The IRS-endorsed methods of auto-substantiation are:
Inventory Information Approval System (IIAS)
IIAS is a voluntary standard that merchants use to comply with IRS substantiation requirements. For example, if you use your card to buy FSA-eligible items at a grocery, discount store or pharmacy, your purchase will be automatically substantiated if that store uses an IIAS system. You will be asked to use a different form of payment for the non-eligible items. Non-health care merchants and pharmacies that choose not to implement an IIAS cannot accept the card for payment of any items. Most merchants have already implemented this system, but for a complete list of participating locations, please visit sig-is.org.
Copay Logic
When you use your card, the system matches the transaction amount to your copay amounts, which were supplied by your employer group.
Recurring Expense Logic
After a transaction has been substantiated once, transactions for the same amount in the same setting do not require another review for the next 12 months. For example, if you make a monthly payment for the same amount to an orthodontist, subsequent payments may be auto-substantiated once the first payment is substantiated in accordance with the IRS guidelines.
Data File Feeds
The debit card system attempts to match your card transaction data to medical, dental and vision data received from UMR. Data matching requires the debit card transaction amount to exactly match the patient responsibility amount (less any ineligible amounts) on your EOB.