchase is

refunded, it must be refunded to the True Link card and not to any other form of

payment.

For a Beneficiary receiving SSI, and in some states Medicaid, the True Link card

cannot be used to pay for food or shelter expenses.

The Advocate(s) is required to submit receipts for all expenditures charged to the

card before further funds can be loaded onto the card.

Misuse of the card may result in temporary or permanent suspension of the card.

True Link Financial charges a $10.00 monthly fee whether the card is used that

month or not.

The process for obtaining a True Link card may take up to four weeks. The Advocate

will need to request a card on behalf of the Beneficiary. Contact CCT for more

information about the True Link card and to discuss whether this option is appropriate

for the Beneficiary.

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TAX INFORMATION

Beneficiaries with funded trusts will receive a K-1 Form as required by the IRS. This

form is for tax preparation purposes and will reflect taxable activity of the trust during a

given calendar year. It is mailed to the Primary Advocate. Consult with a tax preparer

with questions and to ascertain the Beneficiary’s responsibility to file annual tax returns.

UPON THE DEATH OF THE BENEFICIARY OF A FIRST-PARTY

TRUST

Upon the death of the Beneficiary, no further payment requests will be fulfilled.

When the Beneficiary of a First-Party Pooled Special Needs Trust receives Medicaid,

CCT is obligated to notify Medicaid of the death of the Beneficiary. Medicaid is owed for

all medical expenses paid by Medicaid in every state the Beneficiary has received

benefits. Sometimes, the repayment to Medicaid is greater than the remainder in the

Beneficiary’s trust. In that case, CCT retains the funds for its charitable purposes.

The following scenarios help to explain CCT’s policy for the remainder of trust funds

upon the death of the Beneficiary. CCT’s policy is followed to the extent that it complies

with each state’s Medicaid Policy:

(a) When Medicaid is owed less than the amount remaining in the trust, the

Successor or Contingent Beneficiary(ies) named on the Joinder Agreement

will receive the balance after Medicaid is reimbursed and administrative fees

are deducted.

(b) When Medicaid is owed more than the amount remaining in the trust, the

remainder will be paid to the appropriate state Medicaid authorities and/or

retained by CCT to support its mission, which includes the Charitable Fund

Award.

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UPON THE DEATH OF THE BENEFICIARY OF A THIRD-PARTY

TRUST

Upon the death of the Beneficiary, no further payment requests will be fulfilled.

With a Third-Party Pooled Special Needs Trust, funds remaining in the Beneficiary’s

trust account at the Beneficiary’s death are distributed to the Successor or Contingent

Beneficiary(ies) named on the Joinder Agreement, after all administrative fees are paid.

CLOSING THE TRUST

A trust is irrevocable when funded, meaning it cannot be closed while the Beneficiary is

living and funds are in the account. When the account balance is below $3,000, it may

be advisable to begin to spend down the trust for approved disbursements.

HOW TO CONTACT CCT

By Phone: 804-740-6930 main

888-241-6039 toll-free

By Email: paymentrequest@trustCCT.org

CCT office hours are Monday-Friday, 9:00am-5:00pm EST (Eastern Time). The CCT

office will be closed in observance of the following holidays:

New Year’s Day (January 1)

Columbus Day (Second Monday of October)

Martin Luther King, Jr. Day (Third Monday of January)

Veteran’s Day (November 11)

President’s Day (Third Monday of February)

Thanksgiving Day (Fourth Thursday of November)

Memorial Day (Last Monday of May)

Friday after Thanksgiving Day

Independence Day (July 4)

Two Days in Observance of the Christmas Holiday

Labor Day (First Monday of September)

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