Understanding the Trust

What Is a Supplemental Needs Trust?

A Third-Party Supplemental Needs Trust (SNT) is the most common and powerful vehicle for large, long-term financial support for a disabled person — established by someone other than Gabriel (a parent, guardian, or other family member or friend).

  • Funds in the trust are not counted as Gabriel's assets for Medicaid or SSI eligibility — because the trust owns them and distributions are controlled by a trustee.
  • Funds can pay for all of Gabriel's needs: housing, caregivers, transportation, travel, food, adaptive equipment, and more.
  • Any donor can contribute any amount — there is no cap on what can be gifted into the trust.
  • When Gabriel passes, remaining assets go to a contingent beneficiary (501(c)3) and are not subject to Medicaid payback, unlike first-party trusts.

Best for: Long-term funding goals, gifts from many donors, and ongoing support without affecting government benefits.

Gabriel Tempest

Legal Setup

How the Trust Is Established

Establishing a Third-Party SNT follows a clear legal process before any gifts are received.

Attorney Creates the SNT

A qualified attorney drafts the trust document, selecting the beneficiary, trustee, and governing terms in compliance with state and federal law.

Trustees Selected

One or more trustees are appointed to manage distributions and investment decisions solely in Gabriel's best interest.

Tax ID & Bank Account

The SNT receives its own Tax ID from the SSA and opens a dedicated trust bank account — legally separate from Gabriel's personal finances.

Fund the Trust

Donor gifts are deposited directly into the trust. No cash goes to Gabriel — all distributions are made by the trustee to pay approved expenses on his behalf.

Why the Trust Matters

A Complex Web of Care

Gabriel must navigate three separate systems — each with different rules, timelines, and decision-makers, and no single point of contact.

Social Security (SSA)

  • Determines cash benefits
  • Strict income and asset limits
  • Federal rules and reviews

NC Medicaid (NCDHHS)

  • Health care and long-term supports
  • Eligibility does not guarantee services
  • Waiver programs with capped slots (14,138 currently)

Alliance Health (LME/MCO)

  • Authorizes services and providers
  • Manages budgets and availability
  • Separate assessments and approvals

The system is fragmented, difficult to navigate, and often fails individuals with Gabriel's circumstances. The SNT provides a private, stable alternative that is free from red tape and funding gaps.

The Need

Estimated Lifetime Costs

Based on 2026 rates with a 3% annual inflation assumption, Gabriel's estimated lifetime support costs total $33.6 million.

$24.2M

Caregiving — 72%

2 reliable caregivers at ~$22/hr minimum, 14 hrs/day, with electronic monitoring for nights.

$6.2M

Housing — 18.5%

ADA-accessible apartment or single family home: ~$2,000/month plus ~$400 utilities.

$3.2M

Transportation — 9.5%

NEMT, caregiver transport, and Uber/Taxi at ~$15,000 per year.

Daily Care

Care Requirements

Gabriel requires 24/7 care — both in-person and assistive technology — that flexibly supports him as a student and, eventually, as an employed adult.

Daily Living

  • Grocery shopping, food prep, meals, laundry
  • Scribing assistance when needed
  • Flexible schedule to support school and work

Nutrition

  • Specific guidelines for healthy meals
  • Food cut and served so Gabriel can eat independently (bowls)

Exercise

  • Assist with core exercises
  • Recumbent bike rides when desired
  • Gym or fitness venue transportation, or monitor on treadmill

Hygiene & Housing

  • Bathe daily, brush teeth and floss
  • ADA-accessible home with filtered water
  • Cleaning schedule to maintain home

Stewardship

Investment Guidelines

The Third-Party Supplemental Needs Trust will provide stable, lifetime support through prudent investing while protecting the principal and preserving Medicaid eligibility.

