Participants experience substantiation as friction. Administrators experience it as the thing that keeps a cafeteria plan or HRA from turning into taxable taxable chaos.
What “good” looks like
- Claims have a date of service, description, and proof of cost
- Duplicate claims across FSA and HRA get caught
- Card transactions that fail auto-substantiation are worked on a defined timeline
- Dependent care claims include provider identification
What “hope-based compliance” looks like
- Paying whatever hit the debit card because the employee is executive-level
- Accepting credit-card summaries with no itemization for ambiguous merchants
- Letting undocumented claims age until year-end “cleanup”
Midyear reset
If your denial rate suddenly dropped to near zero, don’t celebrate until you know why. It might be better merchant data — or it might be a queue nobody is reviewing.
Tax-favored accounts earn their tax favoritism by being picky. Your TPA should be politely picky on your behalf. That’s not bad service; that’s the job.