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HomeMy WebLinkAbout12-17-10 IN THE COURT OF CONrSON PLEAS OF CUI~ERLAND COUNTY, Pffi~iNSYLVANIA ORPHANS' COURT DIVISION IN RE: TRUST FOR NORMA O. FRAME Attorney for Petitioner: Bruce C. Bankenstein 48 South Duke Street York, PA 17401 (717) 843-0961 Fax (717) 843-0699 N ~~ ~ /0 `~7 J o. Previous Judge: ne o rn ~ n ~,; :' _ ~ ~ G' ` J 3 , --~ r ~=~ . PETITION FOR CREATION OF A TRUST NOW comes Your Petitioner, by her attorney, Bruce C. Bankenstein, and presents this Petition whereof the following is a statement: 1. Norma 0. Frame is a single, adult individual residing at 91 Courtyard Drive, Carlisle, Cumberland County, Pennsylvania. 2. Petitioner is physically disabled and is the proposed beneficiary of the trust requested to be established pursuant to this Petition. 3. Petitioner suffers from Central Nervous System vasculitis with partial blindness for which she has been determined to be disabled 1 by the Social Security Administration and is receiving social security disability benefits. 4. No guardian has been appointed for Petitioner. 5. Petitioner has no available parent nor living grandparent. 6. Petitioner has settled legal action that she had pursued with net proceeds therefrom being anticipated to be approximately $50,000.00. 7. Owning the aforesaid assets will render Petitioner ineligible for prospective benefits, including, but not limited to, medical assistance, waiver funding and social security supplemental security income, if such assets are not consumed or protected. 8. Petitioner proposes to protect the aforesaid assets by placing them in the proposed Norma Frame Special Needs Trust which is attached as the Addendum hereto and made a part hereof. 9. All persons who are proposed to be the Trustee and the various successor Trustees of this trust have consented to serve in that capacity as set forth in the Consents signed by them and attached hereto as Exhibits "A", "B" and "C". 2 10. The purposes of the proposed trust are set forth therein, and generally are to set aside a fund which may be used for purposes which are generally not for the primary support of the Petitioner but will supplement any governmental benefits to which Petitioner may otherwise be entitled. 11. Federal law permits a disabled person under the age of 65 to deposit her own money into a trust which is not intended to be used for her primary support, and such a trust will not be considered to be a resource of such person so as not to adversely affect such person's eligibility for any governmental benefit to which she may otherwise be entitled so long as such trust (a) is established by a parent, grandparent, legal guardian or court, and (b) provides that all amounts remaining in the trust upon the death of its beneficiary will be distributed to the state up to the amount of all medical assistance paid by the state on behalf of the beneficiary. 42 U.S.C. ~1396p(d)(4)(A). A copy of the entire subsection (d) is attached hereto as Exhibit "D" 12. The proposed Norma Frame Special Needs Trust constitutes a special needs trust under 62 P.S. X1414. 13. The corpus of the proposed trust will be generated from the 3 aforesaid net settlement proceeds. 14. Placing these funds in the proposed trust meets the federal law in that the trust is a non-support trust and Paragraph 10 thereof requires the trust remainder to be distributed to the state up to the amount of all medical assistance paid by the state on behalf of Petitioner, thereby protecting these funds from being considered to be a resource of Petitioner in determining her eligibility for various governmental benefits. 15. The Pennsylvania Department of Public Welfare has determined that it has no objection to the proposed Norma Frame Special Needs Trust as a special needs trust as stated in the letter of Lisa B. Dees, Assistant Counsel, Governor's Office of General Counsel for the Department of Public Welfare, dated December 15, 2010, a copy of which is attached hereto as Exhibit "E". 16. Petitioner does not receive supplemental security income benefits from the Social Security Administration so that no review of the proposed Norma Frame Special Needs Trust may be obtained at this time from the Social Security Administration. 