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Disbursement Information Manual - *updated April 2021

TABLE OF CONTENTS

TABLE OF CONTENTS .................................................................................................. 1

CCT KEY DEFINITIONS ................................................................................................. 3

RESPONSIBILITIES OF CCT AS THE TRUST ADMINISTRATOR ................................ 7

RESPONSIBILITIES OF THE TRUSTEE ........................................................................ 7

GOVERNMENT BENEFITS: SUPPLEMENTAL SECURITY INCOME (SSI) AND

MEDICAID ....................................................................................................................... 7

OTHER GOVERNMENT BENEFITS ............................................................................... 9

REPORTING REQUIREMENTS TO GOVERNMENT AGENCIES FULFILLED BY CCT 9

REPORTING CHANGES TO THE BENEFICIARY’S STATUS TO GOVERNMENT

AGENCIES: MEDICAID AND/OR SSI RECIPIENTS ...................................................... 9

GUIDELINES FOR DISBURSEMENTS ........................................................................ 10

THE DISBURSEMENT DECISION-MAKING PROCESS .............................................. 10

THE DISBURSEMENT REQUEST PROCESS ............................................................. 11

GUIDELINES TO COMPLETE THE PAYMENT REQUEST FORM .............................. 11

CLIENT ACCOUNT ON CCT WEBSITE ....................................................................... 12

HOW TO COMPLETE A PAYMENT REQUEST FORM ............................................... 13

SAMPLE PAYMENT REQUEST FORM ........................................................................ 14

ADMINISTRATOR MANAGED PREPAID VISA CARD ................................................. 15

GUIDELINES TO COMPLETE THE TRUE LINK PAYMENT REQUEST FORM .......... 15

HOW TO COMPLETE A TRUE LINK PAYMENT REQUEST FORM ............................ 16

SAMPLE TRUE LINK PAYMENT REQUEST FORM .................................................... 18

EXAMPLES OF WHO CAN RECEIVE FUNDS ............................................................. 19

PRESENTING A CHECK AT A STORE ........................................................................ 19

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HOW TO SUBMIT A PAYMENT REQUEST FORM...................................................... 20

TURNAROUND TIME ................................................................................................... 20

REASONS A DISBURSEMENT REQUEST COULD BE DENIED/REQUIRE

ADDITIONAL INFORMATION ....................................................................................... 21

REASONS A DISBURSEMENT REQUEST COULD BE DELAYED ............................. 22

EXAMPLES OF HOW TRUST FUNDS CAN BE SPENT .............................................. 22

HOME PURCHASE....................................................................................................... 24

HOME RENOVATIONS ................................................................................................ 24

BUYING A VEHICLE ..................................................................................................... 25

CARE PROVIDER......................................................................................................... 25

CASE MANAGEMENT SERVICES ............................................................................... 26

VACATION .................................................................................................................... 26

PRE-NEED BURIAL ARRANGEMENTS ....................................................................... 27

PAYMENT/REIMBURSEMENT FOR MILEAGE AND TRAVEL .................................... 27

BUDGET FORM AND OBJECTIVES OF THE TRUST FORM ..................................... 28

FAMILY AND BENEFICIARY INFORMATION FORM FOR THIRD-PARTY TRUSTS .. 28

PARENTS’ RESPONSIBILITY FOR A MINOR ............................................................. 29

HOLIDAY EXPENSES .................................................................................................. 29

WEAPONS, ALCOHOL, AND BAIL............................................................................... 29

SCHEDULE K-1 TAX INFORMATION .......................................................................... 30

UPON THE DEATH OF THE BENEFICIARY: FIRST-PARTY PSNT ........................... 31

UPON THE DEATH OF THE BENEFICIARY: THIRD-PARTY PSNT ........................... 31

CLOSING THE TRUST ................................................................................................. 32

HOW TO CONTACT CCT ............................................................................................. 32

CCT’S HOLIDAY CALENDAR ...................................................................................... 32

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CCT KEY DEFINITIONS

Advocate(s): The advocate(s) is named by the grantor(s) on the CCT Joinder

Agreement (the legal document to join the trust). The advocate(s) has access to

confidential financial information about the trust and is authorized to make disbursement

requests by signing and submitting the Payment Request Form. The advocate(s) can be

the beneficiary, a guardian, conservator, power of attorney, family member, case

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

beneficiary. Contact CCT to change an advocate(s).

