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IA public employers must restrict certain lodging reimbursements

April 2022 employment law letter
Authors: 
Susan Freed, Dentons Davis Brown

Effective January 1, 2022, Iowa public entities, including public hospitals and schools, must ensure that any lodging provider they pay or reimburse with public funds for lodging, conferences, meetings, or banquet space has an up-to-date certification verifying compliance with Iowa’s human trafficking prevention requirements. The new requirements are outlined in Iowa Code § 80.45A and apply to expenditures directly from the public entity as well as reimbursements by the public entity of expenses incurred by a public employee.

What is a ‘lodging provider’?

A “lodging provider” is defined broadly and includes a person or entity that owns, operates, or manages rooms, apartments, or sleeping quarters in a hotel, motel, inn, public lodging house, rooming house, cabin, apartment, residential property, or manufactured or mobile home that is tangible personal property or in a tourist court, or in any place where sleeping accommodations are furnished to transient guests for rent. It includes VRBO and AirBnB hosts, campgrounds, and hotels providing the public entity with only conference or meeting room space.

The new requirements relate only to lodging providers within the state of Iowa. If a public employee stays at an Iowa lodging provider that doesn’t have an up-to-date certification from the Iowa Office to Combat Human Trafficking, public funds cannot be used to reimburse them.

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