About Commonwealth Community Trust (CCT)

Commonwealth Community Trust (CCT) is a 501(c)(3) nonprofit organization operating nationally that administers affordable and efficient pooled special needs trusts for people with special needs.

CCT was founded in 1990 by parents who have a child with special needs along with concerned professionals.  CCT is managed by a Board of Directors who serves with a caring heart and without compensation.  Our volunteer Board of Directors is comprised of at least two members who are related to an individual with special needs, legal and financial professionals, and experts who work in the special needs field.

CCT staff members are knowledgeable about rules governing trusts for clients receiving Supplemental Security Income (SSI) and Medicaid in order to preserve these benefits.  At the end of 2016, CCT celebrated an important milestone of having served over 1,330 participants since inception.  CCT’s growth over the past nine years is shown in the above graph.

CCT administers the following types of pooled special needs trusts:

  • Third-Party Pooled Special Needs Trust funded typically by a family member or friend, and can be coordinated with an estate plan or life insurance policy.
  • First-Party Pooled Special Needs Trust – funded by the beneficiary who has special needs and has received funds as a result of a personal injury award, inheritance, savings or Social Security back payment. CCT’s First-Party Pooled Special Needs Trust was set up in 1994 in response to the sweeping changes in the Medicaid rules under the Omnibus Budget Reconciliation Act of 1993 (OBRA – 93). This type of trust can be established by the person with special needs, a parent, grandparent, legal Guardian, or the Court. For Beneficiary’s receiving Medicaid, this type of trust is sometimes referred to as a Medicaid payback trust.
  • First-Party Pooled Special Needs Trust with a Medicare Set-Aside Account – In some cases, a person receives Medicare benefits and is also eligible for means-tested benefits such as Supplemental Security Income or Medicaid. In these cases, the individual should consider, with the advice of counsel at the time of settlement, nesting the Medicare Set-Aside (MSA) Account within a special needs trust to avoid losing eligibility for these public benefits.
  • Military Survivor Benefit Plan Pooled Special Needs Trust – funded directly by payments of a military or military retiree’s dependent child’s Survivor Benefit Plan annuity.




The Trust Company of Virginia (TCVA), a financial institution with trust powers, located in Virginia, was selected by the CCT Board of Directors to manage and invest the funds.

Our Master Trust Agreements

Commonwealth Community Trust’s Master Trust Agreements allow CCT to administer the trusts under the umbrella of the “master.”  The Master Trust Agreements for both the Third-Party Pooled Special Needs Trust and First-Party Pooled Special Needs Trust were written by an Estate Planning Attorney with legal expertise in special need planning and signed by the CCT Board of Directors and TCVA.

The Third-Party Pooled Special Needs Trust can be established for Beneficiaries of any age. The First-Party Pooled Special Needs Trust can be established for anyone under age 65.  Requirements differ for clients 65 and older who receive Medicaid long-term care, as the Medicaid rules differ for each state.  Please contact CCT for more information.

Who can establish a special needs trust?

CCT serves clients who have a disability based on the Social Security Administration’s (SSA) definition of disability.

  • For a child under the age of 18, the SSA defines having a disability as follows:
    1. The child must have a physical or mental condition(s) that very seriously limits his or her activities; and
    2. The condition(s) must have lasted, or be expected to last, at least 1 year or result in death.
      For more information, please visit the Social Security website.
  • For an adult 18 and older, “disability” under Social Security is based on an inability to work.  To be considered disabled under SSA rules, the following criteria must be met:
    1. The adult cannot do work that was done before;
    2. Social Security decides that the individual cannot adjust to other work because of his or her medical condition(s); and
    3. The disability has lasted or is expected to last for at least one year or to result in death.
      For more information, please visit the Social Security website.

In what states are trusts from Commonwealth Community Trust available?

CCT is a nonprofit organization operating nationally.

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