IIAS versus 90% Rule Comparison

Some drug stores and pharmacies have the option of supporting an IIAS or registering as a 90% Rule merchant. Additionally, plan administrators may elect to support IIAS and/or 90% Rule programs. The chart below highlights some of the key characteristics and requirements of each program.


Merchant IIAS (Includes TPS Merchant)

90% Rule

Program description

IIAS transactions enable real-time verification that funds approved for debiting an FSA/HRA card account are for eligible medical items, as required by the IRS.

Issuer/issuer processors utilize the IIAS data fields in authorization request transactions to approve and auto-substantiate eligible health care amounts.

After successful program registration, 90% Rule merchants accept FSA/HRA payment cards just like any other payment card; there are no additional technical requirements for merchants.

Issuers/issuer processors support a list of 90% Rule merchant locations during authorization processing.

Qualification requirements

Any merchant that sells prescriptions/Rx or eligible health care items.

Limited to drug stores/pharmacies that have stores whose sales are primarily eligible medical items (90% or more of sales for each store registered must be from prescriptions or eligible health medical items).

Technical requirements for merchants

Merchants are required to make technical changes to support the following:

  • Use the SIGIS Eligible Product List to flag eligible health care items in merchant’s inventory.
  • Change payment card processing to add FSA amounts to transactions.
  • Support a list of FSA/HRA BINs to identify card numbers to add IIAS data fields.
  • Store transaction detail for approved FSA/HRA card transactions in the event of an IRS audit.

Drug stores/pharmacies are not required to make any technical changes.

Identification of prescription amounts

Yes, IIAS merchants have the option to include the Prescription/Rx Amount in addition to the Total Health Care Amount; this enables plan administrators to approve more FSA/HRA transactions.

Not applicable.

Merchant categories

Includes the following:
5411 – Grocery/Supermarket
5310 – Discount Stores
5300 – Warehouse Clubs
5499 – Convenience Stores
5912 – Drug Stores/Pharmacies
5122 – Druggist/Drug Proprietaries
5960, 5964, 5965, 5969 – Online
Various MCC – Other Non-Healthcare Merchants

Only the following:
5912 – Drug Stores/Pharmacies
5122 – Druggist/Drug Proprietaries

Cardholder required to submit a transaction receipt to plan administrator

Because transactions are auto-substantiated, cardholders are most likely not required to submit transaction sales receipts; although it is recommended that cardholders keep copies of transaction receipts.

Cardholders are most likely required to submit transaction sales receipts; cardholders are recommended to keep copies of transaction receipts.

Name of merchant list

IIAS Merchant List

90% Rule Merchant List

Transaction data retention

IIAS merchants are required to store the transaction detail for approved IIAS transactions in the event of an IRS audit for 5 years.

Not required.

Annual processes

IIAS merchants are not required to re-certify unless the merchant makes changes to software that affects IIAS-certified components or if the merchant changes acquirers.

The IRS requires annual registration and re-attestation that the sales of each registered store location are 90% or more from prescriptions or eligible medical items.

For more information

For merchants that operate their own inventory and cash register software, see IIAS Merchant Certification.

For merchants that contract with a POS vendor/third-party servicer, see TPS Merchant Certification.

For drug stores/pharmacies that sell primarily prescriptions and eligible medical items, see 90% Rule Merchant Attestation.