Health Savings Account Cards
Special Interest Group for IIAS Standards (SIGIS) is a non-profit, membership corporation that is responsible for the development and management of an industry standard to meet IRS requirements for operating an inventory information approval system (an “IIAS”). SIGIS assists merchants, plan administrators, acquirers, card issuers, and processors to help support IRS requirements for FSA/HRA card programs.
IIAS Merchant Certification Program
The IRS requires plan administrators to approve FSA/HRA debit card transactions from a non-health care merchant only when the merchant supports an Inventory Information Approval System (IIAS). The IIAS system is a combination of inventory management and POS systems that manage the following three functions:
Confirms the health care eligibility of items purchased with a FSA or HRA card, by accessing eligibility flags in the merchant’s inventory database when merchandise is purchased with a FSA/HRA card.
Generates a payment transaction that contains the required IIAS information.
Supports an information archive system that allows the merchant to respond to an IRS audit as required.
In addition to supporting a system capable of handling IIAS transactions, a merchant must also join SIGIS by completing a Membership Agreement, a Merchant Self-Assessment and Checklist, and Certification with their acquirer.
Merchants that elect to implement an IIAS using the standard published by SIGIS must become members of SIGIS and be certified by SIGIS prior to sending IIAS transactions in the SIGIS-standard format.
Certification requires the following:
- Completion of an IIAS Merchant Self-assessment.
- Technical testing certification by the merchant’s acquirer.
- Use of the SIGIS Eligible Product List.
- Arrangements to support transaction data retention/retrieval.
A merchant’s acquirer will review the IIAS Merchant Self-assessment and submit it to SIGIS for approval. A merchant 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.
Merchants that are clients of a certified third-party service provider may use a simplified certification form.
To obtain a copy of the SIGIS IIAS Technical Specification, SIGIS Members may login to the Members Areaopen_in_newLink opens new window and download a copy.
IIAS Merchant Control Number
After completing a TPS Merchant certification, SIGIS notifies the merchant, its acquirer and payment card networks (MasterCard and Visa). Upon receipt of the IIAS certification confirmation, the acquirer may request each payment card network to assign an IIAS merchant control number. This number must be included in payment card authorization request messages in addition to the IIAS data fields provided by merchant/acquirer.
MasterCard - the merchant control number is called a MasterCard ID (MCID).
Visa - the merchant control number is called a Merchant Verification Value (MVV).
<noteStyle>SIGIS does not assign the MCID or MVV. The assignment of the MCID or MVV can only be done by the respective payment card network, after the card network receives the request from the merchant’s acquirer.</noteStyle>
Register as a 90% Rule Merchant
To register as a 90% Rule merchant, merchants must first be a SIGIS Member in good standing and have paid its membership fee. The merchant will then be able to access the Members Areaopen_in_newLink opens new window of the SIGIS website to complete the 90% Rule registration for each of the merchant’s eligible store locations. The SIGIS 90% Rule Program Implementation Procedures are also available in the Members Area. This contains information for merchants, acquirers, plan administrators, issuers, and processors about the 90% Rule program.
For Plan Administrators, while offering FSA/HRA cardholders the opportunity to use their cards at registered 90% Rule merchants is optional, it is a way to increase the convenience and usability of an FSA/HRA card program. Transactions at 90% Rule stores are not auto-substantiated and plan administrations will need to follow their policies for substantiation of such purchases, most likely asking cardholders to forward their sales receipts.
IIAS Versus 90% Rule Comparison
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 (Includes 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. |
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: |
Use the SIGIS Eligible Product List to flag eligible health care items in merchant’s inventory.
Change payment card processing to add FSA amounts to transactions.
Support a list of FSA/HRA BINs to identify card numbers to add IIAS data fields.
Store transaction detail for approved FSA/HRA card transactions in the event of an IRS audit.
|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:
Various MCC – Other Non-Healthcare Merchants
|Only the following:|
|Cardholder required to submit a transaction receipt to plan administrator||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 processes||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.|
|For more information||For merchants that operate their own inventory and cash register software, see IIAS Merchant Certification. |
For merchants that contract with a POS vendor/third-party servicer, see TPS Merchant Certification.
|For drug stores/pharmacies that sell primarily prescriptions and eligible medical items, see 90% Rule Merchant Attestation.|