Regular Session
Government Affairs & Regulatory Compliance Analysis
HB 2038 establishes two new medical licensure pathways—Provisional Foreign Licenses and Physician Graduate Licenses—effective September 1, 2025, to address provider shortages. Hospitals and rural practices gain recruitment options but face strict vicarious liability and mandatory patient disclosure requirements that demand immediate updates to credentialing and risk management protocols.
Rep. Tom Oliverson·House Bill·Regular Session
This legislation has regulatory implications for the following Texas businesses and organizations:
Significant regulatory changes (effective 2025-06-20). Review with your legal and compliance teams to understand implications.
Affected business types:
mediumModerate costs expected for implementation.
JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.
JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with this legislation
The TMB has significant discretion in the upcoming rulemaking session (Sept–Dec 2025). Monitor the following closely:
JD Key Consulting specializes in Texas regulatory compliance strategy. Work directly with James Dickey—former Chairman of the Republican Party of Texas—to understand this bill's impact on your operations and develop an actionable compliance plan.
Schedule a ConsultationInformation presented is for general knowledge only and is provided without warranty, express or implied. Consult qualified government affairs professionals and legal counsel before making compliance decisions.
This bill's path through the Texas Legislature
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Common questions about HB2038
HB 2038 establishes two new medical licensure pathways—Provisional Foreign Licenses and Physician Graduate Licenses—effective September 1, 2025, to address provider shortages. Hospitals and rural practices gain recruitment options but face strict vicarious liability and mandatory patient disclosure requirements that demand immediate updates to credentialing and risk management protocols.
HB2038 was authored by Texas Representative Tom Oliverson during the Regular Session.
HB2038 was signed into law by Governor Greg Abbott on June 20, 2025.
HB2038 is enforced by Texas Department of Insurance and Texas Medical Board.
The regulatory priority for HB2038 is rated as "critical". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB2038 is estimated as "medium". This may vary based on industry and implementation requirements.
HB2038 addresses topics including intergovernmental relations, military & veterans, occupational regulation, occupational regulation--health occupations and decreasing occupational certification timelines, obstacles, and regulations.
Key dates for HB2038: Effective date is 2025-06-20. Rulemaking: Adopt rules establishing eligibility, fees, and supervision requirements for Foreign Provisional Licenses and Physician Graduate Licenses. (2026-01-01). Consult with legal counsel regarding applicability.
HB2038 establishes the following penalties: administrative penalty of License Revocation/Suspension for Physician Graduate practicing without a valid Supervising Practice Agreement.; civil liability penalty of Full Legal Responsibility for Sponsoring Physicians retain legal responsibility for all patient care activities performed by the supervised Physician Graduate.; administrative penalty of Disciplinary Action for Failure to disclose 'Physician Graduate' status and lack of residency training to patients prior to treatment.. Consult with legal counsel for specific applicability to your situation.
HB2038 primarily affects healthcare providers and medical facilities. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.
JD Key Consulting is an Austin, Texas-based government affairs firm led by James Dickey, former Chairman of the Republican Party of Texas. We specialize in Texas regulatory compliance and legislative strategy for data centers, energy, banking, and manufacturing.