17. The provisions of Paragraph 12 of the proposed Norma Frame Special Needs Trust will be accomplished by paying from the 4 aforesaid net settlement proceeds the sum of $69,152.99 to the Department of Public Welfare in satisfaction of its claim for assistance as agreed by the Department in its letter of September 9, 2010, issued to Petitioner's trial counsel for the aforesaid legal action which agreement was pursued in the administration of the settlement thereof. A copy of said letter of September 9, 2010, is attached hereto as Exhibit "F". Petitioner respectfully requests Your Honorable Court to enter an Order establishing the trust attached as the Addendum hereto, and confirming the payment to the Department of Public Welfare in satisfaction of its claims. Respectfully submitted, MANIFOLD & BANKENSTEIN By. uce C. Bankenstein Attorney for Petitioner Supreme Court I.D. #27025 48 South Duke Street York, PA 17401 (717) 843-0961 Fax (717) 843-0699 5 The undersigned hereby verifies that the statements made in the foregoing Petition are true and correct to the best of the personal knowledge or information and belief of the undersigned. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification. Date : ~(Y..w • !~, o?Ol0 ~• Norma ame ADDENDUM TO PETITION IN THS COURT OF CONNON PLEAS OF CUNBSRLAND COUNTY, PENNSYLVANIA IN RE: No. TRUST FOR NORMA 0. FRAME NORMA FRANK SPECIAL NSSDS TRUST THIS TRUST is established by Order of this Court entered in the above-captioned proceeding on , 20_, which shall be subject to the following terms and conditions, to wit: 1. The Trustee of this Trust is Andrew 0. Mitchell of 91 Courtyard Drive, Carlisle, Pennsylvania 17013. The Successor Trustee of this Trust is Beatrice Renee Hebert of 11251 Eva Drive, Gulfport, Mississippi 39503. The Second Successor Trustee is J. Edward Dagen of 1205 Fleetwood Drive, Carlisle, Pennsylvania 17013. The term "Trustee" as used herein shall refer to the then serving trustee of this Trust, whether it be the aforenamed Trustee, or the Successor Trustee, or the Second Successor Trustee, or any other person serving as such trustee. 2. The beneficiary of this Norma Frame Special Needs Trust is Norma 0. Frame who currently resides at 91 Courtyard Drive, Carlisle, Cumberland County, Pennsylvania, and shall hereinafter be referred to as "Beneficiary". Beneficiary, whose 1 birth date is February 2, 1955, is disabled as defined in Title XVI of the Social Security Act, 42 U.S.C. ~1382c(a)(3). Beneficiary is currently receiving disability benefits from the Social Security Administration. 3. This Trust shall be known as the Norma Frame Special Needs Trust. This Trust is established pursuant to 42 U.S.C. §1396p(d)(4)(a) and 62 P.S. §1414. As a result, all assets held in or owned by this Trust are exempt from being included in the determination of Beneficiary's eligibility for or the amount of medical assistance under a state plan for the same or other governmental benefits, and such assets shall in no way be deemed to have been or to be available to Beneficiary. 4. The initial corpus of this Trust is anticipated to be approximately $50,000.00. The same will be derived from a portion of net settlement proceeds recovered by Beneficiary from legal action she had pursued. 5. For the duration of the life of Beneficiary, the Trustee may pay or apply for the sole benefit of Beneficiary such amounts from the net income and principal of this Trust as the Trustee in the exercise of the Trustee's absolute, complete and unfettered discretion deems advisable for the welfare of Beneficiary as hereinafter set forth. In making such distributions to or for the benefit of Beneficiary, and as the Trust principal and income are not to be used in place of any statutory benefits, 2 the Trustee shall take into consideration all other resources available to Beneficiary, including any benefits to which Beneficiary is, or may be, entitled through public assistance, medical assistance, or from any other governmental or other resources. The Trustee may hold, withhold and retain any or all of the income and principal of this Trust as the Trustee, in the exercise of the Trustee's absolute discretion, shall deem advisable for the uses and purposes herein set forth. All distributions from the Trust. must be for the sole benefit of Beneficiary. 