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Yes, subsidy equals "special needs". They do not actually have to have a medical special need. My son has none and was considered special needs (i.e., getting a subsidy) because he has minority status. And I got the full refundable credit in 2010. Not sure how the law has changed.
Also, don't believe every accountant. Most know nothng about this and I almost missed out on this credit because my accountant said I was not eligible. They were wrong! (I have a new accountant now).