IIAS Certification

  • As an Acquirer, how do I update the TPS Merchant Certification contact email address?

    Acquirers receive an email when a merchant submits a certification form.  If an Acquirer needs to change the email address that receives those notifications they will need to Log In to their SIGIS account and access the Certification form link on the right side of the page.  Under the Contacts sections a contact can be selected or deselected to receive email notifications. In addition, a generic email can be added to receive the notifications.


  • How often is the SIGIS Member Networks list updated?

    SIGIS will post an updated member network list on a weekly basis.


  • How can a 90% Rule Registration or IIAS Certification status be confirmed?

    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..



  • Why do TPAs see some transactions with an Rx Amount and some without?

    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.


  • Where does a merchant get equipment to support the IIAS? Who installs it? Who do I call?

    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.



  • As a TPS, How do I update the TPS Merchant Certification contact email address?

    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.



  • At times, we see that FSA or HRA cards may work at some stores of a certified merchant, but not at other store locations. What could cause that?

    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.


  • What if there is a change to an Acquirer/Processor after Certification?

    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.)



  • Does a merchant need to implement an IIAS system based on its merchant category code (MCC)?

    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.



  • Does SIGIS sell the software or equipment necessary to run an IIAS?

    SIGIS does not make or produce hardware or software. SIGIS is a non-profit, standards organization that works with merchants, their acquirers, issuer/processors and plan administrators to develop consistent standards for the initiating and authorization of FSA/HRA debit card transactions. SIGIS does provide for Third-Party Servicer/POS certification for IIAS systems, please check our website for a list of Third-Party Servicer solutions that have been certified. In addition, SIGIS provides Members with the Eligible Product List that is used to identify eligible health care products in a merchant's inventory when supporting IIAS systems. Lastly, it is suggested that merchants contact their payment card processor for information about how to support an IIAS and which Third-Party Servicers have been certified with their acquirer.


  • Does SIGIS support IIAS and 90% Rule processes for US Territories?

    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.



  • How can a TPS update an approved Certification that has approved merchants?

    TPS’s that wish to update a certification that has approved merchants should contact SIGIS at help@sig-is.org.  The TPS will be asked to complete the “TPS Change Questionnaire” document.  Upon review, the TPS will instructed on required steps.  In some cases a simplified process may be available so as to not impact the approved merchants. Each situation will be evaluated based on the info provided in the TPS Change Questionnaire document.


  • How do I add or remove locations to the Store Locator for my TPS Merchant or IIAS Certification?

    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.


  • How can I change my 90% Registration to an IIAS Certification?

    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.



  • How to complete a TPS Client Merchant Form?

    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.



  • How to complete the Merchant Certification Self-Assessment Form?

    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.



  • If a merchant implements IIAS, is it at all their registers?

    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.


  • If a merchant implements the SIGIS IIAS standard, is there a guaranteed 100% acceptance of the health care debit cards in the marketplace?

    While an IIAS system is required for non-health care merchants to accept FSA and HRA cards under the IRS guidelines, a merchant that implements an IIAS solution is not guaranteed 100% acceptance of all FSA/HRA cards. SIGIS Member card issuers/processor and the majority of their third-party plan administrator clients supporting FSA and HRA cards have enabled SIGIS IIAS processing to authorize and auto-substantiate transactions; however some employer benefit plans may require a level of transaction detail that is not supported with an IIAS solution, thereby, preventing acceptance even at merchants with a fully certified IIAS solution. To maximize authorization rates, merchants should support partial authorization, RX amount and non-eligible items when implementing an IIAS. In addition, normal decline issues can occur for expired cards, insufficient funds, cards not activated and other business reasons.


  • If a merchant’s stores meet the 90% Rule, is it OK to support an IIAS?

    Yes. Many drug stores/pharmacies already support IIAS capabilities. If merchants support an IIAS, they don't have to worry about annually qualifying the gross sales of each store for the 90% Rule. Additionally merchants will benefit from higher card authorization rates and consumers will benefit from the auto-substantiation of IIAS transactions.


  • Can IIAS Certified Merchants experience declines of FSA-HRA transactions?

    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.



  • Is a Merchant required to make IIAS changes to accept FSA/HRA cards?

    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.



  • How do I obtain a Card Network Merchant Identification Number?

    Upon notification of completion of the SIGIS IIAS Certification Process, a merchant should follow up with its acquirer/processor to obtain the card network's transaction control id numbers. The acquirer/processor is the only entity able to retrieve these numbers. A merchant must obtain these identification numbers before FSA/HRA Card transactions will process correctly.


  • The cardholder swiped their card, but the TPA does not see a transaction, why?

    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.


  • What about a merchant’s data retention requirements?

    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.


  • What happens to a merchant’s certification status if its Membership is terminated?

    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.



  • What is an “inventory information approval system” as specified by the IRS?

    An IIAS requires a merchant’s point-of-sale system to have the ability to verify that the merchandise being purchased with a FSA/HRA card is an eligible medical expense, as defined by the IRS. The merchant’s system compares the inventory control information (e.g., UPC or SKU number) of items being purchased against a pre-established list of eligible medical products. The list is limited to eligible medical expenses as described in Section 213(d) of the Internal Revenue Code, including eligible non-prescription items. The merchant’s system totals the eligible medical expenses and transmits this information to the payment card issuer for approval, subject to coverage under the health plan (i.e., type of coverage provided, covered participant, etc.). Thus when a merchant supports an IIAS, consumers are not able to use FSA/HRA card funds to purchase merchandise unless the items qualify as eligible medical expenses.


  • What is Certification?

    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. 



  • How does a POS Vendor seek certification?

    To become IIAS certified, a POS vendor completes a similar IIAS certification process as merchants. This requires completion of a TPS Self-Assessment Certification Form, a technical testing certification by the TPS’s acquirer, use of the SIGIS Eligible Product List, and arrangements to support transaction data retention/retrieval. A TPS's acquirer will review the TPS Self-Assessment Certification Form and submit it to SIGIS for approval. A TPS will not be permitted to claim that it supports IIAS transactions using the SIGIS standard until it has been certified to the IIAS standards developed and approved by SIGIS. 

    For step by step instruction on how to complete the TPS Self Assessment please click Completing the TPS Self-Assessment form.