QIT basics
Do I need a Qualified Income Trust in Florida?
Zacharia Frey PLLC. Updated November 2026. Draft for attorney review.
You need a QIT if you are applying for Florida long-term care Medicaid, in a nursing home, through the home and community-based waiver at home or in assisted living, through PACE, or for hospice care in a facility, and your gross monthly income is more than Florida's income limit. Gross means before the Medicare premium, taxes, or anything else is taken out. If gross income is at or under the limit, a QIT is not needed for the income test.
Florida's income limit for long-term care Medicaid is $2,982.00 a month in 2026, measured on gross income.
Start with gross income
Add up every regular source of the applicant's income for a month: Social Security, pensions, annuities, and any other payment that arrives regularly. Use the amount before anything is withheld. For Social Security, that is the benefit before the Medicare Part B premium comes out, which is more than what lands in the bank. For a pension, it is the amount before tax and insurance premiums.
Working from the bank deposit is the most common mistake we see. A person whose deposit is under the limit can still be over it on a gross basis, and DCF counts gross.
Some kinds of income are counted differently. If anything besides Social Security and a pension is involved, that is a good reason to have the firm look at the figures.
Retirement accounts can push income over the limit
Once a person reaches the age when federal law requires minimum distributions from an IRA, those distributions are part of the picture. That age is 73 for people born from 1951 through 1959 and 75 for people born in 1960 or later. Our free QIT Check adds the year's required distribution, spread over twelve months, to monthly income.
How a particular account is treated depends on the account and how distributions are taken, so the QIT Review works from the actual statements.
Close to the limit is not safe
Social Security and pension amounts usually change each January, and Florida's income limit changes over time too. A person a few dollars under the limit this year can be over it next year. If income is close, plan for a QIT rather than wait for a denial.
Married applicants
The income test looks at the applicant's income: for nursing home Medicaid, DCF does not count income that belongs only to the spouse at home. A QIT holds only the applicant's own income, never a spouse's. The spouse's income still matters later, in figuring any monthly allowance for the spouse at home. That is one reason married households should have the numbers checked.
What to do with the answer
If the answer is yes, the trust has to be signed, its bank account opened, and the income deposited in the same month it arrives, every month. Medicaid will not pay for long-term care in a month the QIT was not funded, and a missed month cannot be fixed by depositing late. Someone also needs the legal authority to sign the trust, which is often where an out-of-state power of attorney falls short. The steps are in how to set up a QIT.
If the answer is no, a QIT is not needed for the income test. The other Medicaid rules, including the asset limit, still apply. A QIT solves an income problem only, and no one can promise that Medicaid will be approved.
Questions
- Can I check online?
- Yes. The free QIT Check asks three questions: gross monthly income, the value of any IRA on December 31 of last year, and age at the end of this year. It answers yes or no based on the information you provide, and nothing you type leaves your browser.
- Is the QIT Check's answer final?
- No. It is only as good as the figures entered, and DCF decides eligibility. The QIT Review checks the figures against the documents.
Where this comes from
- 42 U.S.C. § 1396p(d)(4)(B) (United States Code)
- ESS 1840.0110 (income trusts) (DCF ESS Program Policy Manual)
- ESS 2640.0115.02 (gross income decides eligibility for ICP, hospice, and HCBS) (DCF ESS Program Policy Manual)
- ESS 1840.0109.01–1840.0109.02 (the community spouse's income; who owns income) (DCF ESS Program Policy Manual)
- 26 U.S.C. § 401(a)(9)(C)(v) (age required minimum distributions begin) (United States Code)