6. In exercising the discretionary powers herein conferred on the Trustee, the Trustee shall be guided by the following statement of Settlor's purposes and intentions. It is Settlor's expectation that the Trust income and principal will not be made available to provide primary support for Beneficiary. Therefore, the Trustee is directed to investigate other sources of support available to Beneficiary and to take whatever steps necessary to enroll Beneficiary for such benefits or assistance. The Trust principal and income may be used only as a supplement to, and shall not replace, any statutory or other governmental benefits to or for which Beneficiary is, may be or may become eligible, including, but not limited to, medical assistance, public assistance, supplemental security income, or the like. The Trustee may make Trust distributions to or on Beneficiary's behalf in such a way that Beneficiary's life will be enriched and made more 3 enjoyable, including providing recreational and vacation opportunities for Beneficiary. The Trustee is authorized to make Trust distributions to or on Beneficiary's behalf to increase Beneficiary's quality of life and standard of living, to assist in the treatment of the Beneficiary's disability, and to pay or provide for Beneficiary's special needs. Special needs shall include, but not be limited to, medical expenses, dental expenses, nursing and custodial care, psychiatric or psychological services or both, clothing, recreational therapy, occupational therapy, physical therapy, vocational therapy, durable medical needs, prosthetic devices, special rehabilitative services or equipment, disability related training, education, transportation and required travel expenses (including vehicle purchase), dietary needs and supplements, related insurance, and other goods and services that may be specified as special needs by the Pennsylvania Department of Public Welfare. The Trustee may also use the income and principal of this Trust to purchase or fund an irrevocable funeral account or fund to be restricted to pay the funeral or burial expenses, or both, of Beneficiary, if no other provision has been made for the same. It is Settlor's desire that Beneficiary be able to maintain contact with any siblings and other family members, and the Trustee may expend Trust income and principal for transportation costs for Beneficiary or other family members to facilitate such contact. The Trustee is authorized to expend the Trust estate to procure 4 more sophisticated medical, dental, ophthalmological and other similar treatment than may otherwise be available to Beneficiary and to seek private rehabilitative and educational training; however, the Trust principal and income may not be used in any manner to provide for basic medical care and is not to be used to replace medical assistance or similar statutory or other governmental benefits to or for which Beneficiary is or may become eligible. Subject to the intentions herein stated, the Trustee is authorized to expend such amounts of income and principal of the Trust for goods and services for the support of Beneficiary if and only if the statutory or other governmental benefits to or for which Beneficiary is, may be or may become eligible prove to be inadequate for Beneficiary's basic support or are discontinued or do not otherwise cover or provide for such goods or services for Beneficiary; however, any such expenditure shall be at the absolute, complete and unfettered discretion of the Trustee, and the Trustee shall have no duty to make any such expenditure. The Trustee is authorized to expend such amounts of income and principal as shall enable Beneficiary to achieve Beneficiary's maximum potential and to lead as comfortable a life as possible. To that end, it is Settlor's desire, without it being legally binding, that the Trustee may expend the income and principal of this Trust in ways that shall protect, enforce and expand the rights of Beneficiary, and to provide advocacy for Beneficiary. 