Abbas v. Iowa Insurance DivisionAnnotate this Case
In 1986, the Iowa legislature enacted House File 2219 to provide for payment by healthcare service corporations for services performed by chiropractors. Following the Supreme Court’s decision in Mueller v. Wellmark, several Iowa-licensed chiropractors (collectively, Appellants) brought this action alleging that Wellmark, Inc. wrongfully imposes restrictions and pays lower rates for chiropractic services than for equivalent services offered by medical and osteopathic doctors in violation of Iowa Code 514F.2. The Insurance Commissioner concluded that section 514F.2 does not require health insurers to compensate the chiropractors equally with medical and osteopathic doctors in network. The district court affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the interpretation of section 514F.2 has not been clearly vested by a provision of law in the discretion of the Commissioner; (2) the statute regulates payments to providers; (3) Wellmark’s fees for chiropractic care are not based solely on licensure; and (4) ERISA preempts the application of section 514F.2 to self-funded health plans.