Relating to the Texas Industry-Recognized Apprenticeship Programs Grant Program.
ModeratePlan for compliance
Low Cost
Effective:2025-06-20
Enforcing Agencies
Texas Workforce Commission
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: June 20, 2025 (Immediate effect due to supermajority vote).
Compliance Deadline: Immediate for any grant application submitted on or after June 20, 2025. Grants awarded prior to this date remain governed by former law.
Agency Rulemaking: The TWC is required to adopt rules defining "apprenticeable occupations" and reimbursement schedules "as soon as practicable" after the effective date.
*Regulatory Gray Zone:* Expect a processing freeze for new applications between June 20, 2025, and the final publication of TWC rules, as the agency cannot award grants until new criteria are codified.
Immediate Action Plan
Audit Pending Applications: Push to finalize and sign any pending grant agreements before June 20, 2025, to lock in current, known regulatory terms.
Update Financial Models: Direct the CFO/Finance Director to adjust cash flow forecasts to account for milestone-based (rather than immediate) reimbursement for future grants.
Subscribe to TWC Alerts: Designate a compliance officer to monitor the *Texas Register* for proposed TWC rules regarding "apprenticeable occupations."
Prepare Public Comment: Be prepared to submit comments during the rulemaking phase if TWC proposes milestone schedules that negatively impact operating capital.
Operational Changes Required
Contracts
Grant Agreements: Legal teams must review new TWC grant contracts for "Milestone" definitions. Ensure reimbursement triggers are commercially viable before signing.
Apprentice Employment Agreements: Align apprentice employment contracts with grant milestones. If a grant payment is triggered by a certification exam or a 6-month retention mark, employment terms should incentivize the apprentice to meet these specific goals.
Hiring/Training
Certification Protocol: Cease applications to third-party certifiers for state grant eligibility. All program certifications must now go directly through the TWC.
Occupation Eligibility: Ensure training programs focus on "manual, mechanical, or technical skills," as the TWC is now statutorily limited to certifying occupations fitting this description.
Reporting & Record-Keeping
Data Tracking: Configure HRIS or LMS platforms immediately to track retention outcomes (employment duration post-certification) and completion rates.
Invoicing: Finance departments must shift from lump-sum or expense-based invoicing to milestone-based invoicing. Accounts Receivable must track these milestones to forecast cash flow accurately.
Fees & Costs
Cash Flow Impact: While there are no new state fees, the shift to milestone-based reimbursement may delay cash inflows compared to previous reimbursement models. Budget for potential lags in reimbursement during the initial transition.
Strategic Ambiguities & Considerations
Definition of "Milestones": The law allows TWC to define when you get paid. If TWC sets milestones heavily toward the end of the program (e.g., 100% payment only upon 1-year retention), businesses will carry the training cost burden longer.
"Generally Consistent" Standard: The TWC must adopt rules consistent with federal 29 C.F.R. Section 29. It is unclear if TWC will adopt a "lite" version or mirror the heavy administrative burden of federal registration.
Occupational Scope: The interpretation of "technical skills" is currently undefined. It is unknown if TWC will extend eligibility to white-collar technical roles (e.g., cybersecurity, logistics) or restrict it to traditional trades.
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The 86th Legislature established the Texas Industry-Recognized Apprenticeship Grant Program to encourage the private sector to develop specialized industry-recognized apprenticeship programs for middle skills careers, which require some education beyond high school but less than a four-year degree, to meet industrial workforce needs in regions impacted by natural disasters and overall workforce shortages. According to a 2022 policy recommendations report by the Texas Commission on Community College Finance, over 54 percent of jobs in Texas at the time were considered middle skill, but only 45 percent of Texans were sufficiently trained for such jobs, thus leaving a "middle skills gap" of roughly 1.4 million Texans. Given this issue and the current labor market being tight with low unemployment rates, as reported by the Texas Workforce Commission (TWC), the program helps deliver in-demand skills to Texans while directly connecting them to employers with available jobs. However, the bill author has informed the committee that TWC has received feedback from employers that the reimbursement timeline under the program is too long, often resulting in employers waiting up to 18 months for reimbursement, as current law does not allow for reimbursement until both the apprenticeship and a 12-month post-training employment period are completed. H.B. 3260 seeks to remedy this situation by authorizing TWC to partially reimburse employers for training under the program as milestones are met during apprenticeship training and employment and requiring TWC to establish Texas-specific parameters for the program.
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 rulemaking authority is expressly granted to the Texas Workforce Commission in SECTIONS 2 and 3 of this bill.
ANALYSIS
H.B. 3260 amends the Labor Code to authorize the Texas Workforce Commission (TWC) by rule to distribute payments constituting a partial reimbursement to an eligible person as milestones for on-the-job training and employment are met by Texas Industry-Recognized Apprenticeship Programs Grant Program participants, in accordance with the grant terms. The bill requires TWC to adopt rules as soon as practicable after the bill's effective date establishing the following for the purposes of administering and enforcing the program:
·which occupations are recognized by TWC as an apprenticeable occupation for the program and the criteria for that determination, which must include that the occupation:
obe customarily learned in a practical way through a structured, systematic program of on-the-job supervised training;
obe clearly identified and commonly recognized throughout an industry;
oinvolve manual, mechanical, or technical skills or knowledge which requires significant on-the-job work experience; and
orequire related instruction to supplement the on-the-job training; and
·a process for and the criteria by which TWC may certify a training program as an industry-recognized apprenticeship program for purposes of the grant program.
The bill updates the definition of "industry-recognized apprenticeship program" accordingly to reflect the TWC role in recognizing and certifying such a program and requires the criteria by which TWC may certify a training program to be generally consistent with the standards of apprenticeship prescribed by federal regulations providing labor standards for the registration of apprenticeship programs.
H.B. 3260 applies only to a grant awarded on or after the bill's effective date. A grant awarded before that date is governed by the law in effect on the date the grant was awarded, and the former law is continued in effect for that purpose.
HB3260 centralizes authority for the Texas Industry-Recognized Apprenticeship Programs (IRAP) Grant Program under the Texas Workforce Commission (TWC), eliminating the reliance on federal Department of Labor or third-party certifiers effective June 20, 2025. This legislation fundamentally alters the cash flow model for grant recipients by mandating milestone-based reimbursements and introduces strict new reporting requirements regarding apprentice retention and completion rates. Implementation Timeline Effective Date: June 20, 2025 (Immediate effect due to supermajority vote).
Q
Who authored HB3260?
HB3260 was authored by Texas Representative Keith Bell during the Regular Session.
Q
When was HB3260 signed into law?
HB3260 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB3260?
HB3260 is enforced by Texas Workforce Commission.
Q
How urgent is compliance with HB3260?
The compliance urgency for HB3260 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB3260?
The cost impact of HB3260 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB3260 address?
HB3260 addresses topics including economic & industrial development, economic & industrial development--general, labor, labor--workforce development and state finances.
Legislative data provided by LegiScanLast updated: November 25, 2025
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