The IRS requires that every transaction made with any type of Flexible Spending Account prepaid debit card, like your Debit Card, must be substantiated in order to confirm that the cardholder is using the Card to pay for an eligible FSA expense. The IRS considers many expenses paid with the Debit Card to be automatically substantiated at the point of sale. For example, if you use your Debit Card to pay a copayment amount for a prescription, the expense may be automatically substantiated if your plan’s copay amount is identified in the Debit Card System. In this instance you do not have to separately submit a receipt for the copayment amount for substantiation.
Many expenses cannot be substantiated at the point of sale, and IRS regulations require cardholders to submit supporting documentation in order to verify the transaction. Examples of expenses that may not automatically substantiate include dental, chiropractor and physician office visits where the amount paid is not equal to an established copay amount that is recognized in the Debit Card System, and situations in which you charge more than on copay expense in the same Debit Card swipe.
If you use your Debit Card for an expense that cannot be automatically substantiated at the point of sale, the merchant will be paid for the expense, but you MUST provide documentation to verify that the purchase is an appropriate FSA expense.
You will be required to submit substantiation to Benefit Allocation Systems, LLC. (“BAS”) in order to validate the eligibility of the expense in accordance with IRS guidelines.