Trust Distributions

Trust Distributions2021-10-05T09:18:20-04:00

Trust Distributions

Generally speaking, funds in a special needs trust can be used to meet the disability-related needs of the trust beneficiary and to improve the quality of life of the beneficiary.  Goods and services must be for the sole benefit of the beneficiary, not for the benefit of other family members or friends (although incidental benefits to others will not prevent the funds from being used).  Some examples of common uses of special needs trust funds are listed in the link below.  These are examples only, many other things may also be covered or, conversely, the language of a particular trust may limit the uses of that trust.

A special needs trust is designed to cover the expenses of goods and services that are supplemental to a beneficiary’s basic needs (food and shelter). Basic food and shelter expenses should be provided through a beneficiary’s Social Security Disability payment or Supplemental Security Income.

This list is offered to provide guidance on how a special needs trust can be utilized to help enhance the quality of a person’s life, and is by no means all inclusive. Please keep in mind that the Trustee by law must have absolute discretion in reviewing requests for distributions. Therefore, you should not view this list as guarantees. Your trust document may also contain specific language regarding distributions.

Uses of a SNT Alphabetically Listed

Allowable Uses of SNT  By Category

Distributions may be requested in various ways, including: in advance of expenditures; as a reimbursement for expenses; or as a direct payment to vendors. All expenditures must be verified by the original receipts.

In order to request a distribution from an individual’s account with ACT, the following procedures need to be followed:

Distribution Policy & Procedures

  1. The beneficiary or their representative must submit a Fund Request form to request a distribution. All supporting documentation (original receipt, invoice, bill, letter of explanation, etc.) should be included. For large or unusual purchases, prior approval should be obtained.
  2. In most cases, a check should be received within 10 to 14 business days following receipt, review and approval of the Fund
  3. A check may be issued as an advance for anticipated expenses, reimbursement for expenses or a direct payment to a verified service provider. In some cases the use of an ACH payment can be utilized. The original receipts for items must be received by ACT before another check can be approved.
  4. Original receipts for items purchased must be sent to ACT in order to verify the use of the trust funds. Credit card statements should be accompanied by the original Copies can be sent for services such as telephone, cable and medical bills.
  5. All receipts should be detailed in nature and accompanied by an explanation for each purchase. Receipts should be submitted on a monthly basis. Receipts that are held for an extended period of time may not be reimbursed.
  6. All requests for gas or mileage (Mileage form) should be discussed in advance of submittal.
  7. Any request for a trip/vacation should be discussed in advance of the planned trip. It is highly recommended that you utilize a travel agent.
  8. Services, such as attendant care, respite or case management, must be discussed in advance of submittal. The service provider’s name and address are required when completing the Service form. The service provider’s signature and the signature of the Beneficiary or their designee are required.

Please complete the forms with the appropriate information and details. After completing the form;

  1. Save a copy for your records,
  2. Print out the form and sign
  3. Submit with the appropriate documentation.

ACT – 1012 W 9th Ave. – Suite 215 – King of Prussia, PA 19406

Disbursement Request Form

ACT Outside Custodian Disbursement Request Form

Tutor Disbursement Request Form

ACT Service Form

ACT Mileage Form

ACH Reimbursement – Link to Electronic Disbursement for Reimbursements to Bank Account

If you have questions or are wondering if a specific item/request will impact the beneficiaries benefits or is permissible through the specific Trust agreement please contact us through the provided form. Simply get in touch and we’ll get back to you as soon as we can.

We look forward to hearing from you!

FAQ for Disbursements

Trust accounts administered by the ACT are designed to safeguard eligibility for government benefits.  Therefore, all disbursement requests must be in writing and include supporting documentation (including, but not limited to, receipts, invoices, statements and proof of payment). Each request is reviewed carefully by staff to ensure compliance with the Trust document and the applicable regulations, extraordinary requests are also reviewed and approved by the ACT Board of Directors.

How does the process work?2018-12-20T08:23:09-05:00

The Beneficiary or the Beneficiary’s authorized representative submits a Request for Disbursement form with appropriate supporting documentation to ACT via email, fax, or mail for the Beneficiary’s supplemental needs.

The Trust Administrator assigned to the account reviews each request to determine its appropriateness in light of the Trust’s terms and any benefits that the Beneficiary may be receiving.

If the request is approved, the funds from the trust account are released for payment to the vendor, service provider, or person for whom reimbursement is sought.  Please note that Social Security regulations prevent reimbursement directly to the Beneficiary under any circumstances.

Depending upon the nature of the request, the request may be paid through ACT’s business credit card.  For such requests, after the payment is authorized on ACT’s card, the funds are deducted from the Trust.

For Beneficiaries who use ACT’s restricted debit card service, cards are loaded with trust funds monthly following review of receipts for purchases made in the prior month.  Please refer to the instructions for further information regarding issuance and use of restricted debit cards.

