Merchants might need new equipment or just updates to existing software to support IIAS processing. A number of POS vendors for the supermarket, chain drug store, and related merchants have updated their POS systems software to support IIAS processing. For clarification or confirmation, a merchant should contact its processing acquirer and/or POS software provider, the organizations providing your credit card / debit card solutions or the bank that provides credit card processing. Vendors will work with merchants to install any necessary updates.

A new POS solution could be required for merchants that do not have a POS system that can support electronic inventory management, UPC scanning, and the additional fields used in the IIAS transactions that are required. Many POS solutions supporting the required elements of the IIAS exist in the market today. Contact your POS vendor or acquirer/merchant processor for information about POS systems that are available to support IIAS processing.

While being SIGIS IIAS Certified enables a merchant to be in compliance with IRS guidelines in accepting FSA and HRA cards, SIGIS IIAS Certification does not guarantee 100% acceptance of cards.

SIGIS Member issuer/processors and the majority of their clients who provide employee FSA and HRA cards have enabled SIGIS IIAS processing to authorize and auto-substantiate transactions.

However some employer benefit plans may require a level of transaction detail that is not supported by the SIGIS IIAS Standard, thereby, preventing acceptance even at merchants with a fully SIGIS certified IIAS solution.

Merchants that have implemented IIAS systems may continue to see declines on health care benefit cards that are standard payment card declines (insufficient funds, closed account, etc.). Thus, if the card transaction declines, it is most likely that the decline is valid.

Listed below are the main reasons why properly formatted IIAS transactions at an IIAS merchant may be validly declined. Note: The list below is not intended to be all-inclusive, but, represents the most common reasons that together account for most declines.

MOST FREQUENT VALID DECLINE REASONS

1. The card has not been activated or has been suspended.
2. The card has no funds remaining, or the card has insufficient funds and the merchant does not support partial authorization.
3. The cardholder is attempting to purchase only non-health care eligible items with a card that has only an FSA and/or HRA purse.
4. The participant's plan only reimburses the prescription drug amount and (a) The merchant does not send the Rx amount in the auth message, or (b) The plan requires a match to claim(s) from a pharmacy benefit manager (the cardholder's prescription drug plan) and the transaction failed to match, or (c) The merchant sends the Rx Amount but does not support partial authorizations and there are non-Rx items being purchased.
5. The participant's card has not been loaded with funds for the new plan year because of delays by the employer or TPA in getting the enrollment file to the issuer processor.
6. The merchant sent an expiration date that does not match the date in the issuer processor's system - this can happen when there is an error key entering the expiration date.
7. The merchant manually keys in a card number that does not match a valid card on file with the issuer.
8. The cardholder was issued a new card, either because his/her employer changed TPAs or she/he changed employers, but is continuing to use the old card that has been closed.
9. The participant tried to use their card as a PIN debit and they entered an incorrect PIN number.
10. The participant tried to use their card as a PIN debit and the merchant does not support PIN debit FSA transactions.

Upon notification of completion of the SIGIS IIAS Certification Process, a merchant should follow up with its acquirer/processor to obtain the card network's transaction control id numbers. The acquirer/processor is the only entity able to retrieve these numbers. A merchant must obtain these identification numbers before FSA/HRA Card transactions will process correctly.

A merchant’ s acquirer is the company that actually processes its bankcard transactions. Many merchants have relationships with Independent Sales Organizations or Banks, but the actual processing is done by another company. If a merchant doesn't have a direct relationship with an acquirer, the company with whom a merchant does have a relationship can help you identify its acquirer and should facilitate the gathering of the information needed to complete its registration.

No. A merchant is not required to implement an IIAS; however, FSA/HRA card issuers will not be able to approve FSA/HRA card transactions when a merchant does not support an IIAS. If you are a merchant and choose not to implement an IIAS, you do not need take additional steps.  Merchants that are pharmacies/drug stores and primarily sell prescriptions and medical items may qualify under the IRS rules as a “90% Rule” merchant.  See the 90% Rule Merchant FAQs for more information.

For merchants that would like to accept the FSA/HRA cards from their customers, the IRS requires Merchants selling health care eligible products to support an Inventory Information Approval System (IIAS). The IIAS system is a combination of inventory management and point-of-sale systems that can verify the health care eligibility of items purchased with an FSA or HRA debit card, generate a payment transaction that contains the required IIAS information, and includes an information archive system that allows the merchant to respond to an IRS audit(s) as required. As noted above, for Drug Stores / Pharmacies where 90% of the sales on a store-by-store basis qualify as FSA-eligible, a 90% Rule registration program is an alternative option.

Merchants have the option to not become a Member of SIGIS by establishing their own IIAS standards or 90% Rule Exemption and working with third-party plan administrators individually.

With the IIAS Certification developed by SIGIS, a non-profit standards organization, a broad range of participating merchants have been able to implement a solution that is recognized industry-wide, which enables acceptance of most FSA/HRA payment cards. Likewise, third-party plan administrators have implemented a common set of procedures that are applied to IIAS transactions at participating merchants.

As a paid Member of SIGIS in good standing, a merchant is able to confirm the status of its SIGIS Registration for the 90% Rule Exemption by going to www.sig-is.org and clicking on 90% Rule Merchant List. If the merchant’s organization is not on the list, the merchant will need to complete the online form to complete registration for the 90% Rule.

Please note that the list is updated each Monday morning.

As a paid Member of SIGIS in good standing, a merchant is able to confirm the status of its SIGIS IIAS Certification by going to www.sig-is.org and clicking on IIAS Merchant List.

A Member’s DBA Names (doing business as name) will be posted on the IIAS Merchant List under the following parameters.

• If the Membership is listed as "Certified", the merchant has completed the IIAS Certification process

Please note that the list is published at 5am pst each business day.

It is possible that the merchant has a phased implementation of IIAS capabilities. If the merchant's implementation date is listed as "Live" and a plan administrator continues to experience problems with card usage, please speak with your transaction processor.