Bills › 91st General Assembly
Relating to utilization review organizations’ use of artificial intelligence, prior authorization determinations and exemptions, and audits, and including applicability provisions
Sponsored by the Senate Health and Human Services Committee
Topics:Health careInsuranceTechnology & privacyArtificial intelligence
Where it is now
- Done: IntroducedFebruary 5, 2026
- Done: SubcommitteeFebruary 5, 2026
- Done: Senate committeeFebruary 19, 2026
- Done: Passes the SenateMarch 4, 202644–0
- Skipped: House committeeSkipped
- Done: Passes the HouseMarch 3, 202694–1
- Done: To the GovernorMay 6, 2026
- Done: Signed into lawMay 13, 2026
HF 2635 became law → The same legislation passed as HF 2635, so this version was set aside. Go to HF 2635 What’s a funnel?
What’s in it
AI summary Health insurance companies and review organizations can use artificial intelligence to help review medical requests, but a human must make the final decision to deny or change a service. This law also stops insurance companies from requiring special permission for certain cancer screenings or for treating life-threatening conditions that appear while a person is already in the hospital. Additionally, new rules require companies to follow specific timelines and notification steps when auditing medical claims.1
Read the official explanation
This bill relates to utilization review organizations’ use of artificial intelligence, prior authorization determinations and exemptions, and audits. DIVISION I —— PRIOR AUTHORIZATION —— USE OF ARTIFICIAL INTELLIGENCE AND PEER REVIEW. Under the bill, a utilization review organization (URO) may use an artificial intelligence-based algorithm to provide an initial review of a request for prior authorization (authorization), except that, for a request for a health care service (service) based on medical necessity, a URO shall not use an artificial intelligence-based algorithm as the sole basis for a decision to deny, delay, or downgrade the authorization request. “Downgrade” is defined in the bill. A URO shall not deny or downgrade a request for authorization unless the decision is made by a qualified reviewer or clinical peer and the URO provides the health care provider (provider) requesting authorization a written statement citing the reasons for the decision, explaining the appeals process, and a written attestation as described by the bill. If a request for authorization is denied, the URO shall notify the provider within seven days and conduct a consultation as described by the bill. “Clinical peer” and “qualified reviewer” are defined in the bill. If a URO’s decision to deny or downgrade a request for authorization is appealed by the requesting provider or covered person (person), the appeal shall be conducted by a qualified reviewer or clinical peer who was not involved in the initial denial or downgrade. When conducting an appeal, the qualified reviewer or clinical peer shall consider the known clinical aspects of the services under review. The commissioner of insurance (commissioner) may adopt rules to administer this division of the bill. This division of the bill applies to requests for authorization made before January 1, 2027, if the request has not been finally determined on or before that date, and requests for authorization made on or after January 1, 2027. DIVISION II —— PRIOR AUTHORIZATION —— CANCER-RELATED EXEMPTIONS. A health carrier (carrier) shall not require authorization for, or impose additional utilization review requirements on, a person for a cancer-related screening (screening) if the screening is recommended by the person’s health care professional (professional) based on the most recently updated national comprehensive cancer network clinical practice guidelines in oncology. The director of health and human services shall adopt rules, and the commissioner may adopt rules, to administer this division of the bill as detailed in the bill. This division of the bill applies to health benefit plans (plans) delivered, issued for delivery, continued, or renewed on or after January 1, 2027, and requests for authorization for a screening recommended by a person’s professional if the request is made before January 1, 2027, and has not been finally determined on or before that date. The bill also applies to such requests made on or after January 1, 2027. DIVISION III —— PRIOR AUTHORIZATION —— LIFE-THREATENING HEALTH CONDITIONS. A carrier shall not require authorization for, or impose additional utilization review requirements on, a person for diagnosis and treatment of a health condition (condition) that develops or becomes evident while the person is receiving treatment at an inpatient facility and is reasonably determined by a professional to be a life-threatening condition unless the person receives immediate assessment and treatment. The commissioner may adopt rules to administer this division of the bill. This division of the bill applies to plans delivered, issued for delivery, continued, or renewed on or after January 1, 2027, and requests for authorization for diagnosis and treatment of a condition that develops or becomes evident in a person while receiving treatment at an inpatient facility if the condition is life-threatening unless the person receives immediate assessment and treatment, the request is made before January 1, 2027, and the request has not been finally determined on or before that date. DIVISION IV —— UTILIZATION REVIEW ORGANIZATIONS —— AUDITS. A carrier or URO that conducts an audit shall notify the provider that submitted the claim of the initiation of the audit no later than 15 days after the carrier selects the claim for audit. “Audit” is defined in the bill. A carrier or URO shall complete an audit and issue a determination to the provider no later than 45 days after the carrier or URO receives all documentation regarding the claim from the provider. A provider who submitted a claim that is the subject of an audit and who receives an adverse determination regarding the claim may appeal it no later than 30 days after the provider receives the determination. A carrier or URO shall consider an appeal and issue a final determination no later than 14 days after receiving notice of an appeal. If a carrier or URO violates the bill, the claim shall be automatically approved by the carrier or URO and promptly paid, including interest. The commissioner may adopt rules to administer and enforce this division of the bill. This division of the bill applies to audits initiated on or after January 1, 2027.