• Primary Advocate(s): The primary advocate(s) is responsible for making

requests for disbursements that are for the sole benefit of the beneficiary. The

primary advocate(s) will have access to financial statements and will receive

financial account information, tax documents, and other official correspondence

from CCT.

• Secondary Advocate(s): The secondary advocate(s) serves as backup to the

primary advocate(s). The secondary advocate(s) can receive financial account

information upon request and will be contacted by CCT at any time the primary

advocate(s) cannot be reached or to obtain additional information.

• Additional Contacts: In addition to the named primary and secondary

advocate(s), permission is granted for CCT to contact and share information with

named contacts should the need arise.

Beneficiary: The beneficiary is someone with special needs for whose benefit the trust

was created.

Definition of Disability as described by the Social Security Administration (SSA):

• For a child under the age of 18: The individual must have a medically

determinable physical or mental impairment or combination of impairments that

causes marked and severe functional limitations, and that can be expected to

CCT is a Pooled Special Needs Trust (PSNT) whose responsibility is to be the Trust Administrator

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cause death or that has lasted or can be expected to last for a continuous period

of not less than 12 months.

• For an adult 18 and older: The individual must be unable to engage in any

substantial gainful activity (SGA) by reason of any medically determinable

physical or mental impairment(s) which can be expected to result in death or

which has lasted or can be expected to last for a continuous period of not less

than 12 months.

Discretionary: Disbursements from a PSNT are at the sole discretion of the Trust

Administrator (CCT).

Grantor(s): The person(s) who establishes the PSNT:

• First-Party Pooled Special Needs Trust: The grantor(s) can be the beneficiary

with special needs or someone acting on behalf of the beneficiary such as the

parent(s), grandparent(s), the Court or legal guardian. The funds are the

beneficiary’s own funds from a personal injury award, workers’ compensation

claim, Social Security back payment, inheritance or savings.

• Third-Party Pooled Special Needs Trust: The grantor(s) is a third party, not the

beneficiary. It is typically a family member or friend but can be anyone. Once

established, the trust account can accept funds from any person(s).

Joinder Agreement: The legal document that allows the beneficiary to join the trust

and have a trust account with CCT.

K-1: An attachment to the income tax return filed by an estate or trust (Form 1041) that

reports a participant’s share of the trust’s or estate’s income, credits, and deductions.

(See Schedule K-1 Tax Information)

Medicaid: A Federal program, administered by the states, intended to provide health

coverage for the blind, aged and disabled who are impoverished. (See Government

Benefits: Supplemental Security Income (SSI) and Medicaid)

Medicaid Payback: This applies only to the First-Party Pooled Special Needs Trust, the

First-Party Pooled Special Needs Trust with Medicare Set-Aside, and the Military

Survivor Benefit Plan First-Party Pooled Special Needs Trust. In order for a beneficiary

of a First-Party Pooled Special Needs Trust to qualify for means-tested public benefits,

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federal and state law require that upon the beneficiary’s death, the state or states must

be repaid from the trust the amount that the state or states’ Medicaid program has paid

out on his or her behalf.

It is important to note that the Third-Party Pooled Special Needs Trust does not require

a Medicaid payback upon the beneficiary’s death. (See Upon the Death of the

Beneficiary: First-Party PSNT)

Pooled Special Needs Trust (PSNT): A PSNT is administered by a nonprofit

organization. The funds are pooled together for investment purposes. CCT offers the

following types of PSNTs:

• First-Party PSNT: Established with the beneficiary’s own funds (self-funded)

from a personal injury award, workers’ compensation claim, inheritance, savings

or Social Security back payment. For beneficiaries receiving Medicaid, this type

of trust is sometimes referred to as a Medicaid Payback trust. Remaining funds

at the death of the beneficiary are subject to reimbursement to state(s) for

medical bills paid during the beneficiary’s lifetime. (See Upon the Death of the

Beneficiary: First-Party Trust) This type of trust must be irrevocable by law.