5 Furthermore, any expenditure from the Trust must have a reasonable relationship to the needs or circumstances of Beneficiary. Settlor desires the Trustee to exercise the discretionary power conferred on the Trustee hereunder in a manner which will provide flexibility in the administration of the Trust under conditions from time to time existing, and in exercising such powers, the discretion of the Trustee shall be conclusive as to the advisability of any distribution of income or principal, and as to the person to or for whom such distribution is to be made, and the same shall not be subject to judicial review. Therefore, the Trustee may not and shall not be compelled in any manner by any person, court or governmental agency to expend any of the Trust income or principal for the replacement or reimbursement of any statutory or other governmental benefits, or any support or other assistance, to or for which Beneficiary is, may be or may become eligible, nor may the Trustee be compelled to exercise the Trustee's discretionary powers in favor of Beneficiary as a beneficiary of such statutory or other governmental benefits, or any support or other assistance. Furthermore, the Trustee is authorized to expend such amounts of income and principal for the benefit of the Beneficiary as shall best provide for the comfort and happiness of Beneficiary without regard to the effect that such distributions might have upon the interest of the takers of the remainder of this Trust. 7. In addition to the foregoing, the Trustee is further 6 hereby authorized to make distributions from the principal and income of this Trust, in Trustee's absolute and unfettered discretion, for the following purposes: A. To purchase, repair, upgrade or specially outfit a motor vehicle for the use and benefit by and for Beneficiary. B. To pay any condominium fees, condominium owner association fees, homeowner association fees, or the like which may be imposed upon or with regard to the residence of and owned by Beneficiary. C. To pay or provide for any reasonable and necessary repairs to or maintenance, whether routine, structural or extraordinary, of the residence of and owned by Beneficiary. D. To pay premiums on any life insurance policy covering Beneficiary's life. E. To pay premiums for health insurance covering Beneficiary. 8. Furthermore, in addition to the foregoing and subject to the intentions herein stated, the Trustee is authorized to expend such amounts of income and principal of this Trust, as, in the Trustee's absolute and unfettered discretion, are appropriate or necessary for the Beneficiary's health, safety, welfare, education and treatment, which may include goods and services for the support of Beneficiary, if and only if the same 7 are not provided by a public agency or government program, or the statutory or other governmental benefits to or for which Beneficiary is or may then be eligible for which the same would otherwise be provided are discontinued in general or for Beneficiary. 9. Before the Trustee may distribute any of the principal of this Trust in excess of Ten Thousand ($10,000.00) Dollars for any of the uses or purposes set forth above, Trustee shall give written notice of such intention to the following agencies if such agency provides the stated benefit: the Pennsylvania Department of Public Welfare, or any successor thereof which administers medical assistance, and to the Social Security Administration, or any successor thereof which administers supplemental security income. If no objection to such distribution is received from either of those agencies within twenty (20) days following the date of the said notice, the Trustee may make said distribution. 10. This Trust shall terminate upon the death of Beneficiary. Upon such termination, the Trustee shall distribute pro-rata all remaining principal and accrued income to any state which had provided medicaid, also known as medical assistance, to or on behalf of Beneficiary under any such state's plan under Title 42 of the United States Code or any similar federal law up to the total of all such medicaid paid to or on behalf of Beneficiary. If any funds remain in this Trust after such distribution to a state 8 or states, such remainder shall be distributed as follows: A. One-half (~) thereof, in trust, unto the Trustee of the Stephen 0. Frame Special Trust which Beneficiary established by original Trust Agreement dated December 23, 1996, and amended and reconfirmed by Second Restated Trust Agreement dated July 15, 2009, for the benefit of Beneficiary's son, Stephen 0. Frame as set forth in said Restated Trust Agreement, as part of that Trust for the uses and purposes and under the terms and conditions as therein set forth, so long as such Trust is in existence at the time of such distribution. In the event the