Compliance Guide and Toolkit

In light of the latest Social Security Administration release, we're updating our Compliance Guide! 

SSA released a clear statement on how special needs trustees can use True Link Cards. You can see the full new text of SI 01120.201 I.1.e here:

"Administrator-managed prepaid cards, such as True Link cards, are a type of restricted debit card that can be customized to block the cardholder’s access to cash, specific merchants, or entire categories of spending… If the trustee is the owner of the prepaid card account… [t]he administrator-managed prepaid card is not the  trust beneficiary’s resource."

Great news: if you’ve been using True Link Cards to make disbursements from a special needs trust, the Social Security Administration has specifically clarified that True Link Cards are consistent with the POMS; and, if you’ve been waiting for this moment to set up a True Link Card, the moment has arrived.

Here’s what you need to know:
1. The trust, not the beneficiary, must be the account owner and administrator. No major surprises there. We will be reaching out to all of our current SNT customers to provide clear documentation of this.
2. If the card is used to take out cash, that is considered cash income. If the card is used to buy food or shelter, it would be ISM. This means receipts need to be collected for any purchases at places that sell food or shelter items, like Walmart, Target, or a drugstore.

Check back in the near future to view our updated compliance guide. In the meantime, don't hesitate to reach out with any questions!

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