• Third-Party PSNT: Established by a third-party grantor(s) who is typically a

family member or friend, and can be coordinated with an estate plan, life

insurance policy or gift. (See Upon the Death of the Beneficiary: Third-Party

Trust) The trust can be revoked by the grantor(s) until funded. Once the trust is

funded, the trust becomes irrevocable.

• Medicare Set-Aside (MSA) First-Party PSNT: Established with a portion of the

settlement from a worker’s compensation or liability lawsuit with an MSA nested

inside a First-Party PSNT. Federal law prohibits Medicare from paying for injury-

related medical expenses or for medications that an employer or health insurer

is primarily responsible to pay. To ensure Medicare does not pay a medical

expense or for medication when it is not primarily responsible, federal

regulations direct that a portion of settlement funds be “set aside” in an account,

known as a Medicare Set-Aside, to pay for future injury-related medical expense

and/or medications.

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• Military Survivor Benefit Plan First-Party PSNT: Established with annuity

payments from the Survivor Benefit Plan for the benefit of a dependent child who

has special needs.

Remainder Policy: This is the policy that determines what happens to the remaining

funds in a trust upon the death of the beneficiary. (See Upon the Death of the

Beneficiary: First-Party PSNT and Upon the Death of the Beneficiary: Third-Party

PSNT)

Successor and Contingent Beneficiaries: The grantor(s) designates successor and

contingent beneficiaries on the Joinder Agreement. This information determines what

happens to the remaining funds upon the death of the beneficiary.

• Third-Party PSNT - Successor and contingent beneficiaries can be changed by

the Grantor(s) prior to funding.

• First-Party PSNT - Successor and contingent beneficiaries cannot be changed.

Naming CCT as a successor beneficiary and/or contingent beneficiary, supports the

organization’s mission to serve people with special needs and is greatly appreciated.

Supplemental Security Income (SSI): A federal means tested program, for people

who are impoverished, administered by the Social Security Administration (SSA), that

provides a monthly monetary allowance for food and shelter and a small personal

allowance. (See Government Benefits: Supplemental Security Income (SSI) and

Medicaid)

Trust Administrator: A non-profit organization that oversees all aspects of the PSNT

services. (See Responsibilities of CCT as the Trust Administrator)

Trustee: The Trustee is responsible for the management and investment of the trust

funds. (See Responsibilities of the Trustee)

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RESPONSIBILITIES OF CCT AS THE TRUST ADMINISTRATOR

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

• Act prudently • Provide consultation when establishing a trust • Review each Payment Request and make disbursement decisions • Keep accurate records for each beneficiary • Maintain current knowledge of regulations governing SSI and Medicaid • Provide oversight of the Trustee for management and investment of the trust

funds • Provide information to government agencies for beneficiaries receiving SSI and

Medicaid • Collaborate, as needed, with attorneys, family members, the beneficiary or their

advocate(s) and others

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CCT has selected Capital First Trust Company to be the Trustee. The Trustee holds the

legal title of the trust funds for the benefit of the beneficiary and acts at the direction of

the Trust Administrator. The Trustee has the responsibility to:

• Manage and invest the funds (Visit the www.trustCCT.org for detailed Investment Information)

• Write checks and make disbursements at the direction of CCT • Maintain financial records for the beneficiary’s subaccount and provide access to

financial statements either electronically or by mail • Disseminate the annual tax form (K-1) to the advocate(s)

GOVERNMENT BENEFITS: SUPPLEMENTAL SECURITY INCOME (SSI) AND MEDICAID

One of the benefits of a PSNT is that the trust documents are written to protect the beneficiary’s SSI and Medicaid benefits. A PSNT is not considered a resource when determining eligibility for SSI and Medicaid. CCT is careful, when reviewing disbursement requests, to not jeopardize eligibility. There are many complex rules that must be followed in order to protect these benefits. Often, CCT is in a position of explaining what the government rules are for protecting benefits and what our responsibility is in these situations. It is extremely important to keep in mind that as the Trust Administrator CCT is charged with preserving eligibility for SSI and/or Medicaid benefits and this responsibility impacts disbursement decisions.