Who can make a disbursement request?2018-12-20T08:27:04-05:00

The Beneficiary or the Beneficiary’s authorized representative may make a disbursement request.

What can money be requested for?2018-12-20T08:27:38-05:00

Money distributed from a Trust account must be used for supplemental services or items for the sole benefit of the Beneficiary. Some supplemental services or items may require prior submission to the Beneficiary’s health insurance or to a government program and must be denied prior to being considered for fulfillment from a trust account. If a disbursement would disrupt a government benefit, further review may be warranted prior to granting the request.

In some cases, when it is necessary for a Trust to disburse funds for needs that are considered by Social Security to be In-Kind Support and Maintenance payments (i.e. payments for basic shelter and for food), ACT notifies the local Social Security office regarding the details of the payment.  The payment may affect the amount of benefits received in a subsequent month.

What forms are needed to make a disbursement request?2018-12-20T08:52:29-05:00

The Request for Disbursement form must be submitted with each request.  Supporting documentation must be submitted at the time the request is made.  Requests without documentation will not be fulfilled until the documentation is received. Please see the above section on Disbursement Forms for the specific form corresponding to the beneficiaries request.

How often can requests be made?2018-12-20T08:28:53-05:00

Requests can be submitted to ACT at any time and there is no limit on the number of requests that can be submitted.

When does ACT review requests?2018-12-20T08:29:25-05:00

A Trust Administrator reviews the request and supporting documentation as soon as practicable after the request is received, often on the first business day following receipt.

How long does it take?2018-12-20T08:30:00-05:00

Generally, it takes approximately 7 – 10 business days for a disbursement check to be issued in response to a request submitted with proper documentation, but the request may take longer if there is a need for additional documentation or there are questions regarding the distribution.

Some requests may require approval of the appropriate Court having jurisdiction of the Trust and/or approval of the Pennsylvania Department of Human Services (or if applicable, the state authority that administers the Medicaid program for the state in which the Beneficiary resides).  Requests that require Court approval may take a significantly longer time to fulfill and may require submission of additional documentation to support approval of the request.

What if there is an emergency?2018-12-20T08:30:28-05:00

Emergency distribution requests can be made at any time, but ACT cannot guarantee that the request will be fulfilled within a certain time frame.  Requests received during non-business hours will be reviewed at the first opportunity on the next business day.

If the same thing is requested every month, does the distribution request form need to be submitted to ACT every month?2018-12-20T08:31:00-05:00

If the amount of the item or service remains the same or consists of a bill that the Trust customarily pays for regularly (such as cable or cellular phone), there is generally no need to submit a Request form for each month that payment is requested.  A Beneficiary may contact the service provider to have the bill sent directly to ACT, but should not do so until the request has been approved by a Trust Administrator.

Is there a limit on the amount that can be requested to pay for a supplemental service or item?2018-12-20T08:31:32-05:00

No, there is no limit. The entire balance of a trust account is available to pay for a supplemental service or item, but the request must be properly submitted and approved by ACT.  If a disbursement request is received that will fully deplete the Trust, ACT may require that a reserve be held in the account for payment of any final fees, including tax preparation fees, and any taxes that may be due in the current calendar year and/or the calendar year following the depletion of the trust.

When money is distributed from the account, who gets it and where is it sent?2018-12-20T08:32:00-05:00

On the Distribution Request Form, the Beneficiary indicates the “payee” and where to send the check. The “payee” is the person or company to whom a check is made payable. The payee should be the vendor or provider of the supplemental item or service or a third party if the request is for reimbursement of an item that has been purchased for the Beneficiary.  The check can be sent directly to the payee.  Checks cannot be made payable to the Beneficiary.  Services or items for which requests are made must be for the sole benefit of the Beneficiary.

Why do I need to submit receipts, invoices, or statements?2018-12-20T08:32:45-05:00

Invoices, quotes, receipts, or statements for requested items are needed to document each expense and help safeguard eligibility for benefits. If these items are not provided, the request may be denied.

What if a request is denied?2018-12-20T08:41:58-05:00

A request may be denied because additional information or documentation is needed. If this is the case, the request can be submitted again with the proper documentation.  A request may also be denied because the request exceeds the balance available in the Trust, because the request is not permissible under the terms of the Trust, because the request primarily benefits a person other than the Beneficiary, or because the request is inappropriate in light of the amount available for distribution and the beneficiary’s needs.  The Beneficiary has the right to receive an explanation from ACT as to why a request has been denied.


In 2001 ACT was incorporated as a non-profit charitable organization in Pennsylvania for the purpose of administering a pooled special needs trust for the benefit of individuals with disabilities.  Over the years ACT also became Trustee for other special needs trusts, including Third Party Special Needs Trusts, which are funded with the assets of someone other than the Trust Beneficiary; Non-Pooled Special Needs Trusts, which are funded with assets belonging to the Trust beneficiary; and, educational special needs trusts.

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