Short answer: Yes. Most FSA expenses require documentation, although some purchases are automatically substantiated at the point of sale. If documentation is requested and not provided, your FSA card may be suspended.
In many cases, employees must submit receipts or other proof to show that Flexible Spending Account (FSA) funds were used for eligible expenses. This requirement comes from federal substantiation rules and applies whether the expense is reimbursed manually or paid using an FSA debit card.
Using an FSA debit card
Some transactions are automatically substantiated at checkout, particularly at pharmacies, medical providers, or merchants that use approved inventory systems and merchant category codes. These systems can confirm that the item or service is FSA-eligible without additional documentation.
However, not all transactions qualify for automatic substantiation. If an expense cannot be verified electronically, the FSA administrator may request supporting documentation. If the required proof is not provided within the allowed timeframe, the card transaction may be reversed or the card temporarily suspended.
Submitting a manual claim
When submitting a reimbursement request, documentation is almost always required. Acceptable proof generally includes an itemized receipt or an Explanation of Benefits (EOB) showing:
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Date of service or purchase
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Name of the provider or merchant
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Description of the item or service
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Name of the individual receiving care (if applicable)
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Amount paid
Credit card statements or canceled checks are not sufficient on their own because they do not show what was purchased.
Deadlines and consequences
Most FSA plans include a run-out period—often 60 to 90 days after the end of the plan year—during which employees can submit claims for expenses incurred during the prior year. If documentation is not provided when required, the employee may need to repay the amount, have future reimbursements offset, or have their FSA debit card suspended until the issue is resolved.
Best practice is to retain receipts and EOBs for all FSA purchases, even when a transaction is initially approved. Many FSA administrators offer mobile apps that allow receipts to be uploaded immediately.
FSA substantiation rules are administered by the Internal Revenue Service.
Sources
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Internal Revenue Service, Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans
https://www.irs.gov/publications/p969 -
Internal Revenue Code, Section 125
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IRS FAQs for Cafeteria Plans (government entities)
https://www.irs.gov/government-entities/federal-state-local-governments/faqs-for-government-entities-regarding-cafeteria-plans
Content history
Originally published: March 25, 2025
Last reviewed: January 25, 2026