FAQs

Contents

1.   How does the Springhill Pooled Accounts Trust protect my benefits?
2.   What is Community Housing Network’s role with the Springhill Pooled Accounts Trust?
3.   What are the advantages of the Springhill Pooled Accounts Trust?
4.   Who can join the Springhill Pooled Accounts Trust?
5.   I am thinking about executing a Joinder Agreement with the Trust. When should I contact you?
6.   What happens to any funds remaining in the Trust after an individual’s death?
7.   What can the Trust pay for?
8.   Are there any special rules the Trust Administrator has to follow?
9.   How do I request a disbursement?
10. How does the Trust Administrator decide to pay for something?
11. How long does it take to get a disbursement request paid?
12. Can I add money to the Trust?
13. What are some other rules that I need to know?
14. What does it cost to join? Are there other fees?
15. How are the Trust assets managed?

Trust Overview

1. How does the Springhill Pooled Accounts Trust protect my benefits?

Generally, the Social Security Administration and the Michigan Department of Human Services view all trusts as countable resources when determining eligibility for benefits such as Supplemental Security Income (SSI) and Medicaid. Special needs trusts (including the Springhill Pooled Accounts Trust) are an exception to this rule.

A Pooled Accounts Trust is specifically set up to supplement (not replace) basic government support for an individual’s needs. Indeed, the Trustee is typically restricted from making a disbursement that might jeopardize public benefits.

By complying with federal and state laws for special needs trusts (e.g., 42 USC Sec. 1396(p)(d)(4)(C), funds placed in the Springhill Pooled Accounts Trust are generally not considered countable resources, which helps its beneficiaries establish or remain eligible for government benefit programs.

2. What is Community Housing Network’s role with the Springhill Pooled Accounts Trust?

Community Housing Network, Inc. (also a 501(c)(3) nonprofit is the administrative agent for the Springhill Pooled Accounts Trust. Springhill Housing Corporation is the Trustee of the Springhill Pooled Accounts Trust.  Community Housing Network and Springhill Housing Corporation are housed in the same offices and work together on a daily basis in many different capacities. 

3. What are the advantages of the Springhill Pooled Accounts Trust?

There are several advantages of the Springhill Pooled Accounts Trust. The Trust was created and is administered by nonprofit housing organizations. In addition to being a nonprofit, Springhill Housing Corporation manages many properties for individuals with disabilities. Community Housing Network, Inc. is also a 501(c)(3) with many programs that specifically benefit individuals with disabilities, including a Housing Resource Center that may be able to connect Trust beneficiaries to other resources in the disability community.

Second, by pooling together the resources of many individuals, the Trust is able to reduce expenses and administrative fees for each beneficiary.

Third, while a stand-alone trust would require a substantial balance to make financial sense, the Springhill Pooled Accounts Trust allows for a $500 minimum balance* and a $1,000 minimum initial deposit requirements.

Fourth, the Trust staff are knowledgeable of government benefit programs, and have experience working with people with disabilities.

Finally, while we encourage all those interested in joining the Springhill Pooled Accounts Trust to seek legal advice, joining the Trust is typically less expensive than creating and administering a stand-alone trust.

4. Who can join the Springhill Pooled Accounts Trust?

Any person under age 65 with a disability can join. Most often beneficiaries have already been determined to be disabled by the Social Security Administration.

A beneficiary joins the Trust by signing the Joinder Agreement (enrollment steps and paperwork are here). The Joinder Agreement creates a sub-account for the individual within the larger Trust. By executing the Joinder Agreement, you are agreeing to the terms of the Trust which are outlined in the First-Party Declaration of Trust here and Third-Party Declaration of Trust here.

First-Party: The beneficiary can sign the Joinder Agreement. Additionally, the law allows for a parent, grandparent, court or legal guardian to sign for someone who cannot sign on their own. A power of attorney for the beneficiary can also sign if the power of attorney gives that individual the power to make a contract or form a trust.

Third-Party: Anybody but the beneficiary can sign the Joinder Agreement.

5. I am thinking about executing a Joinder Agreement with the Trust. When should I contact you?

As soon as possible. The Trust Administrator reviews the beneficiary’s enrollment package before accepting the Joinder Agreement and depositing funds into the Trust. If you or your attorney review your situation with the Trust Administrator before  executing a Joinder Agreement, it will likely be accepted as soon as it is received.

Cash assets are generally accepted by the Trust. If you would like to place a non-cash asset into the trust, we strongly encourages you to contact the Trust Administrator beforehand to ensure that the Trust will accept the asset. The Trust strives to work with each individual and/or advisor to quickly determine if the non-cash asset is appropriate for the trust.