RESPONSIBILITIES OF THE TRUSTEE

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Please be aware of the following restrictions regarding disbursement requests for a Beneficiary who receives SSI and/or Medicaid:

• Disbursements from the trust account must be for the beneficiary’s sole benefit. Trust funds cannot be used to purchase gifts for other people or for charitable donations.

• When there are shared household expenses (such as cable or internet service), the cost must be divided among all users.

• With appropriate documentation, an advocate(s) can be reimbursed for expenses paid on behalf of the beneficiary or the trust can either pay the vendor directly by check. Whenever possible, the trust should pay the vendor directly by check instead of reimbursing the advocate.

• Before purchasing items for which you will request a reimbursement, please check with your Client Services Coordinator. There may be a cap on the amount of money the trust will reimburse to you for some purchases. All requests for reimbursement are reviewed on a case by case basis. Requests determined not to be in the child's best interest may be denied.

• Beneficiaries cannot receive cash. • If an advocate requests a disbursement from the trust to pay for food or shelter

(such as rent, mortgage, property taxes, heating fuel, gas, electricity, water, sewer, and garbage collection), the disbursement may be denied because SSI pays for these benefits.* If CCT were to approve the disbursement in an emergency:

o The Social Security Administration (SSA) would be notified and the disbursement could reduce the beneficiary’s SSI.

o The advocate(s) would be requested to sign a form acknowledging that the disbursement will be reported to the Social Security Administration and may reduce the beneficiary’s SSI check.

o Reporting to Medicaid is done on a state by state basis depending upon the rules of the state.

o CCT considers this our fiduciary responsibility.

* Funds from a PSNT can be transferred to an ABLE account to pay for housing if the beneficiary is eligible for and opens an ABLE account. To avoid any impact to the beneficiary’s SSI benefits, funds from the ABLE account used to pay for housing must be spent within the same calendar month that funds are withdrawn from the account.

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OTHER GOVERNMENT BENEFITS

In certain circumstances, having a PSNT may affect other government benefits or

eligibility for them. These include Supplemental Nutrition Assistance Program (SNAP-

formerly Food Stamps), Housing and Urban Development (HUD) housing, and Section

8 housing. A PSNT will not affect eligibility for Social Security Disability Insurance

(SSDI), Supplemental Security Income (SSI), Medicaid or Medicare.

REPORTING REQUIREMENTS TO GOVERNMENT AGENCIES

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

the trust account. CCT provides the following information to these agencies:

REPORTING CHANGES TO THE BENEFICIARY’S STATUS TO GOVERNMENT AGENCIES: 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:

• For SSI recipients: Contact the Social Security Administration at 1-800-772-1213

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(s)? • 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(s) submits the Payment Request Form with supporting documentation

Client Service Coordinators review the disbursement request

In-house Disbursement Committee meets regularly to review requests of a complex nature. The committee is

comprised of the Executive Director, Client Services Coordinators

and General Counsel.

Board of Directors Disbursement Committee is consulted as needed. The 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:

• Advocate(s) Requests a Disbursement: Disbursement requests are made by using a Payment Request Form. Backup documentation such as receipts, estimates, or invoices must be included.

• Requests are Reviewed: Requests are reviewed for appropriate use of funds using best practices criteria. Requests require up to 14 days for processing. Please plan accordingly.

• Approved Disbursement Requests: Approved requests are processed, and checks are mailed within 10 business days of the date the request is received by CCT.

• Questions or Concerns: When there are questions or concerns, every effort is made to contact the Advocate(s) within two business days from the date the request is received.

• Denied Requests: Denied requests are communicated to the Advocate(s) either verbally or in writing. When there is no response from the Advocate(s) pertaining to questionable requests, the requests will be denied.

If you disagree with the decision of the disbursement committee, please submit an appeal in writing to your client services coordinator. Include the reasons why you think the decision should be reversed, along with any documentation to support your request.

