IA, US · AI law tracker
SSB 3118 — IA, US
SSB 3118 is an AI governance legislation from IA, currently introduced. Iowa SSB 3118 prohibits AI as the sole basis for denying, delaying, or downgrading prior authorizations based on medical necessity [2]. AIGI tracks 1 primary-source update on this bill; the most recent was published on 2026-02-05.
Status & timeline
- Regulatory stage
- introduced
- Bill status
- introduced
- Authority / governing body
- Iowa Legislature
- Chamber
- senate
- Document type
- legislation
Next deadline: No fixed deadline — bill pending legislative process.
Subscriber only
Full obligation matrix
| Actor | Obligation | Deadline | Source |
|---|---|---|---|
| utilization_review_organization | May use an artificial intelligence-based algorithm to provide an initial review of a request for prior authorization. | — | — |
| utilization_review_organization | Shall not use an artificial intelligence-based algorithm as the sole basis for a decision to deny, delay, or downgrade a prior authorization request for a health care service based on medical necessity. | — | — |
| utilization_review_organization | Shall ensure that decisions to deny or downgrade a prior authorization request are made by a qualified reviewer if the requesting provider is a physician. | — | — |
| utilization_review_organization | Shall ensure that decisions to deny or downgrade a prior authorization request are made by a clinical peer if the requesting provider is not a physician. | — | — |
| utilization_review_organization | Shall provide a written statement citing specific reasons for the denial or downgrade to the health care provider. | — | — |
| utilization_review_organization | Shall ensure the written statement for denial/downgrade is signed by the qualified reviewer or clinical peer who made the determination. | — | — |
| utilization_review_organization | Shall provide a written explanation of the utilization review organization’s appeals process to the health care provider and the covered person. | — | — |
| utilization_review_organization | Shall provide a written attestation from the qualified reviewer (if provider is a physician) that confirms their specialty, training, and expertise relevant to the medical condition. | — | — |
| utilization_review_organization | Shall adhere to the defined meaning of 'Downgrade' for prior authorization decisions. | — | — |
Subscriber only
Enforcement risk score
25
/ 100
Announced regulation; enforcement footprint still forming.
Subscriber only
Role-based compliance checklist
- compliance_officer Review existing AI policies and procedures for prior authorization to ensure compliance with human oversight requirements.
- cto Assess AI systems used in prior authorization to confirm they are not the sole basis for denial, delay, or downgrade decisions.
- general_counsel Draft or update disclosure templates for prior authorization denials, including reasons, appeals, and reviewer attestations.
- hr_director Ensure appropriate staffing and qualification of clinical peers and qualified reviewers for prior authorization decisions.
- risk_manager Evaluate the risk exposure from AI use in prior authorization and implement controls to mitigate non-compliance.
- product_manager Redesign workflows for prior authorization to integrate mandatory human review for all denial, delay, or downgrade decisions, ensuring AI acts only as an initial review tool.
Subscriber only
Vendor impact assessment
- Vendor risk class
- high
- Procurement categories
- healthcare_ai, security_tooling, productivity_assistants, fraud_detection
Vendors providing AI solutions for healthcare prior authorization must ensure their products are designed to support, not replace, human decision-making for critical actions like denials. Their systems must facilitate transparency, auditability, and clear attribution of decisions to qualified human reviewers, and avoid acting as a 'sole basis' for adverse determinations affecting medical necessity.
Sample vendor questions
- Does your AI-based prior authorization solution ever make a final decision to deny, delay, or downgrade a request without human review?
- How does your solution integrate with human clinical peer review processes to ensure final decisions are made by qualified personnel?
- What mechanisms are in place to provide detailed, specific, and attributable reasons for AI-assisted denial or downgrade recommendations?
- How does your system facilitate the generation of written attestations from human reviewers regarding their qualifications for specific decisions?
- What data governance and explainability features are built into your AI models to support compliance with transparency requirements?
Intelligence briefs (1)
legislation introduced 2/5/2026
Iowa SSB 3118 Prohibits Sole AI Decisions for Prior Authorization Denials
Iowa SSB 3118 prohibits AI as the sole basis for denying, delaying, or downgrading prior authorizations based on medical necessity [2].
This signals a clear legislative stance on human oversight for AI in critical healthcare decisions, impacting deployer obligations for UROs.
Deadline: No fixed deadline — bill pending legislative process.
Primary source →Frequently asked questions
- What is SSB 3118?
- Iowa Senate Study Bill 3118 introduces provisions for utilization review organizations (UROs) regarding artificial intelligence (AI) in prior authorization determinations. It permits AI-based algorithms for initial reviews [1] but explicitly prohibits their use as the sole basis for decisions to deny, delay, or downgrade prior authorization requests based on medical necessity [2]. The bill also establishes specific requirements for human clinical peer review in all denial or downgrade decisions. Primary source →
- Why does SSB 3118 matter?
- This signals a clear legislative stance on human oversight for AI in critical healthcare decisions, impacting deployer obligations for UROs. Primary source →
- Who does SSB 3118 affect?
- Utilization review organizations and health carriers operating in Iowa are directly affected. This includes any entity employing artificial intelligence-based algorithms for initial review of prior authorization requests, particularly those for health care services based on medical necessity. The bill's provisions bear on the operational procedures for denying, delaying, or downgrading such requests. Primary source →
- What are the key dates for SSB 3118?
- No fixed deadline — bill pending legislative process. Primary source →
- What is the current status of SSB 3118?
- As of the last published update, SSB 3118 is at the "introduced" stage, with bill status "introduced". Primary source →
- Where can I find the primary source for SSB 3118?
- The primary source for the most recent update is at https://www.legis.iowa.gov/publications/search/document?fq=id:1599843&q=artificial+intelligence. AIGI publishes the full citation chain plus every approved brief on this bill. Primary source →
Related
Stay informed