Issuers & Plan Administrators

Card issuers and issuer processors enable plan administrators to offer FSA/HRA debit card programs to employer clients. Any issuer or issuer processor using the SIGIS Technical Specification to process IIAS transactions or 90% Rule exceptions is required to be a SIGIS member. Additionally, issuers and issuer processors play an important role in supporting plan administrators with support when FSA/HRA cardholders have questions about card purchases at participating merchants. Plan Administrators support programs to the respective employer and the respective plan participants.

Membership in SIGIS offers issuers and plan administrators access to the following programs:

SIGIS IIAS Transaction and Data Retention Specification

The SIGIS Specification outlines the requirements needed for merchants, acquirers, processors, card issuers and plan administrators to support an IIAS.

SIGIS Eligible Product List

The SIGIS List is a valuable resource in the development of plan criteria for identifying eligible products. The SIGIS List represents a unique tool that provides an industry-vetted list of eligible products that can be used in the administration of FSA/HRA card programs. See the Eligible Product List Criteria publication for more information.

Regulatory Impact

SIGIS actively engages with the IRS and Treasury Department on rules impacting the use of health benefit cards. SIGIS has led efforts to clarify item eligibility and changes required by the Patient Protection and Affordable Care Act.

90% Rule Program

Offering FSA/HRA cardholders the opportunity to use their cards at registered 90% Rule merchants is a great way to increase the convenience and usability of an FSA/HRA card program. It is noted that transactions at 90% Rule stores are not auto-substantiated and plan administrators will need to follow their policies for substantiation of such purchases, most likely asking cardholders to forward their sales receipts. Visit the 90% Rule Merchant Attestation for more information.

SIGIS provides additional support through our Help Desk that is available to answer any questions regarding the programs listed above.

Issuers and Plan Administrators
Related FAQs

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

As a paid Member of SIGIS in good standing, a merchant is able to confirm the status of its SIGIS 90% Registration or IIAS Certification status by visiting the Publications page.

Please note that the 90% Merchant list is updated each Monday morning and the IIAS Merchant list is published at 5 am PST each business day..

SIGIS will publish a list of SIGIS Members that have registered as 90% Rule merchants. Additionally, SIGIS will publish the acquirer IDs and Card Acceptor IDs of these merchants each week. Issuers and issuer processors that elect to participate in the 90% Rule should use the 90% Rule SFTP Report. The issuer processor should use the MasterCard ICA, Visa BIN, Maestro ICA, Visa Interlink ID, STAR ABA, NYCE ID, ACCEL ID, PULSE ID, CAID and MCC code in the authorization process to determine if it is a 90% Rule merchant. Other fields should not be used, as doing so may cause unnecessary declines. The public 90% Rule report should be used as an informational guide when working with merchants. Issuer and issuer processors must be a SIGIS Member to download the list.

Generally, yes. The IRS requires that FSA/HRA purchases be substantiated. As the 90% rule does not provide substantiation, plan administrators will apply their standard substantiation processes to transactions at these locations. The customer may be asked to submit a sales receipt to document that the items being purchased were Rx/prescriptions or Eligible Health Care Products. In some cases the plan administrator may be able to match a transaction amount with other data such as Pharmacy Benefit Management (PBM) co-pay on prescriptions to complete substantiation and not require the customer to submit a sales receipt. But in the absence of an automated matching program like this, it is likely that customers using an FSA/HRA card will be asked by their plan administrator to submit a sales receipt.

While a majority of plan administrators permit FSA/HRA cards to be used at 90% Rule merchants, there may be some that do not or whose employer clients do not permit it. This could mean that plan administrators in a merchant's market area may have elected not to authorize FSA/HRA card transactions at 90% Rule merchants.

It is possible that the IIAS system has been installed in specific locations within a store, the pharmacy for example, and not all registers within the store. If there is any question, please ask the store for more information.

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.

When TPAs experience transaction issues, they should speak with their card processor for specific details. It is possible that the cardholder was attempting to purchase items that the merchant did not have identified as SIGIS qualified items and, therefore, did not submit the transaction for authorization against the card identified as being for health care purchases.

The IRS requires that merchants be able to retrieve the product detail associated with an IIAS transaction for a period of five (5) years. The data retention requirements are published in the SIGIS Technical Specification.

Consumers contact their plan administrator to ask questions about merchants at which their FSA/HRA card will work. Only plan administrators can answer these questions. Plan administrators should research cardholder questions via their transaction processing systems to determine what may have caused a cardholder's problem. If the plan administrator believes that SIGIS 90% Rule merchant information may not be accurate, they should contact their card issuer processor for assistance.

The prescription subtotal is optional for merchants to support when implementing their IIAS systems. For a list of merchants that support the Rx subtotal, please go to the IIAS Merchant List under Governance Documents & Publications. The "Supporting Prescription Subtotal" column indicates which merchants have chosen to provide the prescription subtotal in their card authorization requests.