6. What happens to any funds remaining in the Trust after an individual’s death?

It depends on whether the assets being placed into the Trust belong to the individual or someone else (a “third-party”) when placed into the Trust. If the assets belong to the individual with disabilities and a pooled trust such as Springhill Pooled Accounts Trust is not utilized, the state must be repaid for the Medicaid expenses paid on the individual’s behalf before the assets can be distributed to any other individual after death. In Michigan, one advantage of a pooled trust is the state does not have to be repaid for Medicaid expenses incurred on the individual’s behalf if the funds remain in a trust for the benefit of other individuals with disabilities.

If the assets placed into a trust belong to someone other than the individual with disabilities (i.e., a “third-party”), there may be additional planning options. Please contact us to discuss what options may be available.

Trust Disbursements

7. What can the Trust pay for?

Government benefits, such as Supplemental Security Income (“SSI”) and Medicaid can provide funds to a person with disabilities to be used for housing, food, and medical needs. The Trust usually cannot pay for items the government provides or are provided for by some other resource. However, the Trust can generally pay for other items that would increase or improve the beneficiary’s quality of life. Some examples of typical disbursement requests include clothing, travel, entertainment, transportation, computers, cell phones, and other items based on an individual’s needs. Please review this Permissible Disbursements document for additional information. Please note: disbursement decisions must take into account a beneficiary’s specific benefit situation.

8. Are there any special rules the Trust Administrator has to follow? 

Yes. There are many rules and policies the Trust Administrator has to abide by that are issued by both the state and federal government. Michigan’s rules for Medicaid Assistance are found in the Bridges Eligibility Manual (BEM) and the federal policies for Supplemental Security Income (SSI) are found in the Program Operations Manual Systems (POMS). The rules are on-line and change frequently. There are also other rules and guidelines for Home Choice Vouchers (also called Section 8 housing).

9. How do I request a disbursement?

Disbursement requests are made in writing, using the Disbursement Request Form, along with a receipt or some other proof of what is being purchased. In addition to receipts, proof could include a quote from a store, a bill for service to be provided, or potentially other writings that support the request.

Home, auto and vacation purchases: These requests require a longer approval / processing time as well as additional documentation requirements. Before making purchase plans, please loop us in as soon as possible as we cannot guarantee approval without prior authorization.

Disbursement requests can be submitted, in writing, with all supporting receipts and documentation in any of the following ways:

Email: disbursements@chninc.net, Fax: 248-269-1311 or

Mail: Springhill Pooled Accounts Trust, 5505 Corporate Drive, Ste. 300, Troy, MI  48098

We will then work with the individual to ensure that the requested expense is an appropriate expenditure. Typically, Springhill Pooled Accounts Trust will pay the vendor or credit card company directly for the expense.

10. How does the Trust Administrator decide to pay for something?

The Trust Administrator considers many things before paying a request. Primarily, the Trust Administrator considers whether the disbursement will have any negative consequences to the individual’s benefits. However, the administrator may also consider other factors. For example, is there enough money in the beneficiary’s sub-account? Is the request in the beneficiary’s best interests and for his or her sole benefit? Would the disbursement increase his or her quality of life? Is there someone else responsible for paying the request or is it available from another resource? If the Trust Administrator is not able to make a disbursement, the Trust strives to explain to the beneficiary why the disbursement cannot be made and to see if there is another way that the Trust can help. Cash and cash equivalents are never permissible disbursements.

11. How long does it take to get a disbursement request paid?

Requests received by Monday at 4:30 p.m. generally will be paid by Friday, if approved and additional research is not needed. If there is an emergency, exceptions can be made on a case by case basis.

12. Can I add money to the Trust?

Yes, money and other assets can be added to the Trust at any time. Settlements from lawsuits, structured annuity payments, an inheritance, earnings from employment (direct deposit into the Trust is not permissible), and excess Social Security are a few examples of the type of assets placed into the Trust. Please have checks made payable to Springhill Pooled Accounts Trust, add the beneficiary’s name in the memo line, and mail to our office.

13. What are some other rules that I need to know?

Currently, Michigan’s rules for Medicaid Assistance limit the countable assets for a single person to $2,000.00 or less. That means even if someone has more than one account, such as a checking and a savings account, the total funds cannot exceed $2,000.00. Various Social Security and Department of Human Services programs also have income limits. Subsidized housing and Housing Choice Voucher rates are based on income and assets.

