What to Say at the Bank When Opening a Miller Trust Account in Georgia
When you open a Miller Trust account in Georgia, expect the branch to hesitate — most have never opened a Qualified Income Trust account, and many ask for an attorney or a tax ID (EIN) you do not need. You do not need a lawyer to open the account, and a Georgia QIT is set up using the beneficiary's Social Security number, not an EIN. Below are the 5 refusals Georgia families hit most often and exactly what to say to each — every response is backed by DCH's own published guidance.
Why the bank says no
Opening a Georgia Miller Trust account is not legally complicated, but it is unfamiliar to most branch staff — they rarely see a Qualified Income Trust, so the default reaction is caution. The fix is almost never arguing; it is handing the branch the right DCH document and asking for the right account type. Below are the 5 refusals families hit most often in Georgia.
Refusal 1
Branch asks for a tax ID (EIN) for the trust
What to say: Form 948 establishes the trust under the applicant's Social Security number, and a Miller-type QIT is a grantor trust reported under that SSN. Georgia's own Trustee Guide (Form 945), however, acknowledges that a bank 'may require that a tax identification number be obtained from IRS' — so if the branch insists, a TIN/EIN can be obtained, and the account still holds only the applicant's income. Show the branch the Form 945 guidance and Form 948.
Bring: Form 945 (QIT: A Guide for Trustees) and Form 948 (the template's identification line)
Refusal 2
Branch is unsure how to title the account
What to say: Per Form 945 the account is titled to identify it as the Qualified Income Trust (e.g., 'The Qualified Income Trust'), with the trustee as the authorized signer; checks are imprinted with the same title. Ideally it is a non-interest-bearing checking account with no service charge.
Bring: Form 945 (account-titling and signer guidance)
Refusal 3
Branch wants to set up direct deposit of Social Security into the trust
What to say: Georgia does not allow income to be direct-deposited into the QIT from the source. Each month the trustee deposits a check (or arranges an electronic transfer if the QIT is at the same bank as the regular account) from the applicant's regular checking account into the QIT account — early in the month to protect eligibility. Set up the account as an ordinary checking account, not a benefit-direct-deposit account.
Bring: Form 945 (How to Get the Income into the QIT Bank Account)
Refusal 4
Branch has never opened a QIT / Miller Trust account
What to say: It is an ordinary checking account the trustee manages, holding only the applicant's income and depleted toward care each month. Ask for a full-service branch or the bank's trust department; community banks and credit unions are often more flexible. Do not request a debit or credit card on the account.
Bring: Form 945; Form 946 (QIT Worksheet & FAQ)
Refusal 5
Branch instructs the customer to bring an attorney
What to say: Georgia's own policy and Desk Guide state it is not necessary to hire a lawyer to set up a QIT — the county DFCS office provides the fill-in-the-blank Form 948 template. This is a bank-procedure issue, not a Medicaid requirement; escalate to the bank's trust department or use a community bank or credit union.
If the branch still won't open it
Ask for the bank's trust department, or switch to a community bank or credit union — their account opening tends to involve a human review rather than a screen-driven template, so they accommodate unusual account types more readily. The account itself is ordinary: a dedicated checking account titled to the trust, opened with the beneficiary's Social Security number.
Common questions
- 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.
- Do you need a lawyer to open a Georgia Miller Trust bank account?
- No. Georgia Department of Community Health does not require legal representation to open the account. If a branch insists, that is a bank-policy stance, not a Medicaid rule — escalate to the bank's trust department or use a community bank or credit union. For advice on your specific situation, consult a Georgia-licensed elder-law attorney.