IIAS Certification

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.

Merchants might need new equipment or just updates to existing software to support IIAS processing. 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. 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.

Additionally, merchants can review the SIGIS POS Solution Provider list.

A Member who is currently certified may change its acquirer/processor at any time. However, to avoid a lapse in IIAS Certification status, the Member is encouraged to submit all documentation and complete a new IIAS Certification under the new acquirer/processor before discontinuing the relationship with their existing certified acquirer/processor.

If Member is a Certified TPS Client Merchant who completed the Online TPS Client Merchant Form:

1. If the Member is using the same TPS solution, and the new acquirer is certified under this TPS, the Member will need to complete a new TPS Merchant certification form by clicking Add New TPS Certification.
2. If the new acquirer/processor is not listed as certified with the POS provider, the TPS Merchant certification cannot be used to change your acquirer/processor. The Member must complete the Merchant Certification Self-Assessment Form. (See instructions for completing the Merchant Self-Assessment.)

If a Member is not a Certified TPS Merchant, the Member must recertify using a Merchant Certification Self-Assessment Form (See instructions for completing the Merchant Self-Assessment process.)

A TPS may update the contact email address for a certification in any status without changing other information on the form. To do so, please follow these steps.

1. Log in to the Members Area
2. Select the “Certification Forms link” on the right hand side of the page; a new window will open.
3. Click on the “TPS Self Assessment” Tab
4. Click on the “Online Form” link next to the certification you wish to update
5. Scroll down to the “TPS Contact Email”, make the appropriate change and click the “Save Email” button.

All new TPS Merchant approval requests will be routed to the new email address.

US Territories US Virgin Islands (USVI), Guam, Marianas Islands / Saipan (CNMI) and American Samoa operate under a variety of US tax laws.  Some mirror the US tax law while others are separate and distinct.  In summary:

• US Virgin Islands (USVI) and Guam operate under a mirrored US tax law that supports Section 125 Cafeteria plans and an IIAS.  SIGIS supports retailers and consumers in these markets via IIAS and 90% Rule programs.

• Puerto Rico has its own tax code that does not currently recognize Section 125 Cafeteria plans and IIAS.  SIGIS does not support this market.

• American Samoa and Marianas Islands / Saipan (CNMI) have a combination of US and Local tax laws in effect.  Further research is required to determine if Section 125 applies in these markets and the impact of local tax laws. At this time, SIGIS does not support these markets.

While SIGIS processes may support these locations members and consumers should consult with their counsel and plan administrators that operate in these markets to determine support for FSA, HRA and HSA debit cards.

As of April 12th, 2011.

When purchasing products in or from a foreign country, any expense must be a qualified medical expense according to US IRS guidelines and must be legal in both the US and the foreign country. Additionally in most cases, the US Food and Drug Administration (FDA) prohibits the importation of OTC or Prescription Drugs, so generally drugs must be consumed in the foreign country.  Given the complexities of US legal requirements, foreign legal requirements for each country, General Data Protection Regulation (GDPR) requirements for some countries, SIGIS does not support foreign merchants.  Consumers should be directed to use another form of payment and submit a manual claim if they believe their purchase qualifies for plan reimbursement.

A foreign company may participate in SIGIS and become IIAS certified or 90% Rule registered if conducting business from a valid US based physical or online retail location.  Valid businesses must meet all Federal, State and Local requirements for doing business in the US.  The legal address must be a physical location, not a PO box or a mail forwarding service. Foreign based e-commerce merchants must be operating a legal US-based website that takes US currency.  This will be verified by SIGIS upon request for membership.

1. Click the Login link at the top of the page and enter login information.
2. Click Access IIAS forms on the right side of the page.
3. Click on the TPS or IIAS Certifications tab as appropriate.
4. Click on the Online Form link next to your certification.
5. Scroll down to the DBA section.

   To change:

   • To add your location to the store locator search click the checkbox under the Opt-In column. NOTE: This checkbox is located next to your MCC code.
   • To remove your location from the store locator search click to uncheck the checkbox under the Opt-In column. NOTE: This checkbox is located next to your MCC code.
6. Click Save.

Potentially, yes. The IRS states that cardholders’ use of a FSA/HRA card is limited to merchants and service providers with specific merchant category codes (MCC) related to health care, including physicians, dentists, vision care offices, hospitals, and other medical care providers. The FSA/HRA card can also be used at merchants or service providers that do not have health care related merchant category codes, provided that those non-health care related merchants or service providers use an Inventory Information Approval System (IIAS). It is required that attempts to use FSA/HRA cards at merchants or service providers without a health care related MCC code and who have not implemented an IIAS be declined.

