Iowa Dental Association v. Iowa Insurance Division and Iowa Insurance Commissioner, 831 N.W.2d 138

Iowa Dental Association (IDA) sought a declaratory order from the Iowa Insurance Commissioner on 514C.3B's meaning regarding covered services.
The statute defines covered services as those that are reimbursed under the dental plan, with a later subsection allowing insurer restrictions unrelated to reimbursement.
The Commissioner read 514C.3B(3)(a) and 514C.3B(4) to permit maximum fees for services not actually reimbursed due to plan limits.
ID A argued that “reimbursed” means actual reimbursement; insurers argued it includes generally reimbursable services despite in-instance non-reimbursement.
The district court upheld the Commissioner’s order, applying an arbitrary/erroneous-interpretation standard of review under Iowa law.
The Iowa Supreme Court conducted de novo review due to lack of clearly vested interpretive authority in the Commissioner and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ‘covered services’ require actual reimbursement under the plan.	IDA: reimbursed means actual payment.	Federation/Commissioner: includes generally reimbursable services despite restrictions.	No; services must be reimbursed to be covered.
Whether the Commissioner was clearly vested with interpretive authority to define ‘covered services.’	IDA: no clear vesting of authority.	Commissioner: vested via §505.8(2).	Not clearly vested; de novo review appropriate.
What is the correct construction of 514C.3B(3)(a) and (4) in context of the statute as a whole?	IDA: plain meaning favors reimbursement-based definition; subsection 4 not changing core definition.	Federation/Commissioner: subsection 4 clarifies insurer rights to restrict related to covered services.	Statute requires actual reimbursement to be a covered service; de novo review applied.

Renda v. Iowa Civil Rights Comm'n, 784 N.W.2d 8 (Iowa 2010) (determines whether agency has authority to interpret terms; focus on vesting of interpretive authority)
Sherwin-Williams Co. v. Iowa Dept. of Revenue, 789 N.W.2d 417 (Iowa 2010) (interpreting terms when statutory definition exists; limits on agency interpretation)
Evercom Sys., Inc. v. Iowa Utils. Bd., 805 N.W.2d 758 (Iowa 2011) (agency interpretive authority in technical terms varies by context)
Neal v. Annett Holdings, Inc., 814 N.W.2d 512 (Iowa 2012) (mere rulemaking authority not enough for interpretive power; specialized terms require vesting)
Burton v. Hilltop Care Ctr., 813 N.W.2d 250 (Iowa 2012) (legislative definition present; agency not vested with interpretive authority over term)