Iowa (Iowa) historically had limited protections in place related to emergency services and insurance disclosures, but Iowa does not have a standalone state surprise billing law that replaces or supersedes the federal No Surprises Act (NSA).

Beginning January 1, 2022, the federal NSA became the controlling law for all out-of-network (OON) reimbursement disputes for nearly all commercial plans in the state.

Iowa does not maintain a state-set payment benchmark, a UCR formula, or a state-run arbitration system.

Iowa relies largely on the federal NSA protection framework. Under Iowa’s adoption of NSA standards:

• Patients may not be balance billed for covered OON emergency care or unintentional OON services at an in-network facility.
• Providers must bill the health plan directly, not the patient.
• Carriers must issue an initial payment based on the plan’s recognized amount, which under the federal NSA is the Qualified Payment Amount (QPA).
• Patients are only responsible for in-network cost-sharing (copay, deductible, coinsurance).

Iowa does not impose additional OON payment formulas beyond those in the NSA.

Iowa does not have a state-operated IDR or arbitration program for surprise billing disputes.

As a result:

• Iowa does not have a CMS-recognized Specified State Law (SSL).
• All eligible reimbursement disputes must be resolved through the Federal NSA IDR process.
• This includes:
  
  • Emergency OON care
  • Non-emergency OON services at an in-network facility
  • Air ambulance OON services
  • Payment disputes involving QPA-based initial payments

There is no separate Iowa arbitration pathway.

Iowa follows the mandatory 30-day federal negotiation period, which:

• Begins when the insurer issues its initial payment or denial.
• Requires both parties to attempt good-faith negotiation.
• Allows either side to escalate to Federal IDR if no resolution is reached.

Iowa adds no extra timing obligations beyond federal requirements.

Because Iowa relies exclusively on the federal IDR system, arbitrators evaluate federal statutory factors, including:

• Qualified Payment Amount (QPA) — the primary benchmark
• Provider’s training, experience, and case acuity
• Market share of provider or insurer
• Prior contracted rates within the last four years
• Good-faith network contracting behavior
• Case complexity or facility-specific attributes

Iowa introduces no additional arbitration criteria.

Iowa’s balance billing protections rely on:

• Iowa Insurance Division (IID) consumer protection enforcement
• Existing emergency services billing regulations
• Adoption of federal NSA requirements under 45 CFR 149.510 & 149.520

Iowa’s statutory framework ensures patient protection but does not create a separate OON payment benchmark or arbitration program.

CMS has confirmed that Iowa does not maintain a Specified State Law (SSL) for out-of-network rate determination.

• Fully insured commercial health plans
• Individual health insurance policies
• Group insurance coverage
• Self-funded ERISA plans (unless they voluntarily adopt another SSL — very rare)

• The QPA controls OON payment determinations.
• All eligible disputes move through the federal IDR portal.
• Iowa carriers must follow NSA timelines, disclosures, and procedural requirements.
• Iowa law protects consumers but does not alter NSA reimbursement mechanics.