Steven 0. Frame Special Trust is not in existence at the time of said distribution, then this one-half (~) share of any remainder of this Norma Frame Special Needs Trust shall be distributed unto Beneficiary's son, Andrew 0. Mitchell, if he is living at the time of such distribution, and if he is not then living, then unto his issue who are living at the time of such distribution, per stirpes. B. One-half (~) thereof unto Beneficiary's son, Andrew 0. Mitchell, if he is living at the time of such distribution, and if he is not then living, then unto his issue who are living at the time of such distribution, per stirpes. If Andrew 0. Mitchell is not living at the time of such distribution and leaves no issue who are then living, then this one-half (~) share of the remainder of this Norma Frame Special Needs Trust shall be distributed, in trust, unto the Trustee of the aforesaid 9 Stephen 0. Frame Special Trust as part of that Trust for the uses and purposes and under the terms and conditions as therein set forth. 11. In the event of the change of any state or federal law or regulation or in the event of the occurrence of any event which is beyond the control of Trustee, and if either such event temporarily or permanently disqualifies Beneficiary from receiving or being eligible for public assistance, medical assistance, supplemental security income, waiver programs, or any other statutory or other governmental benefits for which Beneficiary is, may be or may become eligible, then Trustee, in Trustee's absolute, sole and unfettered discretion, may, and Trustee is hereby specifically granted the power to, amend this Trust Agreement to the least extent necessary to maintain or restore Beneficiary's eligibility for any of the aforesaid statutory or other governmental benefits and to maintain the purposes, intentions-and use of this Trust as hereinbefore set forth. 12. Before any assets of Beneficiary may be transferred to this Trust, all liens and claims in favor of the Pennsylvania Department of Public Welfare for repayment of cash and medical assistance shall first be satisfied therefrom. A copy of this Trust Agreement shall be directed to: The Special Needs Trust Depository Attention: Manager, TPL Section P.O. Box 8486 Harrisburg, Pennsylvania 17105-8486 10 13. A. The initial Trustee of this Trust shall be Andrew 0. Mitchell. Upon the death of Andrew O. Mitchell, or if he resigns or no longer qualifies to serve as Trustee of this Trust for any reason, then Beatrice Renee Hebert, Successor Trustee, shall thereupon administer this Trust as Trustee and shall have the duties and powers of Trustee as herein set forth. In the event both of the aforenamed Trustee and Successor Trustee hereunder die, resign or do not qualify or no longer qualify to serve as Trustee of this Trust for any reason, then J. Edward Dagen, Second Successor Trustee, shall thereupon administer this Trust as Trustee and shall have the duties and powers of Trustee as herein set forth. 8. The last serving Trustee of this Trust may appoint in writing a natural person or a corporate fiduciary with trust facilities to succeed such last serving Trustee as the Trustee of the Trust. 14. This Trust shall not be subject to anticipation or to voluntary or involuntary alienation. 15. Trustee shall invest the principal of this Trust in compliance with the Prudent Investor Rule as currently set forth in the Pennsylvania Probate, Estates and Fiduciaries Code, or any subsequent amendment or restatement thereof in force at the time of such investment. Furthermore, Trustee shall have the following 11 powers in addition to those vested in it by law and by other provisions of trust, applicable to all property, whether principal or income, exercisable without court approval, and effective until actual distribution of all property: A. To hold and retain any or all of the assets of this Trust, real or personal, without regard to any principal of diversification or risk. B. To sell at public or private sale, to exchange, or to lease for any period of time, any real or personal property, and to give options for sales, exchanges or leases, for such prices and upon such terms or conditions as Trustee deems proper. C. To allocate receipts and expenses to principal or income or partly to each as Trustee from time to time thinks proper in Trustee's sole discretion. D. To compromise any claim or controversy. 