Cardholder
- How can we get more information?
- If a merchant can qualify its stores under the 90% Rule, will customers that pay with a FSA/HRA card need to submit sales receipts to their plan administrator?
- If a merchant implements the SIGIS IIAS standard, is there a guaranteed 100% acceptance of the health care debit cards in the marketplace?
- What if a plan administrator and/or consumers have questions or inquiries about a possible error with the SIGIS 90% Rule merchant information, who will address the questions?
- Will a merchant’s store name be listed on the SIGIS Merchant List?
- Will all FSA/HRA plan administrators permit their clients to use FSA/HRA cards at 90% Rule merchants?
- Does SIGIS support IIAS and 90% Rule processes for US Territories?
- Can a foreign company become IIAS certified or 90% registered merchant?
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How can we get more information?
Plan administrators should contact their card issuer or processor, and merchants should contact their acquirer. Card holders should contact their Plan Administrator. Contact us for membership information.
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If a merchant can qualify its stores under the 90% Rule, will customers that pay with a FSA/HRA card need to submit sales receipts to their plan administrator?
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.
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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.
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What if a plan administrator and/or consumers have questions or inquiries about a possible error with the SIGIS 90% Rule merchant information, who will address the questions?
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.
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Will a merchant’s store name be listed on the SIGIS Merchant List?
SIGIS has two merchant lists: first, the SIGIS IIAS Merchant List for merchants that are SIGIS-certified to process IIAS transactions, and second, the SIGIS 90% Rule Merchant List for merchants that have registered with SIGIS as meeting the IRS requirement as a store with 90% or more of gross sales from Rx/prescription and qualified medical products.
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Will all FSA/HRA plan administrators permit their clients to use FSA/HRA cards at 90% Rule merchants?
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.
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Does SIGIS support IIAS and 90% Rule processes for US Territories?
US Territories US Virgin Islands (USVI), Guam, Commonwealth of 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), Guam and Commonwealth of the Marianas Islands/Saipan (CNMI) 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 for residents. SIGIS supports merchants in this market serving non-residents with valid debit cards from other supported tax regions due to similar Food and Drug Administration dispensing regulations and large retailers who have implemented systems that include IIAS and 90% Rule functionality.
American Samoa has a combination of US and Local tax laws in effect. Further research is required to determine if Section 125 applies in this market and the impact of local tax laws. At this time, SIGIS does not support this market.
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 May 28th, 2025.
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Can a foreign company become IIAS certified or 90% registered merchant?
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.