Relating to including nursing school applications in a consolidated application service.
ModeratePlan for compliance
Low Cost
Effective:2025-06-20
Enforcing Agencies
Texas Health Education Service at The University of Texas System Administration
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: June 20, 2025 (Immediate legal effect).
Compliance Deadline: The consolidated service must be operational for admissions to the 2027 fall semester. Practically, this means your systems must be integrated and ready to accept data by late 2026.
Agency Rulemaking:
November 1, 2025: Deadline for THES to appoint the advisory board (including nursing program representatives).
January 1, 2026: Deadline for the advisory board to publish the official implementation plan. The period between now and Jan 2026 is the "regulatory gray zone" where technical standards will be defined.
Immediate Action Plan
1.Nominate Leadership: Submit qualified candidates for the THES Advisory Board immediately. Securing a seat is the only way to influence fee structures and data standards.
2.Audit Software Contracts: Identify the earliest penalty-free exit dates for your current admissions software vendors.
3.Analyze Fee Structure: Model the financial impact of losing your direct application fee revenue and prepare a proposal for a "Secondary Application" fee if necessary.
4.IT Gap Analysis: Commission a review of your current SIS (Banner, PeopleSoft, Workday) to determine readiness for API or batch-file integration with the UT System.
Operational Changes Required
Contracts
Vendor Termination: Immediate review of contracts with third-party application service providers (e.g., NursingCAS, Liaison, or proprietary CRM portals) is required. You must align termination clauses with the projected Fall 2026 "go-live" date of the state system to avoid redundancy.
Data Agreements: New Memorandums of Understanding (MOUs) and Data Use Agreements (DUAs) must be executed with the UT System/THES to authorize the secure transfer of applicant FERPA data to your institution.
Hiring/Training
IT Integration: IT departments must prepare Student Information Systems (SIS) to ingest batch data from the THES centralized service rather than direct web inputs.
Admissions Staff: Staff must be retrained to utilize the THES backend for verification and processing, moving away from internal intake processing.
Reporting & Record-Keeping
Prerequisite Mapping: Registrars must map institutional nursing prerequisites to the standardized course schema adopted by the THES Advisory Board to ensure automated transcript verification functions correctly.
Capacity Reporting: Institutions will be required to report program capacity and matriculation data to the centralized service to maintain system accuracy.
Fees & Costs
Revenue Impact: The UT System is authorized to levy application fees directly on students to offset administrative costs.
Budget Re-forecasting: Institutions relying on application fees as a revenue stream must determine if this state fee replaces or supplements their current fees. If the state fee is exclusive, you face an immediate revenue loss in your nursing department budget.
Strategic Ambiguities & Considerations
The law establishes the *mandate* but leaves the *mechanics* to the Advisory Board. Watch for the following in the January 2026 Implementation Plan:
1.Scope of "Professional Nursing": It is currently unclear if this mandate extends to LVN programs or is strictly limited to RN/BSN and graduate tracks.
2.Secondary Applications: The law does not explicitly prohibit institutions from requiring a "secondary application" (and associated fee) for essays or cultural fit assessments. This is a critical loophole for maintaining revenue and holistic review standards.
3.Holistic Metrics: It is undefined how the centralized service will transmit non-cognitive data (interviews, situational judgment tests) or if it will act solely as a transcript/GPA aggregator.
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The Texas Center for Nursing Workforce Studies reports that, by 2036, Texas will have a shortage of licensed vocational nurses, registered nurses, and certified nurse midwives. Compounding this problem, the Texas Healthcare Workforce Task Force found that thousands of applications are not accepted at Texas nursing schools each year because there is no centralized mechanism for submitting applications. Accordingly, the task force recommended streamlining the nursing school application process by including nursing school programs in the Texas Medical and Dental Schools Application Service. H.B. 2851 seeks to provide for a streamlined nursing school application process in Texas.
CRIMINAL JUSTICE IMPACT
It is the committee's opinion that this bill does not expressly create a criminal offense, increase the punishment for an existing criminal offense or category of offenses, or change the eligibility of a person for community supervision, parole, or mandatory supervision.
RULEMAKING AUTHORITY
It is the committee's opinion that this bill does not expressly grant any additional rulemaking authority to a state officer, department, agency, or institution.
ANALYSIS
H.B. 2851 amends the Education Code to require a service or organization that provides consolidated application services for applications to medical schools or dental schools, including the Texas Medical and Dental Schools Application Service operated through The University of Texas System, to include applications for nursing schools in Texas.
H.B. 2851 applies beginning with applications for admission to a nursing school for the 2026 fall semester.
Honorable Terry M. Wilson, Chair, House Committee on Higher Education
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
HB2851 by Howard (Relating to including nursing school applications in a consolidated application service.), As Introduced
No significant fiscal implication to the State is anticipated.
The bill would require consolidated application services for applications to medical schools or dental schools, including the Texas Medical and Dental Schools Application Service (TMDSAS) administered by the University of Texas System, to include applications for nursing schools in Texas.
Based on information provided by The University of Texas System, implementation of the bill would result in a cost to institutional funds that would be partially offset by fees levied on applications submitted through TMDSAS. Institutional funds are not appropriated in the General Appropriations Act, and therefore not a cost to the State.
Local Government Impact
No fiscal implication to units of local government is anticipated.
Source Agencies:
720 The University of Texas System Administration, 781 Higher Education Coordinating Board
LBB Staff:
JMc, FV, LBO, BCa
Related Legislation
Explore more bills from this author and on related topics
HB 2851 mandates the centralization of nursing school admissions in Texas, requiring all professional nursing programs to migrate to a consolidated application service managed by the Texas Health Education Service (THES) at the UT System. This legislation forces a transition from institution-specific intake portals to a statewide "Common App" model, significantly altering applicant data workflows and revenue streams for the Fall 2027 admission cycle. Implementation Timeline Effective Date: June 20, 2025 (Immediate legal effect).
Q
Who authored HB2851?
HB2851 was authored by Texas Representative Donna Howard during the Regular Session.
Q
When was HB2851 signed into law?
HB2851 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB2851?
HB2851 is enforced by Texas Health Education Service at The University of Texas System Administration.
Q
How urgent is compliance with HB2851?
The compliance urgency for HB2851 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB2851?
The cost impact of HB2851 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB2851 address?
HB2851 addresses topics including education, education--higher, education--higher--admission & attendance, education--higher--health institutions and health care providers.
Legislative data provided by LegiScanLast updated: November 25, 2025
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