GUIDELINES TO COMPLETE THE PAYMENT REQUEST FORM

• 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:

• Itemized receipts • Estimates • Invoices • Price quotes

• Requests for reimbursement to the same payee can be combined on one Payment

Request Form. • Before purchasing items for which you will request a reimbursement, please

check with your Client Services Coordinator. There may be a cap on the amount of money the trust will reimburse to you for some purchases. All requests for reimbursement are reviewed on a case by case basis. Requests determined not to be in the child's best interest may be denied.

• Documentation 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.

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• Each Payment Request Form must be filled out completely and signed by an advocate(s).

• An incomplete Payment Request Form may result in processing delays or denial of the request.

• The Payment Request Form is available on the CCT website and can be submitted online, by email, by fax, or by US mail. The preferred method of submitting a Payment Request Form is through the CCT website. If you do not have access to the internet call CCT to request assistance.

• Allow at least 10 business days for approved requests from the date the request is received at CCT for processing and the check to be mailed.

• Send copies of receipts or scanned images of receipts. Do not send original receipts.

CLIENT ACCOUNT ON CCT WEBSITE

For assistance with creating your Client Account, call us at 804-740-6930 during office hours: Monday-Friday 9:00am-5:00pm EST. To make a Payment Request through CCT’s Client Account tab on our website’s homepage, click on the button that reads, “Client Account” at the top right of the screen. The following features are accessible via CCT’s Client Account Portal:

• Sub-account balance • Quarterly statements • Deposits • Administrator managed prepaid Visa card balance and settings (example

pictured below) • Disbursement requests and activity

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HOW TO COMPLETE A PAYMENT REQUEST FORM

To fill out a Payment Request Form, type or print all 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 subaccount. 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: If the check should be mailed directly to the payee, check the box

“Same as above.” If the check should be mailed to the advocate, beneficiary or other, provide the name and mailing address.

5. Account/Invoice Number: If applicable, write in the account, reference or invoice number so that this information can be included when mailing 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.

7. Date Due: The date by which the payment must be received. Allow 10 business days from the date the request is received by CCT for processing and the check to be mailed.

8. Payment For: State the purpose of the request (e.g. cell phone service, dental check-up). Be as detailed as possible.

9. Beneficiary Receives: Indicate the beneficiary’s Medicaid status and SSI status at the time the Payment Request Form 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(s). 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, Monday through Friday).

Always include the beneficiary’s name and account number on each email, fax and document submitted to CCT.

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SAMPLE PAYMENT REQUEST FORM

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ADMINISTRATOR MANAGED PREPAID VISA CARD

An Administrator managed prepaid Visa card funded with money from the beneficiary’s

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

necessary purchases and for emergencies. The following restrictions apply:

• All purchases must be for the benefit of the beneficiary. • The card must be used as a debit card. This means no PIN purchases.

Additionally, cash withdrawals, cash refunds, and cash back are NOT permitted. • For a beneficiary receiving SSI, and in some states, Medicaid, the administrator

managed prepaid Visa 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. • There is a $300 load limit for the card except in extenuating circumstances. • The process for obtaining a prepaid

card may take up to four weeks. The advocate(s) will need to request a card on behalf of the beneficiary. Contact CCT for more information about the prepaid card and to discuss whether this option is appropriate for the beneficiary.

GUIDELINES TO COMPLETE THE TRUE LINK PAYMENT REQUEST FORM

• All requests for a True Link upload must be completed on a True Link Payment

Request Form and be accompanied by itemized receipts for previous purchases.

• All requests must have supporting documents that include but are not limited to:

• Itemized list of planned purchases • Estimates • Unpaid Invoices • Price quotes

• Documents must demonstrate that the items or services purchased will be for the

sole benefit of the beneficiary and will not include items or services that could

jeopardize SSI or Medicaid.

• Each True Link Payment Request Form must be filled out completely and signed

by an advocate(s).

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• An incomplete True Link Payment Request Form may result in processing delays

or denials of request.

• The True Link 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.

• Allow 10 business days for approved requests from the date the request is

received at CCT for processing.

• Send copies of receipts or scanned images of receipts. Do not send original receipts.

HOW TO COMPLETE A TRUE LINK PAYMENT REQUEST FORM

To fill out a True Link Payment Request Form, type or neatly print 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 subaccount.

