Navigating Iowa's New Emergency Workers’ Compensation Rules: What You Need to Know

The Iowa legislature recently passed, and Gov. Reynolds subsequently signed into law SF 2463, which rescinded state agency contested case rules and replaced them with the Uniform Rules on Agency Procedure. As a result, 876 IAC chapters 4, 5, 7, and most of chapter 9 were replaced by the Uniform Rules (unless an agency adopts differing emergency rules) while chapters 1, 2, 3, 6, 8, 10 and 11 remain unchanged.

The Iowa Workers’ Compensation Division (IWCD) determined that many of the Uniform Rules were ill-suited for the workers' compensation system, which has long operated more like district court litigation than a typical administrative proceeding. Accordingly, the IWCD specifically declined to adopt numerous Uniform Rules—including those governing discovery, pleadings, motions, prehearing conferences, continuances, defaults, telephone proceedings, interlocutory appeals, and applications for rehearing—and instead enacted emergency rules to preserve decades of well-established contested case procedures. These new emergency rules replace 876 IAC chapter 4 with new chapter 2506 (see the conversion table below).

The new chapter 2506 represents a deliberate effort to maintain the current procedural framework familiar to workers' compensation practitioners. Importantly, all major practice deadlines remain unchanged.

Practitioners should be aware of four key changes made by the emergency rules:

1. The burden of proof for admission of late evidence has shifted from the objecting party to the offering party. Under old Rule 4.19(3)(e), late evidence was admitted unless the objecting party showed its admittance would be unfairly prejudicial and that the failure to disclose timely was without good cause. Under new Rule 2506.48(4), late evidence will be excluded unless the offering party demonstrates good cause for non-compliance with disclosure requirements.
2. The timing for Hearing Report submissions has changed. Under old Rule 4.19(f), hearing reports were required to be filed 14 days prior to the hearing. Under new Rule 2506.48(5), hearing reports are submitted at the hearing. As a practical matter, counsel for both sides should coordinate prior to the hearing to ensure the hearing report is ready to sign—or agree to on the record—at the time of the hearing.
3. Dismissals may now be with prejudice unless permission is granted or the opposing party consents. (See new Rule 2506.18 and IRCP 1.943.)
4. Under new Rule 2506.20(3), companies can represent themselves at hearing.

Additionally, four subsections of the old Rule 4.9 were not carried over and the IWCD did not adopt corresponding Uniform Rules or emergency rules. Iowa Rules of Civil Procedure therefore control. In practice, the only change is to the procedure for amendments, now governed by IRCP 1.402(2), which permits one amendment as a matter of course before a responsive pleading is served. After a responsive pleading is served, an amendment requires agency approval or consent of the adverse party.

It is important to note the new rules apply only to cases filed on or after June 30, 2026; the old rules continue to apply to all cases filed before June 30, 2026. Another point to note is that the new rules may be again renumbered in late 2026 as part of a major overhaul of all state government rules. Stay tuned for more updates.