How are distributions defined for a Special Needs Trust?

I am the trustee for my brother's special needs trust. The trust requires that I cannot distribute funds directly to my brother, but the trust may pay for the delivery of services, equipment, etc. that the government does not provide.

 

Since I have only been a trustee for a short period, starting with the funding of the trust when both my parents died recently, I am confused by how the IRS defines "distributions" to the beneficiary (my brother). 

 

Can I assume that "distributions" to the beneficiary are narrowly defined as direct payments to my brother (which have not occurred because the trust forbids it)?

 

Or, do I have to account for all the purchases made in 2019 by the trust?