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)||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.
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.
|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:
||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:
||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.||Not required.|
|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.|