Why it matters. Utilization review organizations and health carriers would be prohibited from using artificial intelligence as the sole basis for denying, delaying, or downgrading medical necessity requests, and they must instead use a qualified reviewer or clinical peer for such decisions. Health carriers would also be barred from requiring prior authorization for certain cancer screenings or for the treatment of life-threatening conditions that develop while a person is in an inpatient facility. The fiscal impact of these changes cannot be determined, though the bill may increase administrative costs for the State of Iowa and Board of Regents university plans.2
Changed since by amendments S-5067, S-5060, H-8080; see Amendments.
Senate subcommittee
Named February 25, 2026. On March 2, 2026 it recommended passage.
Three legislators hear a bill first and recommend what the committee should do; it’s the best time to weigh in. How to take part
Fiscal note
AI summary This bill sets new standards for health insurance companies regarding how they use artificial intelligence, conduct audits, and handle prior authorization requests. It may increase costs for the State of Iowa and Board of Regents university health plans due to new administrative requirements and changes to how medical necessity is determined. While the bill could increase revenues for the University of Iowa Health Care as a provider, the exact fiscal impact on these entities is unknown but may be significant.4
Read the fiscal note
Description
House File 2635 relates to health carriers standards of conduct; utilization review organizations (UROs), artificial intelligence (AI), audits, and prior authorizations; certificate of need processes; and includes applicability provisions. The Bill has four divisions, three of which have a fiscal impact and one of which does not.
The following divisions of the Bill have or may have a fiscal impact and are described in further detail below:
- Division I — Health Insurance Trade Practices
- Division II — Prior Authorizations
- Division III — Prior Authorizations — Medical Assistance Program
Division IV — Certificates of Need has no fiscal impact.
Division I — Health Insurance Trade Practices
Description
Division I of the Bill:
- Prohibits a URO from using an AI-based algorithm or system as the sole basis for the decision to deny, delay, or downgrade a prior authorization request based on medical necessity.
- Requires UROs that conduct audits of health care provider claims to meet notification and determination timeline requirements.
- Requires adverse audit determination appeals by health care providers and the final determination on appealed claims by UROs to meet timeline requirements.
- Requires UROs that violate new Iowa Code section 514F.8C(2) to approve and promptly pay the corresponding health care provider claim, with interest.
- Provides applicability requirements.
- Restricts health carriers from taking certain punitive actions against a provider based on the provider’s referral to, or affiliation with, an out-of-network provider.
- Authorizes the Commissioner of Insurance to adopt administrative rules to administer this Division.
Background
Prior authorization is defined in Iowa Code section 514F.8 as a determination by a URO that a specific health care service proposed by a health care provider for a covered person is medically necessary or medically appropriate. The determination must be made prior to the provision of the health care service to the covered person. If applicable, a covered person or a health care provider must notify the URO prior to receiving or providing a specific health care service.
Figure 1 shows insurance claim spend by plan. The State of Iowa costs (2025) were provided by Wellmark, and the Board of Regents (BOR) universities’ costs (2024) were provided by the BOR.
