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 (Included TPS Merchant)
|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.
Issuer/issuer processors utilize the IIAS data fields in authorization request transactions to approve and auto-substantiate eligible health care amounts. Issuers/issuer processors support a list of 90% Rule merchant locations during authorization processing.
|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:
|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.
|Includes but not limited to the following:
|Only the following:
|Cardholder Transaction Receipt Requirements
|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.
|Annual Process Requirements
|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.