16. This Trust is and shall be irrevocable, except that the same may be modified by further order of Court. 17. Subject to the approval of Trustee, anyone may add property, real or personal, to the principal of this Trust by Deed, Will or otherwise. In the event the same should be or include life insurance proceeds payable to this Trust or the applicable Trustee of this Trust under the terms of any life insurance policy, said proceeds shall be paid, in trust, to the then serving Trustee hereof by the applicable life insurance company without liability 12 or further responsibility on the part of such life insurance company. Notwithstanding the foregoing, additions to this Trust of any kind or nature shall not be accepted by Trustee after beneficiary attains the age of sixty-five (65) years. 18. The Trustee shall be entitled to receive compensation for service hereunder, which compensation shall be charged against or payable from both principal and income of this Trust, at such rates as may be reasonable and customary. If the Trustee is a corporate fiduciary, then such Trustee's compensation shall be at such rates as may be provided in such Trustee's published fee schedule in effect at the time said services are performed. 19. The situs of this Trust for administrative and accounting purposes shall be in the County of Cumberland and Commonwealth of Pennsylvania, and all questions pertaining to the construction or validity of the provisions of this instrument shall be governed by the laws of that Commonwealth. 13 CONSENT TO SERVE A3 A TRUSTEE I, Andrew O. Mitchell, hereby consent to serve as the initial Trustee of the Norma Frame Special Needs Trust which is being requested to be established by the Court of Common Pleas of Cumberland County, Pennsylvania. Andr Q . (Address) /~ ~ ,~~,~ ~~-. ~~,[L sr ~ P~ / Tor 3 EXHIBIT "A" CONSENT TO SBRVB AS A TRt1ST8$ I, Beatrice Renee Hebert, hereby consent to serve as the Successor Trustee of the Norma Frame Special Needs Trust which is being requested to be established by the Court of Common Pleas of Cumberland County, Pennsylvania. Beatrice Renee Heber^t (Address) ~ ~ ~ S 1 /-~ {J~ ~!'' ~'~~- l~pot-~ , ry~.S- 39.503 EXHIBIT "8" CONSEIQT TO 3ERV8 AS A TRUSTEY~ I, J. Edward Dagen, hereby consent to serve as the Second Successor Trustee of the Norma Frame Special Needs Trust which is being requested to be established by the Court of Common Pleas of Cumberland County, Pennsylvania. ~~ J. E and Dagen (Address) ~ °~ ds ~~W~ `vr~'x EXHIBIT "C" EXHIBIT ~D" United States Code Annotated Title 42. The Public Health and Welfare Chapter 7. Social Security (Refs & Annos) Subchapter XIX. Grants to States for Medical Assistance Programs 4z U.S.C.A. § i396P § i396p. Liens, adjustments and recoveries, and transfers of assets (a) Imposition of lien against property of an individual on account of medical assistance rendered to him under a State plan (text deleted) (b) Adjustment or recovery of medical assistance correctly paid under a State plan (text deleted) (c) Taking into account certain transfers of assets (text deleted) (d) Treatment of trust amounts (1) For purposes of determining an individual's eligibility for, or amount of, benefits under a State plan under this subchapter, subject to paragraph (4), the rules specified in paragraph (3) shall apply to a trust established by such individual. (2)(A) For purposes of this subsection, an individual shall be considered to have established a trust if assets of the individual were used to form all or part of the corpus of the trust and if any of the following individuals established such trust other than by will: (i) The individual. (ii) The individual's spouse. (iii) A person, including a court or administrative body, with legal authority to act in place of or on behalf of the individual or the individual's spouse. 