Georgia Qualified Income Trust Setup Guide — Qualify a Family Member for Medicaid Before the Next Billing Cycle

The bank step

The bank refusal nobody warns you about

You walk into your branch with the signed trust. The teller calls a manager. The manager has never seen one. They ask for an EIN. They tell you to come back with an attorney. You drive home with an empty trust account and a Medicaid clock ticking.

This is the single most common reason Georgia families lose a month of benefits, and it has nothing to do with the trust itself — it is a bank-procedure problem. The kit's bank section gives you the exact language to cite at the counter, the DCH policy reference to read aloud, and a printable resolution letter you can hand to the branch manager so they can escalate inside their own bank instead of sending you away.

Refusals the kit walks you through:

• Branch asks for a tax ID (EIN) for the trust.
• Branch is unsure how to title the account.
• Branch wants to set up direct deposit of Social Security into the trust.
• Branch has never opened a QIT / Miller Trust account.
• Branch instructs the customer to bring an attorney.

Each refusal has a corresponding response in the kit, with the DCH citation behind it.

Avoid these

The 8 most common Georgia denial reasons

Every denial reason below cites DCH policy. The full kit explains each one in context and the order in which to verify them before submitting the Medicaid application.

▸ QIT not established AND funded before the end of the benefit month

Per Section 2407, an application is denied for excess income for any month in which a QIT was not both established and funded by the end of that month and the applicant's income is at or above the Medicaid Cap. 'Properly funded' means depositing at least the difference between the income cap (minus a dollar) and the applicant's total income. There is no back-dating — the QIT is effective beginning the month it is completed and signed. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Patient Liability / Cost Share not paid on time

The applicant's care payment (Patient Liability/Cost Share) must be paid by the end of the month following the month the income is received. If the required payments are not made, the applicant is not following the provisions of the trust and is not eligible for Medicaid; DFCS acts to close the case for the first month timely notice permits. — GA DFCS Medicaid Policy Manual, Section 2407

▸ An inappropriate payment is made from the trust

Paying lawyer fees, mortgage payments, costs of doing business, or other non-allowable items from the QIT invalidates it; those amounts are then counted as income to the applicant, making them ineligible. The only allowable disbursements are the Patient Liability/Cost Share to the facility, the Personal Needs Allowance, diversion to a community spouse or dependent children, certain medical expenses, and bank fees. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Trust is revocable, not irrevocable

A revocable QIT does not meet the criteria and is treated as a countable resource under the OBRA '93 trust rules. Form 948 is irrevocable by its terms. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Resources placed in the trust

The QIT may contain only the applicant's income. Money from an existing account, a non-liquid resource, or a resource converted to cash cannot be placed in the trust. Depositing resources invalidates the QIT. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Applicant named as their own trustee

Section 2407 states the applicant/recipient may not act as his or her own trustee. A QIT in which the beneficiary is the trustee does not meet Georgia's requirements. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Trust backdated or established in another state

A QIT may not be backdated — it is effective only from the month all required parties sign. A QIT established in another state cannot be used to qualify for Georgia Medicaid; the applicant must establish a Georgia QIT. — GA DFCS Medicaid Policy Manual, Section 2407

▸ Missing DCH remainder (payback) clause

The trust must provide that at the applicant's death the remainder goes to the Georgia Department of Community Health up to the total Medicaid paid for the applicant's care. A QIT without the DCH remainder provision does not qualify; Form 948 already contains the required clause. — GA DFCS Medicaid Policy Manual, Section 2407

The author

Who's behind this

I'm James Whitfield — the person who hit the gap between the free state PDF and a funded Medicaid trust (the short version is up top) and built this kit to close it. I'm not an attorney. I'm a researcher who has now read every DCH policy section that covers Qualified Income Trusts, and I publish what I learned with a citation on every claim. I won't advise you on your specific situation, draft anything, or review a document you or your attorney have drafted; for advice on your situation, you need a Georgia-licensed attorney.

Questions

Frequently asked questions

▸ Is the Georgia QIT Kit legal advice?

No. This kit is informational only and is not legal advice. We are not attorneys and we do not practice law. The kit teaches you how to use Georgia's publicly-published Qualified Income Trust template (Form 948) and its companion forms. For advice on your specific situation, consult a Georgia-licensed elder-law attorney.