3. Make Payable To: The business name, True Link.

4. Previous Purchase Receipt(s) Total: The receipt(s) total amount from the

previous transactions made on the True Link card.

5. Previous receipt (s) attached: Attach copies of all receipt(s) from previous

purchases made on the True Link card. If all copies of receipt(s) are not

attached, explain why.

6. New Amount Requested: The amount requested to be uploaded onto your

True Link card. CCT reserves the right to approve a smaller disbursement

amount than requested if necessary.

7. Estimate Attached: The backup documentation for your new requested

amount (e.g. quotes and estimates).

8. Details of Request(s): Details that state the purpose of your request – what

the money will be used for.

9. Beneficiary Receives: Indicate the beneficiary’s benefits status at the time the

payment request is submitted. Check Yes box if the beneficiary receives

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SSI/Medicaid/SSDI/Medicare or Other benefits; check the No box if the

beneficiary does not receive SSI/Medicaid/SSDI/Medicare. If the beneficiary

received 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(s). CCT may

require a second signature for some disbursement requests.

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

advocate(s) can most easily be reached during business hours (9:00am-

5:00pm EST, Monday through Friday).

Always include the beneficiary’s name and account number on emails, faxes and documents submitted to CCT.

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SAMPLE TRUE LINK PAYMENT REQUEST FORM

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EXAMPLES OF 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). • A retail merchant (e.g. department store, furniture store) • 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.)

• An administrator managed prepaid visa card

PRESENTING A CHECK AT A STORE

When presenting a check as payment at a retail store, ask that the check be run as a

corporate/company check. If the cash register does not have this option, the check can

also be run as:

If the cashier cannot run the check, ask for a manager to try again. If the manager

cannot accept the check, take the check back and call CCT for a replacement option.

*DO NOT give your social security number, your ID or endorse the back of the check.

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

is illegal to make alterations to a check. Do not request cash back.

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HOW TO SUBMIT A PAYMENT REQUEST FORM

• Complete a One-time Payment Request through our online portal.

• Request access to make Payment Requests online by submitting the Statement Options Form or call CCT directly at 804-740-6930 (9:00 am to 5:00 pm, EST, Monday-Friday).

• If you prefer to email, fax, or mail, you can download a fillable Payment Request Form.

CCT Website/ True Link Portal

CCT offers online access to account information. Now you can access account information and submit payment requests online through our new True Link Client Account Portal.

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.

TURNAROUND TIME

Requests are processed within 10 business days of the date of receipt at CCT. Checks

are mailed from Richmond, VA, Monday-Friday excluding holidays, and may take 3+

business days to arrive via US Postal Service. Please take this processing time into

consideration and plan accordingly. Submit bills that are time sensitive as quickly as

possible to allow for turnaround time. If appropriate supporting documentation is not

provided by the Advocate(s), there may be a delay in processing the request.

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REASONS A DISBURSEMENT REQUEST COULD BE DENIED/REQUIRE ADDITIONAL INFORMATION

The following are some of the reasons a disbursement request might be denied:

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 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.

Concern about the intent of the advocate(s). A case manager may be hired to

evaluate the situation and make a recommendation to CCT.

If the request is denied, CCT staff will notify the advocate(s). If you disagree with the decision of the disbursement committee, please submit an appeal in writing to your client services coordinator. Include the reasons why you think the decision should be reversed, along with any documentation to support your request.

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REASONS A DISBURSEMENT REQUEST COULD BE DELAYED

Examples of why a disbursement request could be delayed:

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

primary Advocate(s) by either phone, email, fax, or US mail. In addition, CCT may

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

for clarification within 24-48 hours, 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 with the answers to the stated concern.

EXAMPLES OF HOW TRUST FUNDS CAN BE SPENT

If you have questions about a purchase, please call CCT before you buy or sign a

contract to buy. We are happy to help determine if the purchase can be made using the

trust. For large purchases including, but not limited to a vehicle or home, please

contact CCT well in advance to receive a list of documentation you will need to provide

with the disbursement request so that it can be reviewed.

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

the Advocate(s).

There is missing or insufficient supporting

documentation.

The supporting documentation is not

legible.

The Advocate(s) has not responded to

questions about the request.