Figure 1 — Insurance Spend by Plan
Insurance Plan Annual Spend
State University of Iowa $ 360,800,000 Iowa State University 138,500,000 University of Northern Iowa 27,100,000 University Total $ 526,400,000 State of Iowa 395,700,000 Total $ 922,100,000 Division I is estimated to affect approximately 25.6% of the population (829,000 people). This includes individual coverage, fully insured small and large employer groups, self-insured public employees, and the State of Iowa plan.
Of the individuals not covered by the mandate, approximately 42.9% are covered by government-sponsored health insurance; 26.7% are covered by employer coverage, which is governed by the federal Employee Retirement Income Security Act of 1974 (ERISA); and the remaining 4.8% are uninsured. Additional details are presented in Figure 2. Figure 2 — Population Covered by Insurance Plans Regulated by Iowa Law
Type of Coverage Iowa Population
Percent of
Population
Total Population 2024 3,241,488 100.0%
Included in Mandate
Individual Coverage 143,597 4.4% Fully Insured Small Employer Group 129,342 4.0% Fully Insured Large Employer Group 286,029 8.8% Self-Insured Public Employees* 215,000 6.6% State of Iowa Plan 55,000 1.7% Total 828,968 25.6%
Not Included in Mandate
Employer (self-insured + other types not listed) 864,752 26.7% Uninsured 156,600 4.8% Other Public (Military, Tricare, Veterans Affairs) 24,100 0.7% Medicare 685,671 21.2% Medicaid + Children’s Health Insurance Plan 681,397 21.0% Total 2,412,520 74.4% *Represents total population 2020. Sources: Iowa Insurance Division and Wellmark
Assumptions
- It is unknown how administrative costs will be impacted, but the impact may be significant.
- According to Wellmark, restricting a health carrier’s ability to impose punitive financial incentives on health care providers may increase costs to the State of Iowa plan and the BOR universities’ plans. It is unknown how this may impact the University of Iowa Health Care (UIHC) as a provider.
Fiscal Impact
Division I of the Bill may increase costs to the State of Iowa and the BOR universities’ health plans incurred in responding to audits of clean claims; any potential fiscal impact is unknown but may be significant.
Division II — Prior Authorizations
Description
Division II of the Bill relates to prior authorization requirements and does the following:
- Requires health care providers, beginning July 1, 2027, to submit requests for prior authorization to a health carrier electronically and to comply with federal interoperability regulations.
- Provides the following requirements for a URO to deny or downgrade a request for prior authorization:
- The decision must be made by a qualified reviewer or a clinical peer, who must attest to the reviewer’s or peer’s qualifications, excluding any personal identifiable information.
- The health care provider must be given a statement signed by the qualified reviewer or clinical peer who made the decision, and the statement must include the specific reasons for the denial or downgrade.
- The URO’s appeal process must be disclosed to the health care provider and the covered person.
- Requires a URO to conduct a consultation with a qualified reviewer or clinical peer within seven business days, if requested by a health care provider.
- Restricts a qualified reviewer or clinical peer who was involved in an original denial or downgrade from conducting the pursuing appeal.
- Prohibits prior authorization and additional utilization review requirements by a health carrier for the following:
- Cancer-related screenings that are recommended by the covered person’s health care professional and meet other requirements of the Bill.
- Diagnosis and treatment of an emergency medical condition that develops or becomes evident while the covered person is receiving inpatient care and meets other requirements of the Bill, including that the condition is reasonably determined by a health care professional to be life-threatening without immediate treatment.
- Authorizes the Commissioner of Insurance to adopt administrative rules to administer this Division.
- Establishes applicability.
- Establishes enforcement mechanisms permitting the Commissioner of Insurance to suspend a URO’s authority to conduct utilization review upon finding a pattern or practice of noncompliance with the sections of Iowa Code specified in the Bill. Includes remedies authorized in Iowa Code chapters 505 and 507B.
Background
Civil penalties collected pursuant to Iowa Code chapters 505 and 507B are deposited into the General Fund (60.0%) and the Commerce Revolving Fund (CMRF) (40.0%).
Division II is estimated to affect approximately 25.6% of the population (829,000 people). Additional details are presented in Figure 2.