▸ What does the kit include?

A step-by-step operational guide: a plain-English explanation of how a Georgia QIT works, direct links to the official DCH Form 948 template plus the trustee guide (Form 945), worksheet/FAQ (Form 946), and certification (Form 936), instructions for filling the obvious fields, a monthly funding worksheet, the bank-account walkthrough with a branch script, the month-by-month funding process, and a Georgia-specific list of common denial reasons. Delivered as a single PDF.

▸ Do you provide the trust template itself?

No. We never author or host trust instrument text. The kit links you to the DCH-published Form 948 on Georgia's .gov site. You download the template directly from the state. We explain how to use it, fund it, and keep it compliant. Georgia's own policy says it is not necessary to hire a lawyer — the county provides the fill-in-the-blank template.

▸ Who has to set up a QIT in Georgia?

An applicant for nursing-facility, hospice, or Elderly & Disabled Waiver Medicaid whose gross monthly income is at or above Georgia's Medicaid Cap ($2,982/month in 2026) must establish a Qualified Income Trust to become income-eligible. A QIT is established for an individual, not a couple; resources must also be within the limit.

▸ How much of my income goes into the trust?

At minimum, the difference between your total income and the Medicaid Cap (minus a dollar) — that is the Form 946 worksheet calculation. Georgia lets you deposit all of your income or just that excess, but the state strongly recommends depositing all of it each month to reduce errors. The QIT must be funded every month you want coverage.

▸ If my Georgia QIT names Social Security as a funding source, does the entire Social Security check have to go into the trust, or can I deposit only part of it?

Georgia does not use New Jersey's 'whole source' rule. Per DFCS Medicaid Policy Manual Section 2407, 'All of the A/R's income may be placed in the QIT or just the excess over the Medicaid Cap,' and 'the amount of income deposited into the QIT may change as long as the amount of monthly income that does not go into the QIT does not equal or exceed the Medicaid Cap.' In other words, Georgia's test is a running dollar total, not a rule about any particular income source -- the state does not say a named source must be deposited in full. The Form 946 worksheet calculates only a minimum required deposit (total income minus the Medicaid Cap, minus a dollar) and DCH 'strongly recommend[s] that all the income be deposited into the QIT each month' to reduce errors. One exception: for self-employment income, deposit only the net earnings from self-employment (NESE), since business expenses are not allowable QIT disbursements.

▸ Is income counted gross or net for the Georgia QIT -- is Social Security counted before or after the Medicare Part B premium?

Gross. For the Medicaid Cap test itself, DFCS Medicaid Policy Manual Section 2510 requires you to 'Calculate the GROSS countable monthly income' and 'Compare the GROSS countable monthly income to the Individual Medicaid CAP' while directing caseworkers to 'not allow the income deductions discussed in Section 2505, Income Deductions' -- and Section 2505 confirms 'these deductions are not allowed in Medicaid CAP cases.' The Form 946 worksheet likewise asks for each income source's 'Monthly Gross Amount.' So Social Security is counted at its full gross benefit -- before the Medicare Part B premium is withheld -- both for the QIT/cap comparison and as the starting figure for your Form 946 deposit calculation. The Part B premium becomes a deduction later, inside the separate Patient Liability/Cost Share (PL/CS) budget that sets what you owe the nursing facility. Per Section 2552, that PL/CS budget starts from the recipient's gross income and then allows a Medicare Premium deduction -- but only for the first month of eligibility through the month following Medicaid approval, and never in a month where the premium is already being paid or covered under another Medicaid category (such as a Medicare Savings Program).

▸ What is the actual order of monthly payments out of a Georgia QIT -- is there an official ranked sequence?

Yes -- but the ranked order comes from the trust document itself (Form 948), not from a summary sentence in the policy manual. DFCS Medicaid Policy Manual Section 2407 only lists the allowable categories without ranking them: 'The only allowable income disbursements from the QIT account are for payment of the PL/CS to the facility, the Personal Needs Allowance (PNA), diversion to the community spouse or dependent children, medical expenses of the community spouse or other medical expenses of the A/R not covered by Medicaid.' The binding sequence is spelled out in the DCH-approved Form 948 template itself, which every Georgia QIT uses (Section B, Payments): the trustee must pay, in order, (1) the $70 Personal Needs Allowance; (2) the Minimum Monthly Maintenance Allowance to the spouse/dependent children, if any; (3) Necessary Medical Expenses not subject to third-party payment; (4) Bank fees; (5) the balance to the Patient Liability/Cost Share for nursing home expense; (6) any excess income accumulates in the trust. Note this places the Personal Needs Allowance first and the Patient Liability/Cost Share to the facility last, as the residual balance -- the reverse emphasis from the Form 946 worksheet table, which lists Patient Liability/Cost Share first simply as a layout choice, not a payment-priority statement. Follow Form 948's numbered order when writing checks each month.

