The IRS Notice 2006-69 allows for auto-adjudication for an additional category of claims under the merchant based inventory information approval system (IIAS). As described below, under such an arrangement, a real-time determination is made by the merchant at the point of sale of the amount of eligible medical expenses by comparing the selected items to a pre-approved list. No additional substantiation is required if a merchant compares the item or items to a pre-determined list maintained by the merchant of items sold by the merchant that constitute Code Section 213(d) expenses and restricts use of the Card only to those items that fall on that list. However, as noted below, the employer (or its TPA) must have access to claims level detail provided at the time of the transaction or a later date.

The IIAS system approves the use of the Card only for eligible medical care expenses; when a transaction is not approved in full, the employee must tender additional amounts, resulting in a split-tender transaction.

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Employers are always looking for new ways to motivate their employees. Many employers are looking at gift cards as an additional option for employee incentives. This trend is growing rapidly.

Another trend is the use of prepaid debit cards for payment of wages to employees. Many employers have used electronic payments (direct deposit) for years for meeting their payroll needs. Unfortunately many employees do not have bank accounts and so direct deposit was not a viable method of payment for all. Now many employers are offering the option of payroll cards. Prepaid payroll cards create cost savings by reducing lost or stolen check replacements, bank processing and handling fees, check fraud, and check printing costs.

As electronic payments takes place on a national scale in employee reward programs and as a method for delivering wages, we have also seen electronic payment cards used as a method of payment from various employee health care accounts.

With the migration towards consumer driven health care and the effort to make consumers more accountable for their health care choices, we have seen the introduction of the flexible spending accounts (FSAs), health reimbursement arrangements (HRAs) and health savings accounts (HSAs). The benefit to employees of participation in one or more of these flex accounts is tax savings.  

The adoption of electronic payment cards for use with various consumer driven health care accounts to expedite claims processing has been proven to show a marked increase in participation by employees. With the addition of Information Inventory Approval Systems (IIAS) which will reduce the amount of paper claims required for substantiation of expenses, the use of the health debit cards is likely to increase. Participant’s appreciate having their claims paid sooner (at the point-of-sale) rather than later (days or weeks after the expense was incurred). Increase of participation in consumer driven health care accounts results in a greater tax savings for employer.

For more information on how DataPath’s electronic payment cards can benefit you, please contact Sales at sales@dpath.com