Participants who pay for expenses using a health flexible spending account (FSA) debit card benefit from many expenses being automatically substantiated. However, some of these must be substantiated after payment, and without substantiation participants risk having their card deactivated. Does the IRS give any leeway for expenses under a certain amount? The answer is unfortunately “no”. There are several steps employers must take when participants have unsubstantiated expenses, as failure to substantiate could result in the plan’s losing its tax-favored status.