▸ Does a Georgia QIT need an EIN?

The Form 948 template sets the trust up under the applicant's Social Security number, and a Miller-type QIT is a grantor trust reported under that SSN. Georgia's Trustee Guide notes that a bank may still ask for a tax ID from the IRS, so some Georgia banks request one — either way the account holds only the applicant's income.

▸ When does coverage begin?

The QIT must be established and funded by the end of the month you are seeking eligibility — there is no back-dating. Georgia also does not allow income to be direct-deposited into the QIT from the source, so each month the trustee transfers that month's income into the QIT from the regular account, early in the month, and pays the care cost by the end of the following month.

▸ What if my bank refuses to open the trust account?

Bank refusal is common on a first attempt. The kit includes a branch script, the most common refusal types (tax-ID demand, titling confusion, direct-deposit setup, unfamiliarity) and how to respond to each, and the Georgia facts that resolve them — the account is titled as the Qualified Income Trust, the trustee is the authorized signer, and only the applicant's income goes in.

▸ Can I be my own trustee in Georgia?

No. Per Section 2407, the applicant/recipient may not serve as their own trustee. A spouse, anyone named in the trust who is willing and capable, or a nursing-home representative may serve. Whoever establishes the QIT for the applicant must show a Power of Attorney, court-appointed guardianship, or conservatorship.

▸ What happens to the trust after the person on Medicaid passes away?

The trustee stops depositing funds, notifies the county DFCS office and DCH, and writes a check for the trust balance — up to the total medical assistance Medicaid paid on the applicant's behalf — payable to the Georgia Department of Community Health's Estate Recovery Program. Only funds remaining after DCH is reimbursed pass to the residuary beneficiaries named in the trust.

▸ Do you offer a refund?

Yes — money back if DCH/DFCS rejects the QIT for any reason traceable to following the kit. Email support@millertrustguide.com within 30 days of purchase with the agency's stated denial reason and we issue a full refund within one business day.

▸ Will you talk to me on the phone about my situation?

No. We do not offer phone support and we do not advise on individual situations. For advice on your specific situation, consult a Georgia-licensed elder-law attorney — you can find one through the State Bar of Georgia's Find a Lawyer service or GeorgiaLegalAid.org.

▸ Do you need an EIN to open a Georgia Miller Trust account?

Form 948 establishes the trust under the grantor's (applicant's) Social Security number, and a Miller-type QIT is a grantor trust reported under that SSN — no separate EIN is created by the trust itself. Note a Georgia-specific nuance: the official Trustee Guide (Form 945) states the bank 'may require that a tax identification number be obtained from IRS,' so some Georgia banks ask for a TIN/EIN when opening the account. Either way the account holds only the applicant's income, is titled to identify it as the Qualified Income Trust, and lists the trustee as the authorized signer; do not obtain a debit or credit card on the account.

▸ Who can serve as trustee of a Georgia Miller Trust?

Per Section 2407, the applicant/recipient may NOT serve as his or her own trustee. A spouse, anyone named in the trust who is willing and capable, or a nursing-home representative may serve (a nursing home may be trustee but may not establish the trust). Whoever establishes the QIT for the applicant must show a Power of Attorney, court-appointed guardianship, or conservatorship. The trustee is the authorized signer on the QIT bank account, makes the monthly deposits and the allowable disbursements, keeps records (bank statements, cancelled checks, receipts), and accounts to the county DFCS office on behalf of DCH at the twelve-month review. A distinctive Georgia rule: income may NOT be direct-deposited into the QIT from the income source — each month the current month's income is transferred into the QIT account from the applicant's regular bank account. The template requires no trustee bond and provides for successor trustees.

▸ Which banks will open a Qualified Income Trust (QIT) bank account in Georgia?

