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Senior Living Liability
ComplianceNegotiable

Resident Trust Fund Coverage

What this clause says

Coverage is extended to include loss of Resident Personal Funds held by the Insured in a fiduciary capacity, including funds held in a resident trust account.

What this actually means

Facilities frequently hold personal funds on behalf of residents in a trust account. CMS requirements at 42 CFR Part 483 govern how those funds must be managed, accounted for, and surety-bonded or otherwise assured for facilities participating in Medicare and Medicaid. A shortfall in that account is both a financial loss and a regulatory violation.

What it means for an operator

This is the coverage gap most likely to be discovered during a survey rather than after a claim. A standard crime form covers loss of the organization's money; funds held for residents are not the organization's money, they are held in a fiduciary capacity, and some forms do not reach them without a specific extension. Meanwhile the regulatory obligation to assure those funds sits on you regardless of what the crime policy says. Confirm the extension is actually endorsed, confirm the limit is sized against the aggregate balance the trust account actually carries rather than a nominal figure, and reconcile that balance regularly, because the reconciliation record is what a surveyor asks for.

How this evaluates

The Policy Checker applies these rules in order; the first match wins.

resident funds covered is set -> Compliant: Resident trust funds are specifically covered. Confirm the limit is sized against the actual aggregate trust account balance. resident funds covered is not set -> Gap: Resident personal funds are held in a fiduciary capacity and are not automatically covered by a standard crime form, while the regulatory obligation to assure them applies regardless.

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Related clauses

Common questions about this clause

Questions about compliance

Resident Trust Fund Coverage - common questions

Is this not already covered by my crime policy?

Not necessarily. A crime policy covers loss of the organization own money and property. Resident personal funds are held in a fiduciary capacity, and reaching them usually requires a specific extension. Federal requirements at 42 CFR Part 483 govern the assurance of those funds regardless of what the crime policy says.

What control matters more than the coverage?

Regular independent reconciliation of the trust account, performed by someone who does not have custody of the funds, with the reconciliation retained. That record is what a surveyor asks for, and it is also what makes a claim provable, since a facility that cannot show what the balance should have been struggles to establish its loss.

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