Debit
Cards are the newest convenience in Flexible Spending
Accounts and HRA's. Debit Cards look like a typical
Mastercard credit card, but, in fact, they are stored
value cards. When employees elect to participate
in a FSA or an HRA, the value of their accounts
is credited to the debit card. As the participant
incurs eligible expenses, payments for those services
are deducted directly from their FSA or HRA account
each time the card is swiped. In effect, the participant
no longer has to pay for the eligible expense with
money from their own pocket. The
Debit Card is an option for your Employer to offer
as a part of their Plan. Not all Employers will
choose to offer the card. Employers that do offer
the card may choose to pass on the expense of the
card to the participant.
Many employees shy away from FSA's because
they worry that they will be paying out of pocket
twice; first the pre-tax deduction comes out of
the participant's check, and then the participant
must pay the provider for the service rendered and
wait for their reimbursement check to come. The
debit card eliminates this delimma because the
provider is paid on the spot, directly from the participant's
account.
The IRS requires claim substantiation on all FSA
and HRA expenses. However, if the swipe amount is equal
to your Employer's single co-pay or up to a multiple of 5 times a co-pay
for services rendered, there is no need to submit
a paper claim following the swipe. The IRS has issued
guidance that allows for the match up of such expenses
as sufficient substantiation. For all other
expenses (deductibles, co-insurance,
discount vision plans, over the counter items etc),
you will receive a Receipt Notification from Taxsaver
Plan requesting the receipt to substantiate the
expense. Many stores and pharmacies have implemented a system
referred to as IIAS (Inventory Information Approval System).
When the FSA Debit Card is used at a store that has implemented IIAS,
eligible FSA prescription and Over-the-Counter items are identified at
the point-of-sale as eligible and receipt substantiation will not be
required. If you have attempted to purchase an item the IRS deems as ineligible
OR an item the IRS deems as Dual Purpose, an additional form of payment will be
requested at the register. You may still submit this expense for reimbursement
by completing a claim form (available online). If the expense is considered eligible
under the Plan, a reimbursement will be processed and sent to you.
A receipt is not the credit card proof
of payment receipt, but an itemized statement from
the provider that includes the date of service and
type of service rendered, or date of service and
name of the prescription or over-the-counter items
purchased. You will receive a series of Receipt
Notifications requesting the receipt. If you do
not respond to the requests, your card will be temporarily
deactivated until the swipe has been properly adjudicated.
Generally, you are given 35 days to submit the receipt
requested.
Once you submit the receipt and it is approved,
you will receive an Approval Notification and your
swipe amount will be labeled "complete" when viewed on our
website. It is possible that if you are using your FSA Debit
Card and submitting expenses that you have paid
for out of pocket at the same time, the expenses
that you submit for reimbursement will be held in
your account until your debit card receipt is submitted.
This will also generate an Approval Notification
but the swipe amount will show "pending" on our
website. As soon as you send in the receipt for
the FSA Debit Card swipe, the receipts that you submitted
for reimbursement will be sent to you on your Employer's
next scheduled reimbursement day. If you do not
have the requested FSA Debit Card receipt or the
expense that you paid for with your FSA Debit Card
is not eligible under the Plan, the non-debit card
expense will be used to adjudicate and keep the
card active. You may also send in a check made payable
to your Employer to adjudicate a FSA Debit Card
expense when your receipt is lost or the expense
is not eligible under the Plan.
Debit cards can only be used at providers with certain
eligible merchant codes. You may use a provider
that is eligible under the Plan, but the merchant
code assigned to that provider is not an eligible
merchant code. In this circumstance, you will need
to pay for the expense out of pocket and submit
the receipt for reimbursement. Non-approved merchant
codes will block you from improper use of the card.
Should an ineligible expense slip through at the
point of swipe, the ineligible expense will be reported
to Taxsaver Plan within 24 hours of the swipe, and
you will be sent a request to reimburse the Plan
for the ineligible expense. It is also possible
that the provider will be assigned an eligible merchant
code, but the merchant code may not match to the
provider co-pay under the health plan. For instance,
you will visit the doctor and pay your co-pay, but
when the swipe comes through the system, your doctor's
merchant code will be a hospital merchant code,
not one assigned to a doctor's office. In this circumstance,
your card will be accepted but you will be requested
to submit a receipt for the expense even though
the co-pay amount matches the health plan.
Taxsaver Plan realizes that not all providers accept
credit cards. If you use a provider that does not
accept credit cards, you will be able to submit
your claims and then a check or direct deposit will
be issued to you. The amount of the check or direct
deposit will be deducted from the balance in your
account, making sure that you are not reimbursed
for more than you have elected in your FSA or have
contributed to you in your HRA.
At midnight on the last day of the Plan Year, the
card will be turned off for FSA accounts. Any claims
directly submitted during the runoff period will
be reimbursed by a check or direct deposit. For
HRA account accounts, your card will remain active
from Plan Year to Plan Year, as long as you have
a balance to carry forward. As long as you re-elect
a FSA for the new plan year, the card will be activated
with your new election as soon as your first deduction
for the new Plan Year is taken. If you do not elect
a FSA in the new Plan Year, then the card will stay
inactive.
If you terminate during the Plan Year, the card
will be turned off as soon as your termination is reported to
Taxsaver Plan. Therefore, any expenses incurred that had not been
reimbursed with a swipe would need to be submitted
for reimbursement with a check or direct deposit.
After your Employer's run-out period has ended, a report will be
released that identifies those participants with remaining un-substantiated
FSA Debit Card transactions from the prior year. Under IRS regulations, your
Employer is required to take action on the un-substantiated amounts. You
can expect to be contacted by your Employer, or Ex-Employer if you have been
terminated during the year in regards to these amounts. We STRONGLY suggest
that you keep your account in good standing to avoid a 1099 or other form
of action.
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