  • Lifetime fund designed to withstand normal market cycles
  • Return target of 6%, allowing annual spending of 3–4%
  • Fiduciary investment advisor fee of 0.5%
  • Governed by the Prudent Investor Rule
  • Annual summary reporting to donors
  • No direct cash to Gabriel — all distributions are coordinated to preserve SSI and Medicaid

Tax Considerations

Why Gifts Are Not Tax-Deductible

Under U.S. tax law, charitable deductions are only allowed when a donor gives to a qualified 501(c)(3) public charity or certain government entities — and the gift is used for a public, charitable purpose, not a private individual.

Because gifts to Gabriel's Angels Supplemental Needs Trust ultimately benefit one identifiable person, the IRS classifies them as a private benefit, not a charitable one. Contributions are therefore not tax-deductible.

Gifts to the trust are transformational — they benefit Gabriel's life for a lifetime.

The Plan

Funding Milestones

Our goal is to reach full funding by July 2027. Here is the roadmap.

Jul. 1, 2026

Formally establish Gabriel's Angels SNT. Raise $500K with initial network. Find our first Anchor contributor. Create video and marketing plan. Search for new agency.

Oct. 1, 2026

Raise $1M total. News, print, and social campaigns launch. Two anchors, two lead donors, others. Grow fundraising team. Establish new agency and housing. Begin housing distributions.

Jan. 1, 2027

Raise another $1M. Focus on community and core gifts. Community events drive awareness. New staff, increased care, increased dignity. Gabriel focused on school and faith.

Apr. 1, 2027

Raise $1.5M more. Create quarterly reporting. Begin food and transportation distributions. Increased social and community interactions. Independence not tied to others.

Jul. 1, 2027 — Fully Funded

Quarterly updates to Anchor and Lead contributors. Annual updates for core and community contributors. Gabriel free to focus on his faith, studies, and career.

Contributions are gifts to a private Supplemental Needs Trust and are not tax-deductible charitable donations under IRS rules.

Our Foundation

What We Stand For

Everything we do is guided by four core values that honor Gabriel and the community that surrounds him.

Love

Gabriel is at the center of everything. Every decision is made with his best interests and happiness as the highest priority.

Integrity

We are responsible stewards of every gift entrusted to us. Funds are managed transparently and used exclusively for Gabriel's benefit.

Community

We believe Gabriel's life is enriched by the people around him. We welcome every supporter as part of his extended family.

Hope

We believe deeply in Gabriel's future — and in the power of a caring community to make that future bright.

Common Questions

Frequently Asked Questions

Will my gift affect Gabriel's government benefits?
No. Because Gabriel's Angels is a third-party supplemental needs trust, contributions you make are not counted as Gabriel's personal assets. His Medicaid and SSI eligibility is fully protected.
Is my contribution tax-deductible?
No. Gifts to Gabriel's Angels Supplemental Needs Trust are not tax-deductible charitable donations under IRS rules. Because the gift ultimately benefits one identifiable individual, it is classified as a private benefit — not a charitable one.
Who manages the trust funds?
The trust is administered by a designated trustee whose responsibility is to act solely in Gabriel's best interest. All disbursements are reviewed for compliance with trust terms and applicable law. A fiduciary investment advisor manages the invested assets.
What can trust funds be used for?
Trust funds can be used for all of Gabriel's needs: housing, professional caregivers, transportation, food, adaptive technology, home modifications, medical equipment, and quality-of-life enhancements. No cash is distributed directly to Gabriel.
How is the trust invested?
Trust assets are invested in diversified funds under the Prudent Investor Rule, targeting a 6% return. This allows annual spending of 3–4% to fund distributions while protecting the principal over Gabriel's lifetime. A fiduciary advisor charges 0.5% in management fees.
What happens to the trust when Gabriel is no longer living?
As a third-party trust, any remaining funds at the end of Gabriel's life are distributed to a named contingent beneficiary (a 501(c)(3) organization). There is no Medicaid payback requirement for third-party supplemental needs trusts.

Have More Questions?

We are happy to walk you through the trust and how your gift makes a difference.