FSA Debit Card - Background

Background

Though these cards can be issued with HRAs and HSAs as well as FSAs, the FSA is the oldest and most common of these accounts; therefore, for simplicity these cards are often referred to as "FSA" debit cards. Walgreens and drugstore.com have "FSA stores" designed for use with these cards, whether tied to medical FSAs, HRAs or HSAs.

Though a few FSA debit cards are also issued for dependent care and transportation expenses, most are issued for medical expenses. (The rest of this article deals only with FSA debit cards used with medical FSAs, HRAs or HSAs.)

Traditionally, to meet Internal Revenue Service (IRS) substantiation requirements, FSAs were accessed only through claims for reimbursement after incurring (and usually paying) an out-of-pocket expense, often after deductions were already made from the employee's paycheck to fund the FSA; this is commonly known as "double-dipping". This, along with the so-called "use it or lose it" rule (i.e., all funds not spent are forfeited), has long been seen as one of the problems minimizing utilization of FSAs.

The FSA debit card was developed to avoid this problem by allowing users to access their FSA directly without "double-dipping", and also (where possible) to provide methods for automating the IRS substantiation requirements which often require substantial paperwork and manpower. Substantiating an FSA debit card transaction without paperwork is known as "auto-adjudication".

HRAs, which were introduced later, technically don't involve "double-dipping" because they are funded by employer funds, not by employee funds; however, they are subject to the same IRS requirements as FSAs, and thus are generally accessed only by paper claims or debit cards just like FSAs.

Unlike FSAs and HRAs, HSAs do not require substantiation prior to withdrawal; users need only retain their receipts with their tax papers. However, since most HSA providers came from FSA and HRA backgrounds, most offer substantiation services for HSAs that are similar to those for FSAs and HRAs. Though many HSA providers offer unrestricted debit cards and even credit cards with their accounts, some voluntarily choose to issue FSA debit cards and impose the same restrictions on their use as those required by the IRS for FSAs and HRAs.

Flexible Spending Accounts (FSAs), commonly referred to as “Section 125” plans or “Cafeteria” plans, were developed as part of Internal Revenue Code Section 125 to provide employees with tax relief for their un-reimbursed medical and dependent day-care costs. FSAs enable employees to utilize pre-tax dollars and save Federal, FICA, and, in most cases, state taxes when paying for eligible expenses not covered by traditional insurance plans.