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

Medication and Devices: The trust can provide funds for prescription and

nonprescription medication not paid for by Medicaid: eyeglasses, 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) and for on-going maintenance and repairs. A lien by

CCT is required for vehicles at the time of purchase.

Home Modifications and Furnishings: The trust can provide funds for home

modifications such as ramps and rails to accommodate the beneficiary and 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.

Household bills: The trust can provide funds for

phone, cable, internet service, car and renters’

insurance, and storage units.

Clothing: The trust can provide funds for the beneficiary’s clothing.

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.

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Family Travel: The trust can provide funds for a family member or advocate(s)

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. See Payment/Reimbursement for Mileage

and Travel

Pre-Need Burial and Funeral Expenses: The trust can provide funds for a pre-

paid burial or cremation if 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.

HOME PURCHASE

The advocate(s) must contact CCT several months in advance of purchasing a home.

CCT requires detailed documentation before considering the use of trust funds to make

the purchase. The Disbursement Committee will conduct a careful review of the

documentation and the beneficiary’s circumstances to determine if the purchase is in

the best interest of the beneficiary and whether the purchase will be approved.

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 a home (where the 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 trust subaccount.

• CCT requires that all work be done by licensed and insured contractors, and that

several estimates be obtained.

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BUYING A VEHICLE

Before using the trust to purchase a vehicle, it is important that the advocate(s) contact

CCT. CCT will provide written information outlining the documentation that is required

before the vehicle purchase 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 subaccount. If the vehicle is

sold, funds from the sale are owed to the beneficiary’s subaccount.

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

considered in determining the beneficiary’s percentage of ownership.

• CCT requests that the advocate provides 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(s)

must contact CCT. Please consider the following before hiring

a care provider.

• The trust can be used to pay 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.

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• If the care provider is not employed through an agency, the advocate(s) will need

to sign the Caregiver Agreement Form that states that for tax obligations, the

caregiver is not an employee of CCT.

• Before payment can be made from the trust to an independent care provider, the

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

• If the trust pays the independent 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.

• In many situations, where the arrangement is regular and ongoing, CCT will

require that an employment agency be used for payroll obligations.

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 or other service that may be helpful.

VACATION

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

For SSI recipients:

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

expenses for the beneficiary on vacation. For the trust to pay for a travel

companion, documentation from a medical professional is required that explains

the need for a companion.

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PRE-NEED BURIAL ARRANGEMENTS

Pre-need burial arrangements must be made and paid for prior to the death of the beneficiary. Upon the death of the beneficiary, no further disbursements can be made. 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.

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.

PAYMENT/REIMBURSEMENT FOR MILEAGE AND TRAVEL

Payment/Reimbursement for mileage and travel expenses:

• For an advocate or other person driving a beneficiary to school, work or to a

medical/health-related appointment:

1. Using the advocate or other individual’s own vehicle, the trust can reimburse /

pay for mileage at the IRS medical mileage reimbursement rate (rate subject

to change). A Mileage Reimbursement Form is required and is available on

the CCT website or by contacting CCT.

2. Using a vehicle titled in the name of the beneficiary, the trust can pay for gas.

• The trust can reimburse a family member for travel expenses to visit the

beneficiary in a hospital or nursing facility.

• The trust can also pay/reimburse for public or commercial transportation

expenses when appropriate.

*Before purchasing items for which you will request a reimbursement, please check with your Client Services Coordinator. There may be a cap on the amount of money the trust will reimburse to you for some purchases. All requests for reimbursement are reviewed on a case by case basis. Requests determined not to be in the child's best interest may be denied.

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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.

• First-Party PSNT: We ask the advocate(s) to complete these forms when the

trust is first established.

• Third-Party PSNT: We ask the advocate(s) to complete these forms once the

trust is funded.

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.

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PARENTS’ RESPONSIBILITY FOR A MINOR

Parents and guardians of a minor beneficiary have the responsibility to provide for their

children’s needs. These needs include, but are not limited to, food, clothing, shelter

needs (for example: rent, utilities, furniture), and school supplies. Parents wishing to use

their child’s trust for these items should contact CCT to discuss the request. Before purchasing items for which you will request a reimbursement, please check with

your Client Services Coordinator. There may be a cap on the amount of money the trust

will reimburse to you for some purchases. All requests for reimbursement are reviewed

on a case by case basis. Requests determined not to be in the child's best interest may be denied.

