JD Key Consulting Logo
Signed Into Law
Signed May 29, 2025Effective 2025-10-01
HB3594

Regular Session

Relating to the administration of a retirement health care plan for firefighters and police officers in certain municipalities.

Government Affairs & Regulatory Compliance Analysis

HB3594: Government Affairs Overview

HB3594 fundamentally restructures the administrative timeline for the San Antonio Fire and Police Retiree Health Care Fund, introducing strict 30-day and 60-day deadlines for FMLA service credit buybacks and retirement contribution elections. These changes, effective October 1, 2025, place immediate operational pressure on municipal HR departments and Fund administrators to update payroll triggers and election forms to avoid irreversible benefit forfeitures and civil liability.

Rep. John Lujan·House Bill·Regular Session

Moderate
Medium Cost
Effective:2025-10-01
Enforcing Agencies

Board of Trustees of the Firefighters' and Police Officers' Retiree Health Care Fund (San Antonio)

Business Impact

Who HB3594 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: moderate

Notable regulatory updates (effective 2025-10-01). Consider how these changes may affect your operations.

🏥

Healthcare

Affected business types:

  • Hospitals
  • Healthcare systems
  • Medical practices
  • Health insurance providers
View all healthcare legislation

Key Operational Considerations

  • 1Retirement Counseling: Counselors must be trained to present the new "Lump Sum" payment option and the "Conditional Waiver" for married dual-members during pre-retirement sessions.

Estimated Cost Impact

mediumModerate costs expected for implementation.

Need Government Relations Support?

JD Key Consulting provides government affairs and regulatory strategy services. We help businesses navigate Texas agencies, understand legislative impacts, and advocate for their interests.

Need Help Navigating This Legislation?

JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.

HB3594
Relating to the administration of a retirement health care plan for firefighters and police officers in certain municipalities.
Moderate Urgency
Unanimous Passage
House Vote146 - 0
YEA
100% in favor146 voting
Senate Vote31 - 0
YEA
100% in favor31 voting
Cost Impact
Medium
Effective
2025-10-01
Enforcing Agencies
Board of Trustees of the Firefig...
Primary Author: Rep. John Lujan
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: October 1, 2025.
  • Compliance Deadline: October 1, 2025 (Hard stop for new forms and payroll logic).
  • Agency Rulemaking: The Board of Trustees must prescribe forms for lump-sum elections and conditional waivers prior to the effective date. Expect a "regulatory gray zone" between May 2025 and September 2025 as actuarial formulas for lump-sum payments are finalized.

Immediate Action Plan

  • Configure Payroll Triggers: Program a strict 60-day alert for all FMLA return-to-work dates to ensure municipal matching payments are timely.
  • Audit Vendor Contracts: Ratify any service contracts not explicitly executed by the Board of Trustees to ensure enforceability.
  • Update Retirement Packets: Insert the "Lump Sum" option and "Conditional Waiver" forms into pre-retirement counseling materials immediately.
  • Establish Date-Stamping Protocols: Create a rigid intake process for divorce-related reinstatement requests to defend against eligibility disputes regarding the 30-day window.

Operational Changes Required

Contracts

  • Vendor Agreements: Review all professional service agreements (investment, legal, auditing). Under Section 14, the Board has *exclusive* contracting authority; contracts executed by municipal designees may be voidable and must be ratified by the Board.
  • Marital Settlement Agreements: Family law attorneys must revise standard divorce decree templates. Section 12(l) explicitly excludes Fund health benefits from being treated as divisible marital property; the Fund will reject court orders attempting to divide these assets.

Hiring/Training

  • FMLA Protocols: Municipal HR staff require immediate training on the new FMLA "buyback" clock. Personnel must understand that missing the 60-day employer matching window triggers liability for denied service credits.
  • Retirement Counseling: Counselors must be trained to present the new "Lump Sum" payment option and the "Conditional Waiver" for married dual-members during pre-retirement sessions.

