CSPN ABLE Forum Overview
August 6- 7, 2015
Last week, many State Treasurers and other vested parties met in Chicago to discuss and share their plans for their ABLE programs. The meeting was supported by the National Association of State Treasurers (NAST) and the College Savings Plan Network (CSPN), both of whom are strong supporters of ABLE legislation.
The meeting began with an interactive discussion of the proposed Treasury regulations. The regulations were looked at as a whole, and then with a specific look into provisions relating to, safeguards for disability distributions, and reporting requirements. All were invited to participate, and there was great insight gained from all who shared. Catherine V. Hughes, Estate & Gift Tax Attorney-Advisor, Office of Tax Policy, U.S. Department of the Treasury also shared her insights into the proposed regulations, providing additional legal expertise into the conversation. The session concluded with a discussion about the appropriate response from NAST/CSPN to the regulations. The group was able to come up with many great ideas, and agreed on a direction for their communications moving forward. Intuition was very pleased that several assumptions that were made based on the clear wording of the Act, seem to hold up under scrutiny.
After a short break, the next session began with Andrea Feirstein, an expert consultant in 529 program management. The session focused on the potential of various states’ ABLE markets including the size of the beneficiary pool, scale ability, funding sources, various program models, start-up and operational costs, and the anticipated uses of ABLE accounts by beneficiaries. Panelists included representatives from various state agencies and the private sector. Ms. Feirstein’s insight from the existing 529 industry bears the closest resemblance to what ABLE programs could end up looking like. She challenged the private sector panelists to provide high level considerations for how they are determining costs and services. The session had a high level of forum participation. Several key points seem to come to the forefront — states are still trying to determine how many potential beneficiaries there may be in a state. Program Managers are trying to understand how consumers will use these accounts, and working through the challenges of accounts which can have potentially higher transactional volume but low account balances. The forum collectively agreed that there are still many unknowns surrounding ABLE plans.
The third session focused on interstate collaborative models. There was a lot of discussion surrounding how states may be able to collaborate. There were various questions and discussions in areas such as program oversight, expenses, roles and responsibilities between Host and Contracting states.
The final session of the day focused on communicating financial matters with individuals with disabilities and their families, and the most appropriate and effective ways for doing so. The session had a special interest on communicating with individuals with vision and hearing disabilities, and how to create materials that will be best understood by the target audiences. ABLE programs will only be effective if beneficiaries are able to understand them and leverage their resources.
The day was filled with great discussion and helped to get many of the industry leaders on the same page. All of the speakers prompted thought provoking discussion and offered different insights into the rapidly developing ABLE industry. With some states pushing to have their programs go live by January 2016, meetings like this are a necessity for growing and sharing information.
Intuition is continuing development of an ABLE program and platform. We agree that there are numerous challenges in developing a program that will balance the need for flexibility for beneficiaries, at reasonable costs to the state and beneficiary.