Iowa public bodies (cities, counties, school districts, some hospitals) that maintain a self-insured group healthcare plan for its employees, are required to file a certification and a financial summary with the Iowa Insurance Division; this is done annually.  An executive summary of the legal requirements are shown below:

  • The governing statutes for Iowa public body self-insured plans are Iowa Code sections 509A.14 and 509A.15.
  • Public body self-insured plans are subject to minimum plan standards pursuant to Iowa Administrative Code rule 191-35.20; state mandated benefits are required including those mandated by Iowa Code chapter 514C.  
  • The plan must contract with an independent actuary to attest to the adequacy of the reserves, rates, and the overall financial condition of the plan.
  • A separate plan fund must be established exclusively for the deposit of premiums and other assets pertaining to the plan.  The plan fund shall be disbursed only for specified plan expenses.  Iowa Administrative Code rule 191-35.20(3)(f) lists specific examples of plan expenses.
  • The plan must hold enough funds to cover the estimated required reserves, i.e., IBNR claim reserve and a claims fluctuation reserve .  The independent actuary determines the magnitude of these two reserves.
  • The public body must increase premiums rates (funding) or transfer funds from other sources (general fund, etc) if the plan is in a deficit mode.
  • The public body must contract with a registered third party administrator or licensed insurance company to administer the plan.
  • The plan must maintain aggregate and specific stop-loss coverage to protect the plan from catastrophic claims.
  • The financial summary and the actuarial opinion are reviewed to assess the financial condition of the plan.  The review includes an analysis of the loss experience, claim reserves, and trends.  If the plan reports a net loss for the year, the Iowa Insurance Division may recommend an increase in the funding rate, or request the public body’s administrative plan to eliminate the shortfall of funds.  The balance in the plan fund must be large enough to cover the required statutory reserves, i.e., IBNR and claims fluctuation reserve.
  • The State of Iowa 509A Certificate of Compliance and the financial summary page can be downloaded here.
  • For 28E self-funded Iowa public body multiple pool groups (multiple Iowa counties in a pool group -- for example), the plan must maintain a claims fluctuation reserve equivalent to two month of paid claims.  In addition, 28E pool groups must file quarterly financial statements as opposed to annual summaries required for single entity plans described above.  

New 28E plans that wish to self-fund under 509A must submit their 28E agreement to the Division for approval.  Additional requirements for 28E pool groups are contained in Iowa Administrative Code rule 191-35.20(2).  

Important changes regarding the submission of Iowa Public Body Self-insured Group Healthcare plans (509A and 28E plans)

509A certificates of compliance are required to be submitted with the Iowa Insurance Division electronically at  All groups must file their submissions on an annual basis within ninety days following the end of a fiscal year.

Payment can be submitted using a credit card or by ACH/electronic check. Convenience Fee: If you pay by ACH, a $1.59 fee will be added.  If you pay by credit card, a $1.59 + 2.5% fee will be added.

FAQ - Iowa Public Body Self-insured Group Healthcare plans