Keeping an accurate record of which items, goods, or services were paid on behalf of a beneficiary is one of many responsibilities a trustee has when administering a Special Needs Trust. In the event of an audit from the Social Security Administration (SSA), the trustee (CPT), would have to adequately provide necessary documents to ensure that the reimbursement was in fact for the sole benefit of the beneficiary and was for the specific item, good, or service that is to be reimbursed.
For example: A beneficiary submits a disbursement request form (DRF) in the amount of $100 to be reimbursed to a friend who paid for the beneficiary’s salon services. However, the beneficiary cannot seem to find or has misplaced the receipt. The Trustee (CPT) cannot and should not reimburse the friend in the amount of $100 due to the missing receipt/invoice. If the Social Security Administration (SSA) audits the beneficiary’s account and requests the specifics for the reimbursement of salon services, and the trustee is not able to provide such specifics; the Social Security Administration (SSA) may take the position in penalizing the beneficiary’s eligibility for benefits.
Another example: A parent of a beneficiary submits a disbursement request form (DRF) in the amount of $300 for the purchase of a mobile phone. The parent is able to provide the necessary receipt/invoice for the transaction. In this example, given the proper receipt/invoice for the purchase of the mobile phone, a reimbursement to the parent is appropriate and acceptable. If the Social Security Administration were to audit the beneficiary’s Special Needs Trust, there would not be any identifying risks of the beneficiary losing or jeopardizing his/her benefits due to the documentation recorded on file for the specific purchase.
CPT as Trustee, requires that beneficiaries and advocates submit proper documentation, statements, receipts, and invoices not to make the process more complicated, but to adequately keep records in case of an audit from the Social Security Administration (SSA). In addition, CPT as Trustee, requires specific documentation to adhere to the Social Security Administration Program Operations Manual System (POMS).
William E. Lindahl, MBA, CLPF