Benny™ Card Substantiation Requirements PDF Print
  • The Benny™ Card is a tool for Medical FSA claim payments.  It protects your cash flow, BUT the process is not paperless.  Therefore, it is important for participants to save receipts from ALL card transactions.

  • IRS Revenue Ruling 2003-43 governs substantiation requirements for debit card use and dictates that “charges other than matched co-payments, recurring expenses and real-time substantiation are treated as conditional pending confirmation of the charges through additional third-party verification.”

  • GDI will mail participants a letter requesting documentation for services  that require substantiation.
  • IRS regulations require card de-activation if the required documentation is not received by the date indicated in the letter.

The chart below displays the types of situations where substantiation will be required and those where no follow up is required.

Type of Charge on Benny™ Card

Substantiation Required

No Follow-up Required

Matched Co-pays

Transactions at “IIAS Vendors

Recurring Expenses

1 time only

No further substantiation required if subsequent transactions are at the same merchant for the same dollar amount.

Dental Care

Vision Care

Medical Care