Relating to the use of funds awarded under the Jobs and Education for Texans (JET) Grant Program.
LowStandard timeline
Low Cost
Effective:2025-06-20
Enforcing Agencies
Texas Workforce Commission (TWC)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: June 20, 2025
Compliance Deadline: Immediate for all grant applications submitted for award cycles beginning after June 20, 2025.
Agency Rulemaking: The Texas Workforce Commission (TWC) must update the Request for Applications (RFA) guidelines. Expect a "regulatory gray zone" between the effective date and the release of the next RFA, during which the definition of "technology solutions" will remain subject to agency interpretation.
Immediate Action Plan
1.Revise Proposals: Update sales proposal templates to break out "Implementation" and "Maintenance" as separate, eligible line items for JET grant applications.
2.Audit Pipeline: Review all pending deals with community colleges and ISDs. If a deal is contingent on a future JET grant, restructure the quote to include software and maintenance.
3.Segregate Accounts: Instruct billing departments to create specific codes for "JET-Eligible Maintenance" to ensure these costs are not commingled with general IT services.
4.Monitor TWC: Assign a compliance officer to monitor the TWC website for the updated JET Grant RFA to confirm the definition of "Technology Solutions."
Operational Changes Required
Contracts
Service Level Agreements (SLAs): Vendors must restructure contracts to itemize "ongoing maintenance" as a distinct, grant-eligible deliverable.
Term Alignment: Align software licensing and maintenance contract terms with the grant performance period. Include "termination for convenience" or "funding contingency" clauses in multi-year maintenance agreements in case grant funding is not renewed.
No Retroactivity: Do not attempt to amend existing contracts funded by pre-June 2025 grants to include maintenance costs. This is a statutory violation.
Hiring/Training
Sales Teams: Retrain public sector sales teams immediately. They must shift from "Capital Expenditure (CapEx)" pitches to "Total Cost of Ownership" pitches that include implementation and maintenance.
Grant Writers: Internal or contracted grant writers must be instructed to include software implementation and maintenance line items in new budget narratives.
Reporting & Record-Keeping
Nexus Documentation: Invoices for technology maintenance must explicitly reference the specific Career and Technical Education (CTE) program supported. General IT maintenance invoices that cannot be segregated from campus-wide IT costs will fail TWC audits.
Asset Management: "Technology solutions" must be tracked with the same rigor as physical equipment. Maintain logs of software license keys, user seats, and maintenance logs.
Fees & Costs
No New Fees: There are no new state fees.
Budget Impact: This is a revenue opportunity for vendors. For applicants, this allows for a shift of operational maintenance costs to grant funding, freeing up local operational budgets.
Strategic Ambiguities & Considerations
Definition of "Technology Solutions": The statute is broad. It is currently unclear if this includes infrastructure (e.g., broadband/servers) or is strictly limited to instructional software/hardware. Watch TWC rulemaking for exclusions.
"Ongoing" Duration: The law does not define the maximum duration for "ongoing maintenance." It is unclear if TWC will allow pre-payment of a 3-5 year maintenance contract or if it will be restricted to the 1-2 year grant term.
Personnel Costs: It is ambiguous whether "maintenance" covers internal staff salaries or is restricted to third-party vendor contracts. Based on precedent, assume third-party restrictions apply until TWC clarifies.
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Information 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.
The Texas Workforce Commission administers the Jobs and Education for Texans (JET) Grant Program, which supports open-enrollment charter schools, public school districts, public junior colleges, public technical institutes, public state colleges, and the Windham School District. The JET program funds the purchase and installation of equipment for career and technical education programs resulting in a certificate, credential of value, or post-secondary degree. However, the bill author has informed the committee that current law does not provide for the technology solutions needed to ensure these programs are sustainable and effective long-term. H.B. 322 seeks to improve JET's efficiency and flexibility by authorizing the use of JET grants to pay costs relating to technology solutions to support career and technical education programs.
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. 322 amends the Education Code to authorize grants awarded under the Jobs and Education for Texans (JET) Grant Program from the JET fund to pay costs for the acquisition, implementation, and ongoing maintenance of technology solutions necessary to support new career and technical education programs at public junior colleges, public technical institutes, public state colleges, and school districts and open-enrollment charter schools. The bill applies only to a grant awarded on or after the bill's effective date.
HB322 fundamentally expands the Jobs and Education for Texans (JET) Grant Program to allow funding for the acquisition, implementation, and ongoing maintenance of "technology solutions," rather than strictly tangible equipment. This change immediately benefits EdTech vendors, Managed Service Providers (MSPs), and educational institutions by authorizing grant funds for software stacks and long-term maintenance contracts, provided the grant is awarded on or after the effective date. Implementation Timeline Effective Date: June 20, 2025 Compliance Deadline: Immediate for all grant applications submitted for award cycles beginning after June 20, 2025.
Q
Who authored HB322?
HB322 was authored by Texas Representative Ryan Guillen during the Regular Session.
Q
When was HB322 signed into law?
HB322 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB322?
HB322 is enforced by Texas Workforce Commission (TWC).
Q
How urgent is compliance with HB322?
The compliance urgency for HB322 is rated as "low". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB322?
The cost impact of HB322 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB322 address?
HB322 addresses topics including education, education--higher, education--higher--student financial aid, education--primary & secondary and education--primary & secondary--vocational.
Legislative data provided by LegiScanLast updated: November 25, 2025
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