unrestricted debit cards and even credit cards with their accounts, some voluntarily choose to issue HSA 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. Where FSA debit cards may be used Unlike other debit cards, the IRS does not allow FSA debit cards to be used at every merchant that accepts Visa or MasterCard. Rather, only the following types of merchants may accept an FSA debit card, usually enforced using "merchant category codes" or "merchant type codes" assigned by Visa and MasterCard: Medical providers such as doctors and hospitals. Merchants with an inventory information approval system (IIAS). In an IIAS, a merchant flags "FSA-eligible" items in its point of sale database so they can be separated from all other items by its scanner (brick-and-mortar) or shopping cart (online); it then permits only the "FSA-eligible" items to be charged to the card, with another form of payment required to purchase all other items. Until December 31, 2007, all grocers, discounters, and online pharmacies. These merchants must install an IIAS to accept the card after this date. Until December 31, 2008, all "true pharmacies" (i.e., those not located inside grocery or discount stores and not online). They must install an IIAS after this date, unless 90% or more of their sales are of FSA-eligible items (prescriptions or over-the-counter items). IRS requirements Under IRS Revenue Ruling 2003-43, every transaction on an FSA debit card must be either substantiated or recouped from the employee. Substantiation can be through either electronic evidence (auto-adjudication) or paper receipts submitted by the user (similar to paper claims). The process of obtaining receipts or recoupment when auto-adjudication is not possible is known as "pay and chase", a term the IRS also used in its most recent ruling (Notice 2007-02). The most common method of auto-adjudication is known as "copay matching". Under Ruling 2003-43 as amplified by Notice 2006-69, the FSA or HRA provider must obtain from the employee's health plan the