1 8XHI8IT "D" (iv) A person, including any court or administrative body, acting at the direction or upon the request of the individual or the individual's spouse. (B) In the case of a trust the corpus of which includes assets of an individual (as determined under subparagraph (A)) and assets of any other person or persons, the provisions of this subsection shall apply to the portion of the trust attributable to the assets of the individual. (C) Subject to paragraph (4), this subsection shall apply without regard to-- (i) the purposes for which a trust is established, (ii) whether the trustees have or exercise any discretion under the trust, (iii) any restrictions on when or whether distributions may be made from the trust, or (iv) any restrictions on the use of distributions from the trust. (3)(A) In the case of a revocable trust-- (i) the corpus of the trust shall be considered resources available to the individual, (ii) payments from the trust to or for the benefit of the individual shall be considered income of the individual, and (iii) any other payments from the trust shall be considered assets disposed of by the individual for purposes of subsection (c) of this section. (B) In the case of an irrevocable trust-- (i) if there are any circumstances under which payment from the trust could be made to or for the benefit of the individual, the portion of the corpus from which, or the income on the corpus from which, payment to the individual could be made shall be considered resources available to the individual, and payments from that portion of the corpus or income- (I) to or for the benefit of the individual, shall be considered income of the individual, and (II) for any other purpose, shall be considered a transfer of assets by the individual subject to subsection (c) of this section; and (ii) any portion of the trust from which, or any income on the corpus from which, no payment could under any circumstances be made to the individual shall be considered, as of the date of establishment of the trust (or, if later, the date on which payment to the individual was foreclosed) to be assets disposed by the individual for purposes of subsection (c) of this section, and the value of the trust shall be determined for purposes of such subsection by including the amount of any payments made from such portion of the trust after such date. (4) This subsection shall not apply to any of the following trusts: (A) A trust containing the assets of an individual under age 65 who is disabled (as defined in section 1382c(a)(3) of this title) and which is established for the benefit of such individual by a parent, grandparent, legal guardian of the individual, or a court if the State will receive 2 EXHIBIT "D" all amounts remaining in the trust upon the death of such individual up to an amount equal to the total medical assistance paid on behalf of the individual under a State plan under this subchapter. (B) A trust established in a State for the benefit of an individual if- (i) the trust is composed only of pension, Social Security, and other income to the individual (and accumulated income in the trust), (ii) the State will receive all amounts remaining in the trust upon the death of such individual up to an amount equal to the total medical assistance paid on behalf of the individual under a State plan under this subchapter, and (iii) the State makes medical assistance available to individuals described in section 1396a(a)(10)(A)(ii)(V) of this title, but does not make such assistance available to individuals for nursing facility services under section 1396a(a)(10)(C) of this title. (C) A trust containing the assets of an individual who is disabled (as defined in section 1382c(a)(3) of this title) that meets the following conditions: (i) The trust is established and managed by a nonprofit association. (ii) A separate account is maintained for each beneficiary of the trust, but, for purposes of investment and management of funds, the trust pools these accounts. (iii) Accounts in the trust are established solely for the benefit of individuals who are disabled (as defined in section 1382c(a)(3) of this title) by the parent, grandparent, or legal guardian of such individuals, by such individuals, or by a court. (iv) To the extent that amounts remaining in the beneficiary's account upon the death of the beneficiary are not retained by the trust, the trust pays to the State from such remaining amounts in the account an amount equal to the total amount of medical assistance paid on behalf of the beneficiary under the State plan under this subchapter. (5) The State agency shall establish procedures (in accordance with standards specified by the Secretary) under which the agency waives the application of this subsection with respect to an individual if the individual establishes that such application would work an undue hardship on the individual as determined on the basis of criteria established by the Secretary. (6) The term "trust° includes any legal instrument or device that is similar to a trust but includes an annuity only to such extent and in such manner as the Secretary specifies. Current through P.L. 111-264 (exGuding P.L. 111-203, 111-257, and 111-259) approved 10-8-10 3 gXHIBIT "O" u~c.,15. Z!!