Some programs, such as SSI, have negative consequences if cash is given to the beneficiary by the Trust. The first $20.00 has no effect on SSI income. However, any amount over $20.00 is a dollar for dollar reduction of SSI income. The SSI program generally views the purchase of gift cards as cash. If an individual is receiving benefits with income restrictions, the Springhill Pooled Accounts Trust disbursement procedures are designed to prevent a disbursement from being considered income if at all possible.

Generally, the Trust must also be administered for the sole benefit of the beneficiary. Disbursements that benefit other people, even friends and family, are not permitted. If you would like to file a grievance, please follow the instructions here.

Fees

14. What does it cost to join? Are there other fees?

Initial set up of a Springhill Pooled Accounts Trust sub-account currently costs nothing until the trust is funded. We understand that Supplemental Needs Trusts may remain empty, or not funded for years and may not be funded until an inheritance is paid, a gift is given, or a personal injury award is received by the beneficiary. At the time the trust is funded, a one-time joinder fee (currently $500) will be assessed to the account, and paid to Springhill Housing Corporation. After that, the following fees currently apply:

Trust Administration and Trustee: There is a 1.75% annual Trust Administration and Trustee fee.  The fee is calculated based on assets under management and billed monthly. This fee covers services such as disbursement review, general correspondence, additional deposits, account and file updates, etc., and is automatically paid to Springhill Housing Corporation.

Investment Management Fee: There is a 0.75% annual investment management fee. The fee is calculated based on assets under management and billed quarterly. The investment management services are provided by True Link Financial Advisors, LLC.

Sub-Account Close Out: Beneficiaries whose accounts are $500 or less will be contacted to see if any additional funding is expected. If there will not be any additional funding, we will request that a disbursement request is submitted within 90 days. After 90 days, the sub-account will close, and remaining funds will revert to Springhill Housing Corporation’s Retained Funds account to help further our mission.

 Additional Fees

• Property Management services for sub-account owned homes

• Check delivery requests: overnight, two-day or wiring funds

• Professional services charged at market rate including but not limited to attorney consultation, trust tax return or personal tax returns.

Investment Information

15. How are Trust assets managed?

Springhill Housing Corporation, as Trustee, has contracted with True Link Financial Advisors, LLC to manage the investment assets of the Springhill Pooled Accounts. True Link Financial Advisors, LLC does not manage these pooled assets for any individual beneficiary, but rather manages the investments for the pooled trust overall.

• True Link Financial Advisor, LLC’s investment management helps Springhill Housing Corporation fulfill its fiduciary requirements related to the allocation of Special Needs Trust assets.

 

• True Link seeks to offer diversified investment portfolios aligned with the principles of the Uniform Prudent Investor Act (UPIA). The portfolios are built with the goal of capturing market returns while carefully managing risk and minimizing the impact that fees, taxes, and excess cash can have on returns. Invested assets are custodied with Charles Schwab and invested using low-cost, highly liquid investment options, typically Exchange Traded Funds (ETF) from leading providers.

Benefits of this partnership to beneficiaries

True Link Financial Advisors, LLC, is an SEC-registered investment advisory firm and wholly owned subsidiary of True Link Financial, Inc.,[2] dedicated to providing its financial expertise to serving trusts that support thousands of trust beneficiaries. True Link Financial, Inc.’s trust administration software and record-keeping platform is specifically built for trusts and their beneficiaries to help efficiently and reliably administer trust assets. True Link Financial Advisors, LLC’s investment management services combined with True Link Financial, Inc.’s trust administration software and the True Link Visa prepaid Card work together as a unified system to provide greater flexibility and more advanced tools so that we can better serve our trust beneficiaries. Notably, the True Link Visa Card is the only Visa prepaid card referenced in the Social Security Administration guidelines in the POMS with settings that can help protect government benefits.

Beneficiary and Representatives Online Portal

• • • Beneficiaries and their representatives will have access to sub-account balances, deposits and disbursement activity.
    • Beneficiaries and their representatives will be able to view and download Beneficiary sub-account statements.

Financial statements are mailed to beneficiaries and/or their guardians on a quarterly basis.

* Low minimum balance policy is addressed in our Notice of Fees.

[1] Investing involves risk, and you may incur a profit or loss regardless of the strategy selected, including loss of principal.

[2] Required Disclosure: Registration with the SEC authorities as a Registered Investment Adviser does not imply a certain level of skill or training nor does it constitute an endorsement of the advisory firm by the SEC