Special Needs 101

Provided by 
Michael W. McGreaham
Attorney at Law
101 S. Capitol Blvd.
10th Floor
PO Box 829
Boise, Idaho 83701-0829
Tel (208) 345-2000
Fax (208) 385-5384

Committed to providing the highest quality estate planning legal services for individuals, families and businesses.

     Do you have a special family member, or know someone who does? If so, you will want to bookmark this article for future reference and share it with others.
     That said, this article is not a substitute for competent legal counsel regarding this very complex subject matter. Rather, it is intended to stimulate informed thought, open discussion and appropriate action while there still may be time to make appropriate legal plans.

Financial Challenges
     Not only do parents of special needs children face unique challenges in providing for the daily special needs of such children while both parents are alive, they face unique challenges in providing for them after both parents are deceased. This is true whether the children are minors (e.g. under age 18 in most states) or adults.
     The financial costs of caring for a special needs family member can be over-whelming. Many of these costs are incurred for needs over and above room and board. Specialized equipment and skilled professional assistance may be required for many of life’s otherwise routine tasks. Ongoing and expensive medical care is common, often without private health insurance to cover the bills. While assistance is available from state and federal governments, such assistance is subject to strict financial eligibility requirements.

Planning Challenges
     Given the unique challenges faced by families with a special needs family member, the Life & Estate Plans of the parents (and grandparents) must be carefully tailored and monitored to meet objectives beyond probate avoidance and federal estate tax minimization. Although the challenges differ in each case, there is one fundamental planning objective common to all: How can parents (and grandparents) help assure adequate care throughout the lifetime of their special needs family member…without disqualifying them from government assistance?

Do No Harm
     In medicine, the first rule is to do no harm. So it is with planning for the needs of a special family member. Parents and grandparents should be discouraged from establishing custodial accounts for a special needs minor child. Why? Once such a minor child reaches the age of majority under state law, the custodial account is distributed to the now special needs adult child (or to their lawfully appointed guardian/conservator on their behalf). This distribution itself may disqualify them from government assistance subject to certain financial resource limits. Similarly, if parents (and grandparents) leave assets directly to or for the benefit of the special needs family member, whether outright or in a plain-vanilla trust, then the same disqualification may result. When assets of the special needs adult exceed the governmental financial resource limits, then they may be disqualified from both Supplemental Security Income (SSI) and Medicaid until the disqualifying funds are spent-down.

Supplement, But Don’t Supplant
     Even if a special needs adult qualifies for SSI and Medicaid, the benefits provided are limited. Because most of the meager monthly SSI benefit* is used for food, clothing and shelter, little if any financial resources are left for life’s extras. For example, Medicaid covers medical care and prescription drugs, but not dental work. The key, then, is to financially supplement for life’s extras without financially supplanting government assistance. 
     But how can this be done when an inheritance is left without special planning for a special needs family member?

Payback Trusts
     As part of the Omnibus Budget Reconciliation Act (OBRA) of 1993, a trust containing certain statutorily required provisions may be established to administer and distribute trust assets for a special needs beneficiary without otherwise disqualifying them from government benefits.
     These special provisions require the trust to payback the government post-mortem for government benefits provided to the special needs beneficiary of the trust. If trust assets are depleted or are otherwise insufficient to fully payback the government, then no further reimbursement is required from the family. However, if trust assets remain after the payback, then the remaining assets may be distributed to further beneficiaries designated under the trust.

 * The Federal Benefit Rate (FBR) for 2003 is $552. It changes annually and some states provide a financial supplement to the FBR.

Insuring Long-Term Security

     In this article we will review two alternative planning techniques to the Payback Trust discussed in the main article (above), along with an effective method to help finance long-term security.

Special Needs Trusts
     A Special Needs Trust provides distributions only for life’s extras that do not disqualify the special needs beneficiary. Distributions are made at the discretion of a disinterested Trustee. Authorized distributions may include dental expenses, special schooling, travel expenses, or even a television. Upon the death of the special needs beneficiary, the remaining trust assets may be administered on behalf of other non-special needs family members.
     In some Special Needs Trusts, a poison pill provision may be included. Such a provision may instruct the Trustee to distribute the trust assets to non-special needs family members if the trust is or may be deemed to disqualify the special needs beneficiary from government assistance. Should this poison pill provision become triggered in the future, the other beneficiaries would be under a moral, not a legal obligation to provide the trust assets for their special needs family member.

Blended Discretionary Trusts
     A Blended Discretionary Trust is often used for general asset protection purposes to protect an inheritance from the potential divorces, lawsuits and bankruptcies of its beneficiaries. This trust has multiple beneficiaries, each with no specific right to any distribution of income or principal from the trust assets.
     To be most effective, any distributions must be in the sole and absolute discretion of the disinterested Trustee, without regard to any ascertainable standards such as health, education, maintenance or support.
     Nevertheless, the Trustmaker(s) may prepare a non-binding letter of intent to provide guidance to the Trustee. A Blended Discretionary Trust is often used to include even grandchildren as eligible beneficiaries and avoid inclusion in the estates of the children for federal estate tax purposes by careful application of each parent’s generation-skipping transfer tax exemption.

Leveraged Funding
     Payback Trusts, Special Needs Trusts and Blended Discretionary Trusts all require one common denominator to effectively finance the long-term security of a special needs family member: money.
     One of the most powerful financial tools to accomplish this funding requirement is life insurance. Simply put: life insurance provides a sum certain in cash at an uncertain time in the future with dollars purchased in advance at a discount. In addition to individual life policies, a married couple may be insured together under a joint life policy that only pays its death benefit after the death of the surviving spouse. As a result, a joint life policy typically provides a greater return on investment than would two individual life policies insuring the same insureds for the same total death benefit. In addition, through careful legal planning, the death benefits of life insurance policies and their eventual proceeds may be excluded from the estates of the insured parents (or grandparents).

Conclusion
     Eligibility regulations for government assistance are complex and vary in their application by jurisdiction. Accordingly, always seek competent legal counsel before committing your resources.

 

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