~l~ 11:21A COMMONWEALTH OF PENNSYLVANIA GOVERNOR'S OFFICE OF GENERAL COUNSEL December 15, 2010 ('V'ia Facsimile-717-843-0699) Bruce C. Bankenstein, Esquire MANIFOLD & BANKENSTEIN 48 South Duke Street York, PA 17401 Hard Copy by Mail Re: Norma Frame Special Needs Ttust Dear Attorney Bankenstiez~: vo. 2 Please be advised that I have reviewed the Special Needs Trust that was prepared on behalf of Norma Frame. The Commonwealth of Fetmsylvania, Department of Public Welfare has no objection to this Special Needs Trust ("SNT'~. The disabled beneficiary's assets that are used to fund the SNT will not be considered an available resource in determining Norma )aYame's eligibility for Medical Assistance. If Ms. Frame has other assets that are not part of the SNT, the County Assistance Office ("CAO'~ may determine that the disabled beneficiary is not eligible for Medical Assistance. In order to assist the Department in making its determination of Medical Assistance eligibility, please provide to the CAO (with a copy to me) the documexitation regarding the funding of tb~is SNT and any subsequent additions to the SNT. Thank you for your attention and cooperation with the Department. Tf you have any questions, please feel free to contact me. Sincerely, L~cJ CL~~.~-' Lisa B.' Dees Assistant Counsel C: Susan Naylor, TPL, SNT Depository OFFICE of CHIEF CoUNSEI. 1 DEPARTMENT OF PUBLIC wELFaRE 3' I'L. WC-9T, HEALTH & YVELFARE BLGG. ~ 7' & FORSTER STREETS ~ HARRtSEUItG, F4 17120 ph: 71~-783-2g40 I Fx: 717-772-0717 ~ wv+w,~ow.state.oa.us EXHIBIT "E° 12/15/2010 WED 12:27 (T%/12% NO 8603] X002 Sep. 9. 2010 3:36PM Third Party Liability crn~uxoNwPxn~ oP Pe+Nmv~wu DEPAR7MEH7 Of PUBLIC WELFARE BUREAU OF PROGRAM INrEGRRY DMlIDN OF TNRD PART'/ L.UERJ7Y GAlUAL1V UlYT P.O.lOx 6/E6 IW WBBURA. PA 1718SS/06 September 9, 2010 ANGINO 6 ROVNER PC NEIL J ROVN$R ESQUIRE 4503 NORTH FRONT STREET HARRISBURG PR 17110-1708 Re: Norma frame CIS ~1: 790153250 Incident Date: 05/01/2006 Dear Neil J, Rovnez, Esquire: No.5622 P. 2 The Department of Public Welfare maintains a claim in the amount of $136,699.06 for the above-referenced incident. The Department has agreed to reduce its claim by 33 1 33 plus a prorate share of expenses and accept the net payment of $69,152.99 to satisfy the total claim amouriC. Checks should be sonde payable to the Department oL Public Welfare and seriL Lo my attention at the above address. Wo rsqu~at that r-ith all tsanaadttal of funds, you provide the Department With a copy of the final diatributd.on ahaet. In the event you har-e already brought or will bring any action resulting in a further recovery, we xeseroe the right to seek recovery of any additional unpaid portion of our medical/cash claim. This settlement in no way affects our future rights. Thank you for your cooperation in this matteY. It you have any further questions, please coritaet me. Sincerely, j~ ~ilw.twL1 ! .yLM.~ Karin L. Tyler Claims Investigation Agent 717-772-6619 717-772-6553 FAX EXHIBIT "F" f IN TH8 COIIRT OF CONN:ON PL8A8 OF CUD®SRLAND COIINTY, P8NN3YLVANIA ORPHANS' COIIRT DIVISION IN RE: No. TRUST FOR NORMA 0. FRAME Previous Judge: None CERTIFICATION OF 38RVIC8 I, the undersigned Attorney for the designated party in the above-captioned action, do hereby certify that on this day, a true and correct copy of the foregoing Petition in the above-captioned matter was served by first class mail, postage prepaid thereon, upon the following persons at the following addresses: Lisa B. Dees, Esquire Special Needs Trust Review Department of Public Welfare Office of General Counsel P.0. Box 2675 Harrisburg, PA 17105 Karin L. Tyler Claims Investigation Agent Department of Public Welfare Bureau of Program Integrity Division of 3rd Party Liability Casualty Unit P.0. Box 8486 Harrisburg, PA 17105 Date: /°7-/~--lD ~ _. Bruce C. Bankenstein Attorney for Petitioner 48 South Duke Street York, PA 17401 (717) 843-0961 Fax (717) 843-0699