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Iowa Senate Bill 2226 Restricts Health Carriers From Using Automated Systems to Deny or Downcode Claims Without Clinical Review

Original title: A bill for an act relating to the use of automated adjudication systems by health carriers, and including civil penalties.

Last action · February 10, 2026: Subcommittee: Warme, Petersen, and Schultz. S.J. 244 .Sponsors: Art Staed and 6 others

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What This Bill Would Do

Health carriers and third-party administrators are prohibited from using automated algorithms or software to deny or medical claims without first conducting a documented individualized review by a . The bill establishes written notice requirements, a 30-day appeal window for healthcare providers, and civil penalties of up to $10,000 per intentional or reckless violation.

Why it matters

Healthcare providers gain new formal appeal rights and transparency regarding automated claim denials, while health carriers face record retention mandates, reporting duties, and potential civil lawsuits for noncompliance.

Background
  • Automated adjudication systems and algorithms are increasingly utilized by health insurers to process medical claims, prompting concerns among providers regarding automated claim denials and reductions. context
  • Senate File 2226 was introduced in the Iowa Senate during the 2026 legislative session by Senator Staed alongside six cosponsors. context

Who It Would Affect

Groups the bill's text would affect if enacted, as described in the record. Being affected is not a position for or against it.

Directly affected

Health carriers

Health carriers must alter claim processing procedures, conduct individualized clinical reviews before automated downcoding or denials, provide detailed written notices, maintain records for five years, and submit annual transparency reports to providers.

Directly affected

Health care providers

Health care providers receive a mandated 30-day appeal window, rights to request clinical reviews, access to annual summary reports of automated claim decisions, and the ability to file civil lawsuits for statutory violations.

Directly affected

Covered persons

Covered persons experience changes in how their health benefit plan claims and medical necessity determinations are adjudicated by health carriers and third-party administrators.

Key Facts

  • An automated adjudication system cannot be used as the sole basis for denying a claim for lack of medical necessity, rejecting a claim for insufficient documentation, modifying a code without verification, or withholding payment for routine services.
  • Health carriers must provide written notice to healthcare providers before downcoding or denying a claim, including clinical justifications, reviewer identification, and a minimum 30-day window to appeal.
  • Health carriers must disclose their use of automated adjudication systems to the insurance division, detailing criteria, decision rules, audit frequencies, and measures to prevent unlawful bias.
  • Carriers must retain documentation for each downcoded claim for a minimum of five years from the date of payment.
Show all 10 facts
  • Healthcare providers have 30 calendar days from receipt of a notice to appeal a proposed denial or downcode by submitting additional documentation or requesting clinical review.
  • Health carriers must respond to provider appeals no later than 45 calendar days from receipt.
  • If an appeal determines the original code was supported, the health carrier must readjust the claim and provide a written explanation.
  • Health carriers must provide an annual report summarizing automated claim processing statistics upon request by a healthcare provider.
  • The insurance commissioner may impose a penalty of up to $10,000 per violation if a health carrier intentionally or recklessly processes claims in violation of the chapter.
  • Injured persons or healthcare providers may bring a civil action in district court to recover damages, obtain injunctions, and collect court costs and reasonable attorney fees.

Frequently Asked Questions

What is considered an automated adjudication system under this bill?
It is defined as any software, algorithm, artificial intelligence, machine-learning system, or rule-based automated process used by a health carrier or third-party administrator to evaluate, adjust, approve, deny, or a claim submitted by a healthcare provider.
How long does a healthcare provider have to appeal a downcoded or denied claim?
A healthcare provider must be given no less than 30 calendar days from the date of receipt of the notice to appeal the decision or submit additional documentation.
What penalties can be imposed on health carriers that violate these rules?
The commissioner of insurance may impose a penalty of up to $10,000 per violation for intentional or reckless violations, and affected providers or persons can bring a civil action to recover damages and attorney fees.

What else do you want to know?

News Coverage

No news coverage found yet. Articles are indexed twice daily.

Where This Stands

Currently in committee. The next step in the legislative lifecycle is Floor Vote.

Procedural history

2 actions
  1. Feb 10, 2026Senate
    Subcommittee: Warme, Petersen, and Schultz. S.J. 244 .
  2. Feb 5, 2026SenateIntroduced
    Introduced, referred to Commerce. S.J. 212 .

Version history

Only one version on file - nothing to compare yet. As later stages (committee substitute, engrossed, enrolled) are captured, the redline appears here.

View official text →

Lobbying Activity

No state lobbying filings in our records match this bill. Federal lobbying reports (LDA) cover Congress, so they are not listed on state bills.

Full breakdown

Who this bill affects and the strongest case for and against it, written only from the bill’s own text.

Sponsors

Discoveries

1 pattern noticed across the record

Patterns POLISCOPE noticed across the record. These are observations to investigate, not conclusions.

policy shift98% confidence

Introduction of Mandated Clinical Review for Automated Claims

The bill shifts regulatory oversight by legally barring health carriers from relying solely on automated systems or algorithms for claim denials and downcoding without human clinical verification.

Connected Entities

Liz Bennett, Catelin Drey, Molly Donahue and 4 more
PersonLiz Bennett“Cosponsor of Senate File 2226”Map →
PersonCatelin Drey“Cosponsor of Senate File 2226”Map →
PersonMolly Donahue“Cosponsor of Senate File 2226”Map →
PersonArt Staed“Primary sponsor of Senate File 2226”Map →
PersonRenee Hardman“Cosponsor of Senate File 2226”Map →
PersonJanet Petersen“Cosponsor of Senate File 2226”Map →
PersonMike Zimmer“Cosponsor of Senate File 2226”Map →

Sources

Open source document

www.legis.iowa.gov

Analysis Score

0–100
  • Significance75
    How much this matters to a regular citizen
  • Controversy65
    Intensity of disagreement among stakeholders
  • Entertainment10
    Compellingness for a non-policy-wonk reader
  • Buzz40
    Current news / social attention level

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