HOLIDAY EXPENSES

Contact CCT to use trust funds for holiday and birthday

presents for the beneficiary. The maximum amount is $400

per occasion.

WEAPONS, ALCOHOL, AND BAIL

CCT does not approve requests for the following items.

• Weapons (such as guns, knives, compound bows), weapons accessories, or

ammunition including bullets or other similar items

• Alcoholic beverages

• Any cannabis related product that includes THC as an ingredient, regardless of

its legality in the state where the beneficiary resides

• Illegal and recreational drugs

• Bail or bonding

• Items and services that are illegal to purchase or possess

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SCHEDULE K-1 TAX INFORMATION

Beneficiaries with funded trusts will receive a grantor letter or Schedule K-1 after the

trust has filed its annual income tax return (Form 1041) as required by the IRS. The tax

return is not required to be filed until April 15th each year, but the trust strives to file it

earlier so that the trust beneficiaries receive the grantor letters or K-1s as soon as

possible. A 1041 is filed for both the CCT First-Party and Third-Party Pooled Special

Needs Trusts (PSNT). The K-1 is for tax preparation and reporting and reflects the

taxable activity of the beneficiary’s trust account during a given calendar year.

As required by the IRS, CCT beneficiaries who have a funded First and/or Third-Party

PSNT account will receive a Schedule K-1 that is prepared by an accounting firm and

mailed to the advocate. CCT mails the K-1s as soon as they are received from the

accounting firm. Because the Trustee’s filing deadline with the IRS is the same as the

personal tax filing deadline, beneficiaries may need to file for an extension.

CCT recommends that if you have any questions

regarding the Schedule K-1, that you consult with

a tax preparer to ascertain the beneficiary’s

responsibility to file annual tax returns.

CCT, like a bank reporting interest or an employer reporting wages, merely reports the activity of the PSNT account. CCT cannot provide tax advice.

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UPON THE DEATH OF THE BENEFICIARY: FIRST-PARTY PSNT

Upon the death of the beneficiary, no further disbursements can be made.

For a Beneficiary of a First-Party PSNT Who Received Medicaid Benefits CCT is obligated to notify Medicaid of the death of the beneficiary. Medicaid is owed for

all medical expenses paid by Medicaid on behalf of the beneficiary in every state the

beneficiary has received Medicaid benefits.

The following scenarios help to explain CCT’s policy for the remainder of the First-Party

PSNT funds upon the death of the beneficiary. CCT’s policy is followed to the extent

that it complies with each state’s Medicaid Policy:

For a Beneficiary of a First-Party PSNT Who Never Received Medicaid Benefits Upon the death of the Beneficiary, the remaining funds are distributed to the Successor

Beneficiary(ies) per the Joinder Agreement after allowable distributions for CCT

administrative fees and True Link Financial Advisors, LLC investment management fees

are deducted.

UPON THE DEATH OF THE BENEFICIARY: THIRD-PARTY PSNT

Upon the death of the beneficiary, no further disbursements can be made.

Upon the death of the Beneficiary, distributions for CCT administrative fees and True

Link Financial Advisors, LLC investment management fees are allowed. After the

administrative fees are disbursed, the remaining funds are distributed as designated in

the Joinder Agreement.

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

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CLOSING THE TRUST

A trust is irrevocable when funded, meaning it cannot be

closed while the beneficiary is alive, 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.

Customary administration and management fees for both CCT and the trustee will be

deducted from the account before it is closed.

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.

CCT’S HOLIDAY CALENDAR

The CCT office will be closed in observance of the following holidays:

New Year’s Day (January 1) Labor Day (First Monday of September)

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

Columbus Day (Second Monday of October)

President’s Day (Third Monday of February) Veteran’s Day (November 11)

Memorial Day (Last Monday of May) Thanksgiving Day and Friday after (Fourth Thursday of November)

Independence Day (July 4) Christmas Holiday (Two Days in Observance)