Reporting & Record-Keeping

  • New Mandatory Forms: You must implement and distribute three specific forms by the effective date:
  • 1. Irrevocable Lump-Sum Election: Must include waiver of refund rights.
  • 2. Conditional Waiver of Eligibility: For married couples within the system.
  • 3. Reinstatement of Eligibility: For divorced retirees who previously waived coverage.
  • Audit Trail: Systems must timestamp the *receipt date* of these forms. Eligibility reinstatement is strictly limited to a 30-day window following divorce; a date stamp is your primary defense against litigation.

Fees & Costs

  • Dependent Child Premiums: The Board now has statutory authority to levy premiums for dependent children. Budget for this potential cost shift to retirees.
  • Late Payment Penalties: Update accounting systems to calculate interest on late remittances at the "Default Rate" (the Fund's actuarial assumed rate of return), rather than a standard statutory interest rate.

Strategic Ambiguities & Considerations

  • "Default Rate" Volatility: Penalties are tied to the "actuarial assumed rate of return." If this rate fluctuates annually based on market performance, penalty calculations will require constant updating in payroll systems.
  • Dependent Premium Formulas: The statute authorizes premiums for children but provides no cap or calculation method. Monitor Board meeting minutes closely for the release of the fee schedule, as this is left entirely to agency discretion.

Need Compliance Guidance on This Legislation?

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 Consultation

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.

02

Legislative Timeline

This bill's path through the Texas Legislature

Filed
Mar 3, 2025
Passed House
May 8, 2025
Passed Senate
May 19, 2025
Signed
May 29, 2025
Effective
Oct 1, 2025
TopicsCity GovernmentCity Government--employees/officersFamilyFamily--marriage RelationshipFire Fighters & PoliceFire Fighters & Police--generalRetirement SystemsRetirement Systems--municipalRetirement Systems--police & FirefightersFamily & Medical LeaveMilitary & Veterans
03

House Authors

Rep. John LujanRepublican · Primary Author
Joint Authors
Coauthors (2)

Senate Sponsor

Sen. Jose MenendezDemocrat · Primary Sponsor

Bill Text(with markup)

Showing first 50k characters.

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

Explore more bills from this author and on related topics

More from Rep. John Lujan

View all bills by Rep. John Lujan

Related by Topic

View more City Government legislation
Quick Reference

Frequently Asked Questions

Common questions about HB3594

Q

What does Texas HB3594 do?

HB3594 fundamentally restructures the administrative timeline for the San Antonio Fire and Police Retiree Health Care Fund, introducing strict 30-day and 60-day deadlines for FMLA service credit buybacks and retirement contribution elections. These changes, effective October 1, 2025, place immediate operational pressure on municipal HR departments and Fund administrators to update payroll triggers and election forms to avoid irreversible benefit forfeitures and civil liability.

Q

Who authored HB3594?

HB3594 was authored by Texas Representative John Lujan during the Regular Session.

Q

When was HB3594 signed into law?

HB3594 was signed into law by Governor Greg Abbott on May 29, 2025.

Q

Which agencies enforce HB3594?

HB3594 is enforced by Board of Trustees of the Firefighters' and Police Officers' Retiree Health Care Fund (San Antonio).

Q

How significant are the changes in HB3594?

The regulatory priority for HB3594 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of HB3594?

The cost impact of HB3594 is estimated as "medium". This may vary based on industry and implementation requirements.

Q

What topics does HB3594 address?

HB3594 addresses topics including city government, city government--employees/officers, family, family--marriage relationship and fire fighters & police.

Q

What are the key dates for HB3594?

Key dates for HB3594: Effective date is 2025-10-01. Rulemaking: Must prescribe forms and procedures for: lump-sum payment elections, conditional waivers of eligibility for married retirees, and unconditional waivers of rights. (2025-10-01). Consult with legal counsel regarding applicability.

Q

What are the penalties under HB3594?

HB3594 establishes the following penalties: civil penalty of Interest calculated at the 'default rate' (actuarial assumed rate of return) for Failure to remit required monthly retiree contributions by the last day of the month.; administrative penalty of Forfeiture of service credit for the leave period for Failure to pay voluntary contributions for FMLA leave within 30 days of returning to work.; administrative penalty of Discontinuation of benefits for Failure to make required monthly contributions.. Consult with legal counsel for specific applicability to your situation.

Need Strategic Guidance on This Legislation?

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.

Legislative data provided by LegiScanLast updated: January 11, 2026