Disability Distribution - Non-Taxable Scenario?

[TCWalker]

OK - Maybe it's a stupid question, but.

Anyone know how to structure a 401(a) plan distribution due to disability that will afford the employee to receive the monies on an income tax-free basis?

I thought the general rule is tax treatment of disability benefits atbrutable to employer contributions that were not includible in the gross income of the employee or contributions made by the employee on a pre-tax basis are always subject to income taxation, (perhaps excepting a few types of insurances).

Thanks.