Sunset Commission & Agency Implementation
Navigate agency reviews, rulemaking, and post-legislative implementation strategy
The Texas Sunset Advisory Commission reviews state agencies on a 12-year cycle, evaluating their effectiveness and determining whether they should be continued, restructured, or abolished. For industries regulated by these agencies, Sunset reviews present both risk and opportunity—the risk of unfavorable reforms, and the opportunity to fix broken regulatory frameworks. JD Key Consulting helps clients engage before, during, and after Sunset reviews to protect regulatory structures that serve their business interests while positioning concerns as good government reforms.
Sunset advocacy requires a different approach than traditional lobbying. Sunset staff are policy analysts, not politicians—they respond to data, efficiency arguments, and evidence of regulatory dysfunction. Successful engagement begins early, during staff research phases, not at public hearings. Companies must frame their concerns in terms of agency effectiveness and public interest, not private benefit. Once staff recommendations are issued, the focus shifts to working with legislators to refine sunset bills during session.
Beyond Sunset, JD Key Consulting helps clients navigate agency implementation of legislation. Passing a bill is only half the work—agencies implement laws through administrative rulemaking, and the details of those rules often matter more than the statute itself. We help clients participate in rulemaking processes, submit strategic comments, and coordinate with legislators to ensure favorable implementation. We also advise companies seeking to do business with the state through procurement processes managed by the Comptroller, DIR, and individual agencies.
Key Capabilities
Sunset Schedule Navigation (2026-2027)
Strategic engagement with Sunset staff, testimony preparation, bill tracking, and legislative coordination for agencies under review.
Agency Rulemaking Participation
Comment drafting, hearing participation, SOAH contested case coordination, and agency negotiation for favorable rule implementation.
Post-Bill Implementation Strategy
Ensuring legislative victories translate into favorable agency rules and enforcement practices through strategic rulemaking engagement.
Texas Procurement Navigation
Vendor registration, cooperative purchasing access, RFP strategy, and agency procurement coordination for state contracting opportunities.
Who We Help
Frequently Asked Questions
What is the Texas Sunset Advisory Commission?
The Texas Sunset Advisory Commission reviews state agencies on a 12-year cycle to determine whether they should be continued, restructured, or abolished. The Commission is composed of 5 House members, 5 Senate members, and 2 public members. Staff conducts comprehensive reviews examining agency effectiveness, efficiency, and compliance with legislative intent. The Commission then issues recommendations that are incorporated into sunset legislation considered by the full Legislature. Most agencies are continued with modifications, but the threat of abolition creates leverage for meaningful reform.
What is the timeline for Sunset reviews?
Sunset reviews follow a two-year cycle. Agencies scheduled for review are announced approximately 18 months before their sunset date. Sunset staff conducts field investigations, stakeholder interviews, and analysis during the first year. Public hearings occur in the fall before the legislative session. During session, the Legislature considers sunset bills containing staff recommendations and any member amendments. Bills must pass before the agency sunsets. Stakeholders should engage early—by the time public hearings occur, staff recommendations are largely set. The 2026-2027 cycle will review multiple major agencies.
How can my company participate in Sunset reviews?
Participation should begin early. When an agency affecting your industry enters the Sunset cycle, engage with Sunset staff during their initial research phase—share data, explain regulatory challenges, and identify reform opportunities. Submit written testimony before public hearings. Testify at hearings if you have specific recommendations. Once staff issues recommendations, work with legislators to refine sunset bills during session. The key is building credibility with Sunset staff and positioning your concerns as good government reforms, not special interest asks. JD Key Consulting helps clients navigate this process strategically.
How does agency rulemaking work in Texas?
Texas agencies implement legislation through administrative rulemaking. The process includes: drafting proposed rules, publishing them in the Texas Register for public comment (typically 30 days), holding public hearings if requested, considering comments, and adopting final rules. Controversial rules may trigger contested case hearings before the State Office of Administrative Hearings (SOAH). Final rules are codified in the Texas Administrative Code. Stakeholders can influence rulemaking by submitting detailed comments, requesting hearings, and working with legislators to pressure agencies. Post-bill implementation often matters more than the bill text itself.
What is Texas state procurement and how do I access it?
Texas state procurement is governed by the Government Code and managed primarily by the Comptroller's office. Most procurements use competitive bidding (Requests for Proposals or Invitations for Bids). Many contracts are accessible through cooperative purchasing programs like DIR's contracts or the Texas Multiple Award Schedule (TXMAS). Vendors must register with the Comptroller's Vendor Performance Tracking System. Some agencies have delegated procurement authority. Understanding which procurement method applies to your service/product is critical. JD Key Consulting helps vendors navigate procurement requirements and identify contracting opportunities.
Ready to discuss your needs?
Schedule a confidential conversation with James Dickey.
Call 512.543.4971