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IRS Provides Further Guidance on Use of Debit and Credit Cards for FSAs and HRAs
McDermott Will & Emery 
July 20, 2006
Excerpt: In the ruling, the IRS provided three methods (co-payment match, recurring expenses and real-time substantiation) a plan sponsor could adopt to substantiate claimed medical expenses under Internal Revenue Code Section 213(d) after a participant uses a debit or credit card.
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