I have heard that if a merchant can qualify its stores under the 90% Rule that FSA/HRA cardholders will not need to submit sales receipts to their plan administrator. Is that correct?
Generally, no. Unlike an IIAS where the merchant substantiates the items being purchased at the point of sale, the 90% Rule indicates that stores that qualify as 90% locations can be viewed as “healthcare merchants.” This means that plan administrators will apply their standard substantiation processes to transactions at these locations – and the customer may be asked to submit a sales receipt to document that the items being purchased were prescriptions/Rx or Eligible Healthcare Products. It is possible that in some cases the card issuer processor will be able to match a transaction amount with Pharmacy Benefit Management (PBM) system information, and can determine that the card transaction amount matches the plan’s co-pay on prescriptions, for example. In this case, the customer may not be asked to submit a sales receipt. But in the absence of an automated matching program like this, it is likely that customers using a FSA/HRA card will be asked by their plan administrator to submit