There's no published list of banks that offer QIT accounts — most retail branches simply haven't opened one before, since it's an uncommon account type, not because anything is wrong with the trust itself. In practice: larger banks (Chase, Wells Fargo, Bank of America) generally have a centralized trust department that can process the request even when a branch teller can't; full-service branches (often a market's main branch) open commercial and trust-style accounts more routinely than limited-service branches; and community banks and credit unions are frequently the most willing, since their account-opening process tends to involve a human review rather than a screen-driven template. Form 948 establishes the trust under the grantor's (applicant's) Social Security number, and a Miller-type QIT is a grantor trust reported under that SSN — no separate EIN is created by the trust itself. Note a Georgia-specific nuance: the official Trustee Guide (Form 945) states the bank 'may require that a tax identification number be obtained from IRS,' so some Georgia banks ask for a TIN/EIN when opening the account. Either way the account holds only the applicant's income, is titled to identify it as the Qualified Income Trust, and lists the trustee as the authorized signer; do not obtain a debit or credit card on the account. The kit includes the exact script to use at the counter and a printable letter for a branch manager if the first attempt is refused.

▸ When does Georgia Medicaid coverage begin after the Qualified Income Trust is set up?

Coverage begins the calendar month the QIT is signed, the trust account is opened, and enough of the applicant's income is deposited to bring remaining countable income below the 2026 special income limit of $2,982/month — all in the same calendar month. There is no back-dating, so every month of delay is another month of full private-pay care ($8,821–$9,429/month in Georgia). Source: DCH DFCS Medicaid Policy Manual, Section 2407 (Qualified Income Trust; effective May 2026, MT 79); Section 2510 (Medicaid Cap Budgeting) and Section 2505 (Income Deductions) for the gross-income cap test; Section 2552 (Patient Liability/Cost Share Deductions) for the post-eligibility Medicare Part B treatment.

▸ What happens to the money in a Georgia Miller Trust when the beneficiary dies?

The QIT terminates only upon the applicant's death or DCH's express written approval. On death, the trustee stops depositing funds, notifies the county DFCS office and DCH of the reason for termination, and writes a check for the trust balance payable to the 'Georgia Department of Community Health' — up to the total medical assistance Medicaid paid on the applicant's behalf — enclosing a copy of the bank statement and a cover letter identifying the decedent by name, Social Security number, and/or Medicaid number. No other checks are written from the QIT account after death. Per the Trustee Guide (Form 945), the check is mailed to Department of Community Health Third Party Administration, ATTN: Estate Recovery Program, P.O. Box 1984, Atlanta, Georgia 30301-1984; Section 2407 separately routes termination paperwork to the DCH Trust Unit — confirm the current address with DCH at termination, since agency mailing addresses can change. Only funds remaining after DCH is reimbursed pass to the residuary beneficiaries named in the trust.

▸ Can you set up a Georgia Miller Trust without a lawyer?

For the core Qualified Income Trust setup, the task is following DCH's publicly-published template and opening a specific kind of bank account — work many families do themselves. Attorneys typically charge $1,000–$2,500 for it. For complex situations (significant assets, prior gifting, second marriages, multi-state property), consult a Georgia-licensed elder-law attorney. Miller Trust Guide is informational only and is not legal advice; we do not draft the trust or advise on individual situations.

▸ Can an attorney, paralegal, or care manager use this kit for a client?

Yes. It explains Georgia's own published Qualified Income Trust process in plain language, which works whether you're doing this for your own family member or for a client — professionals handling a case outside their usual specialty use it as a working reference this way. It doesn't replace your own judgment on a specific client's facts and isn't personalized advice; it's the same walkthrough of Georgia's official form either way. If you expect to use it across more than a handful of clients or want redistribution rights, email support@millertrustguide.com about licensing options.

Keep reading

Step-by-step Georgia guides

New to this? What Is a Miller Trust? covers the plain-English basics — what it is, why states use different names for it, and how it differs from a Medicaid Asset Protection Trust. Below are the free operational walkthroughs that go deeper on the questions Georgia families ask most.

Primary sources

State agency sources

Last verified against DCH on 2026-09-09. Email support@millertrustguide.com if anything below conflicts with what DCH currently publishes — we correct verified discrepancies within five business days.