What needs to change in Iowa.

• Clergy absent from the § 232.69(1) enumerated list

  The mandatory-reporter list in **Iowa Code § 232.69(1)** names 16 classes of professionals: a health practitioner under paragraph (a), plus fifteen further classes under paragraph (b). Those fifteen are social workers, employees and operators of health-care facilities, certified psychologists, licensed school employees, child-care operators, substance-use-disorder program staff, employees of a department institution listed in § 218.1, juvenile-detention and juvenile-shelter-care staff, child-foster-care staff, mental-health-center employees, peace officers, counselors and mental-health professionals, Medicaid-waiver service providers, children's-residential-facility staff, and licensed massage therapists. Clergy appear nowhere in the list. Iowa's Department of Health and Human Services confirms this in its official mandatory-reporter guidance: clergy are not considered mandatory reporters unless they are functioning as a social worker, counselor, or another role described as a mandatory reporter. Acting only as clergy, they are permissive reporters under § 232.69(2), meaning they may report but are not required to.

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• § 232.74 privilege override is silent on the clergy-penitent privilege

  **Iowa Code § 232.74** declares two whole sections of the evidence code inapplicable to evidence regarding a child's injuries in any civil or criminal proceeding resulting from a child-abuse report: § 622.9, the spousal-testimony privilege, and § 622.10, the professional-confidence privilege. Iowa's clergy-penitent privilege is codified inside § 622.10, at subsection (1), and § 232.74 names that section whole with no subsection carve-out. The statute then describes the privileges it displaces in terms of the testimony of a husband or wife and of a health practitioner or mental health professional. Whether that trailing description narrows the displacement of the two sections named by number, or instead qualifies only the catch-all 'any other statute or rule of evidence' that immediately precedes it, is an open question on the face of the statute. No Iowa appellate decision resolving it surfaced in this review. The privilegePosture is recorded as silent because the legislature never addressed the clergy context expressly, not because it weighed the question and chose to preserve the privilege.

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• State agency guidance confirms the gap directly

  Iowa Health and Human Services states in its official guide for mandatory reporters that **clergy members are not considered mandatory reporters unless they are functioning as a social worker, counselor, or another role described as a mandatory reporter**. The guide adds that a clergy member who provides counseling services to a child who then discloses abuse is mandated to report as a counselor. Clergy acting only in a clergy role are permissive reporters. The guide quotes Iowa Code § 232.74, which sets aside §§ 622.9 and 622.10 for child-injury evidence while describing the displaced privileges in spousal and health-practitioner terms; it does not name the clergy-penitent privilege, and the guide does not address clergy privilege at all. The structural reporting gap the legislature has left in place through repeated amendment cycles is established by the statute itself.

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What it takes to close the gap.

How Iowa got here.

• 2019
  HF 731 mandatory-reporter training reform, clergy gap unchanged

  HF 731, signed by Governor Kim Reynolds on May 8, 2019, amended only the training provisions at § 232.69(3), shortening the retraining interval from five years to three and consolidating curriculum development in the department. It never opened § 232.69(1), the enumerated reporter list, and added no professional category. Subsequent amendments in 2022, 2023, 2024, and 2025 likewise left the clergy gap in place.

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Public-record sources UCO is tracking.

Always verify against the underlying statute or filing before quoting.

• Iowa Legislature· Iowa Code 2026 (through 2025 Acts chs. 86 & 135)
  Iowa Code § 232.69 — Mandatory and permissive reporters

  Principal mandatory-reporter statute. Subsection (1) enumerates 16 classes of professionals (a health practitioner under paragraph (a), plus fifteen further classes under paragraph (b)); clergy are not among them. Subsection (2) makes any other person a permissive reporter. Amended in 2018, 2019, 2022, 2023, 2024, and 2025 without adding clergy to the enumerated list.

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• Justia US Law
  Iowa Code § 232.69 — Justia mirror with amendment trail

  Justia mirror of Iowa Code § 232.69 annotated with the session-law amendment trail. Cross-validation of the Iowa Legislature primary source; the underlying statute text is the same.

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• Iowa Legislature· Iowa Code 2026
  Iowa Code § 232.74 — Evidence not privileged or excluded

  Declares §§ 622.9 and 622.10 inapplicable to evidence regarding a child's injuries in proceedings resulting from a child-abuse report, while describing the displaced privileges in spousal and health-practitioner terms. The clergy-penitent privilege sits inside § 622.10, so its status under this section is unresolved on the face of the statute. Basis for the silent privilegePosture, which records the absence of express treatment.

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• Iowa Legislature· Iowa Code 2026 (through 2025 Acts ch. 86)
  Iowa Code § 232.68 — Definitions

  Definitions section of the child-abuse-reporting subpart of Chapter 232. Contains no definition of clergy or any religious actor category, reinforcing that the statute does not address clergy expressly.

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• Iowa Legislature· Iowa Code 2026
  Iowa Code § 622.10 — Communications in professional confidence

  Iowa's professional-confidence privilege statute. Subsection (1) includes a member of the clergy among persons whose confidential communications are privileged. § 232.74 names this section by number without naming the clergy privilege, so whether the privilege is displaced in child-abuse proceedings is unresolved on the face of the statute.

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• Iowa Department of Health and Human Services
  Mandatory Reporters — Iowa Health and Human Services

  Official Iowa HHS mandatory-reporter page. Directs mandatory reporters to Iowa Code § 232.69 for child abuse and § 235B.3(2) for dependent adult abuse, and covers reporter training, rights, and responsibilities. The page does not mention clergy and does not enumerate the professional categories.

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• Iowa Department of Health and Human Services· Rev. 07/24
  Child Abuse: A Guide for Mandatory Reporters (Comm. 164)

  Iowa HHS official guidance for mandatory reporters. States directly that clergy are not considered mandatory reporters unless functioning as a social worker, counselor, or another listed role; clergy acting only as clergy are permissive reporters under § 232.69(2).

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• U.S. Department of Health and Human Services, Children's Bureau
  Clergy as Mandatory Reporters of Child Abuse and Neglect — Iowa State Statutes Series

  Federal HHS / Children's Bureau state-by-state compilation. Notes that the question of clergy as mandatory reporters is not addressed in the Iowa statutes reviewed, corroborating the not-expressly statusBucket classification.

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• Iowa Legislature· Signed May 8, 2019
  Iowa House File 731 (88th General Assembly) — bill history

  Bill history page for HF 731. Signed by Governor Kim Reynolds on May 8, 2019. Restructured mandatory-reporter training requirements under § 232.69, increasing training frequency and consolidating curriculum development. Clergy were not added to the § 232.69(1) enumerated list.

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