An IRS ruling highlighted merchants in categories such as supermarkets, grocery stores, discount stores, wholesale clubs, mail order vendors and web-based vendors that sell prescription drugs as examples of merchants that would not be considered health care related and would therefore fall into the class of merchants requiring the implementation of the IIAS system. Because of the broad range of the merchandise sold by many drug stores or pharmacies, the IRS has also specified that drug store and pharmacies are not to be considered medically related, and thus, must implement an IIAS capability. Additionally, drug stores and pharmacies where 90% of their products sold qualify as medically eligible items may qualify for the 90% rule exception.

If the Primary Organization has registered for the 90% Rule Exemption from IIAS standards and would like to convert to SIGIS IIAS Certification, the Member must first determine appropriate IIAS Certification option:

• Contact your POS service provider to determine if the POS service provider is a SIGIS certified as a Third-Party Servicer (TPS). If so, apply for SIGIS IIAS Certification by completing an online TPS Client Merchant Form that can be accessed in the SIGIS Members Area of www.sig-is.org.
• If the merchant’s POS software is not certified by a TPS, apply for SIGIS IIAS Certification by completing the Merchant Certification Self-Assessment online form which can be accessed in the Members Area of the SIGIS website at www.sig-is.org.

As the Primary Organization is waiting completion of the SIGIS IIAS Certification process, all registered DBA(s) currently listed on the 90% Rule Merchant List will remain.

Upon completion of the SIGIS IIAS Certification process, the Member should withdraw their 90% Self-Registered form, which will then be removed from the 90% Rule Merchant List.

If a merchant is a Member of SIGIS in good standing (Membership is current and fees are paid) and is a Merchant with a point-of-sale system that utilizes software from a SIGIS Certified Third-Party Servicer (TPS), the merchant can obtain IIAS Certification without technical testing, if your TPS has been certified by SIGIS with the processor / acquirer you use. To initiate IIAS Certification, the Member must complete an online TPS Client Merchant Form.

For step by step instructions on completing the TPS Merchant Certification form please click How to Complete the TPS Merchant Certification.

If a Member is in good standing (Membership is current and fees are paid) and is a merchant with a point-of-sale system utilizing software operated by the merchant or a software provider that is not yet SIGIS-certified, the merchant must complete the Merchant Certification Self-Assessment form to be IIAS certified.

The Merchant Certification Self Assessment must be completed in conjunction with the merchant's processor/acquirer (the company that you are contracted with to accept credit card payments).

 For step by step instructions on completing the IIAS Self Assessment form click How to Complete the IIAS Merchant Self Assessment Form.

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.

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.

To maximize authorization rates, merchants should support partial authorization, rx amount and non-eligible items when implementing an IIAS.

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.

Please see our list of Most Frequent Valid Decline Reasons for why properly formatted IIAS transactions at an IIAS merchant may be validly declined.

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.

Membership termination will result in removal of the merchant’s name from the IIAS Merchant List or the 90% Registration list, depending upon what SIGIS process the merchant may have implemented. In addition, the Member will no longer have access to the SIGIS Members Area or the Eligible Products List. SIGIS will notify Visa, MasterCard and card issuers of the merchant’s suspension and the card issuers will decline FSA/HRA Card transactions at that merchant’s locations because the merchant no longer supports IRS requirements for FSA/HRA card acceptance.

If an active Member is terminated and wishes to become reinstated as a SIGIS Member, a Member must send a check with company name and contact information to SIGIS at:

SIGIS - Special Interest Group for IIAS Standards
111 Deerwood Rd. Suite 200
San Ramon, CA 94583 USA

Please remember to include an additional $50 for the membership reinstatement processing fee.

In accordance to IRS requirements, merchants that accept FSA/HRA cards must demonstrate that their point-of-sale terminal(s) can identify eligible products that may be purchased with these health benefits related card accounts. IIAS Certification is the process by which testing is done to ensure that a merchant’s point-of-sale terminals can distinguish eligible versus non-eligible products and correctly transmit the information for payment authorization at time of a sale in accordance with SIGIS IIAS Standards.

There are two ways for a merchant to complete IIAS Certification:

1. Merchant Certification Self-Assessment
2. TPS Client Merchant Certification Self-Assessment

To assist in determining which SIGIS IIAS Certification is right for a merchant, please contact your POS vendor or the SIGIS Help Desk.