Assumptions
- Requiring a qualified reviewer or a clinical peer to make denial or downgrade determinations may increase administrative costs for health carriers.
- According to Wellmark, some of these specialized positions may not currently be on staff, and there may be significant costs to hire or contract this work to individuals with the same qualifications and experience as the health care professional or physician requesting prior authorization. Potential costs are unknown but may be significant.
- According to Wellmark, any reduction in prior authorization utilization is accompanied by a sentinel effect, which increases utilization and costs to a health insurance plan.
- Additional consultation pursuant to the Bill may increase administrative costs by an unknown amount, which may be significant.
- According to Wellmark, prohibiting prior authorization and additional utilization requirements for cancer-related screenings and for the diagnosis and treatment of emergency medical conditions, as restricted by the Bill, is not expected to have a significant impact on costs to the State of Iowa plan. It is unknown whether there will be any impact on costs to the other State-funded plans.
- According to the BOR, any increase in the utilization of services may increase revenues or decrease costs to the UIHC as a provider, but any such impact cannot be quantified at this time.
Fiscal Impact
Division II of the Bill may increase administrative costs to the State of Iowa and the BOR universities’ health plans by requiring denial and downgrade determinations for prior authorization requests to be performed by qualified reviewers and clinical peers. Administrative costs for each of the plans may also be increased in the appeal and consultation process outlined in Division II. Additionally, Division II may increase costs to the BOR universities’ health plans by prohibiting prior authorization and additional utilization requirements for specific screenings, diagnoses, and treatments that meet the requirements of the Bill. Finally, Division II may increase revenues to the UIHC as a provider if increased utilization of services occurs. Any potential fiscal impact is unknown but may be significant.
Division III — Prior Authorizations — Medical Assistance Program
Description
Division III of the Bill relates to prior authorization requirements and does the following:
- Prohibits the Department of Health and Human Services (HHS) and managed care organizations (MCOs) from requiring prior authorization or additional utilization review requirements for Medicaid and Healthy and Well Kids in Iowa (Hawki) recipients for the following:
- Cancer-related screenings that are recommended by the recipient’s health care provider and meet other requirements of the Bill.
- Diagnosis and treatment of an emergency medical condition that develops or becomes evident while the recipient is receiving inpatient care and meets other requirements of the Bill, including that the condition is reasonably determined by a provider to be life-threatening without immediate treatment.
- Requires health care providers, beginning July 1, 2027, to submit requests for prior authorization to an MCO electronically and to comply with federal interoperability regulations.
- Division III of the Bill is applicable to all contracts between the HHS and an MCO that are delivered, issued for delivery, continued, extended, or renewed beginning January 1, 2027, and to requests for prior authorization made beginning January 1, 2027.
- Authorizes the HHS to adopt administrative rules to administer this Division.
Background
Division III applies to Medicaid and Hawki and is estimated to affect approximately 21.0% of the population (681,000 people). Additional details are presented in Figure 2.
Assumptions and Fiscal Impact
Division III of the Bill may increase costs for Medicaid reimbursements by prohibiting prior authorization and additional utilization requirements for specific screenings, diagnoses, and treatments that meet the requirements of the Bill. Any potential fiscal impact is indeterminable.
Fiscal Impact Summary
Any potential fiscal impact of HF 2635 to the State is unknown, but may be significant. The Bill may increase revenues to the UIHC. Divisions I and II of House File 2635 may increase costs to the State of Iowa and the BOR universities’ plans. Division III may increase costs to the HHS. Division IV is estimated to have no fiscal impact.
Sources
- Board of Regents
- Department of Administrative Services
- Department of Health and Human Services
- Department of Insurance and Financial Services, Iowa Insurance Division
- Wellmark
- Legislative Services Agency analysis
- Final Fiscal Note — Health Insurance and Managed Care, Payment Practices · March 31, 2026
- Prior Authorizations, Cancer Screenings, Reviews, and Timelines · March 4, 2026
- Health Insurance and Managed Care, Payment Practices · March 3, 2026
Iowa Code it changes
Creates§514F.10§514F.8A§514F.8B§514F.8C
Amends§514F.8
Lobbying
25 for · 6 against · 15 undecided · Who →
Family tree
Study bill