the difference that the employee has spent from the flexible spending account but not yet contributed if other employees' contributions do not account for the money spent. The amount the employer loses due to pre-funding may eventually be partially, totally, or more than made up by employees that do not spend all of the money in their FSA account by the end of the plan year and grace period (see above). Over-the-counter drugs and medical items Another FSA feature that was introduced in 2003, is the ability to pay for over-the-counter (OTC) drugs and medical items. In addition to substantially expanding the range of "FSA-eligible" purchases, adding OTC items made it easier to "spend down" medical FSAs at year-end to avoid the "use it or lose it" rule. However, substantiation has again become an issue; generally, OTC purchases require either manual claims or, for FSA debit cards, submission of receipts after the fact. Most FSA providers require that receipts show the complete name of the item; the abbreviations on many store receipts are incomprehensible to many claims offices. Also, some of the IRS rules on what is and isn't eligible have proven rather arcane in practice. The recently developed inventory information approval system (IIAS), separates eligible and ineligible items at the point-of-sale and provides for automatic debit-card substantiation. Effective January 1, 2020, over-the-counter medicines are allowable without a prescription or a note from a physician. In addition, menstrual care products are also allowable. The change was made as part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Eligible Medical Item List The IIAS system references a master eligibility list of FSA eligible products at the point of sale. The Special Interest Group for IIAS Standards (SIG-IS) maintains this eligibility list and updates it on a monthly basis. The FSA Eligibility List includes items within eligible healthcare product categories determined by the IRS. Health Savings Accounts share the same medical item eligibility list as FSAs. According to section 9003(c) of the Patient Protection and Affordable Care Act, as of January 1, 2011, drugs needed to be prescribed to be reimbursable. That requirement was lifted, effective January 1, 2020. Use it or lose it A potential drawback is that the money must be spent "within the coverage period" as defined by the benefits cafeteria plan coverage definition. This coverage period is usually defined as the "period that you are