Regular Session
Government Affairs & Regulatory Compliance Analysis
Texas has mandated the standardization of the Coordination of Benefits (COB) process, effectively outlawing the use of proprietary carrier forms for health benefit plans, including those sponsored by Professional Employer Organizations (PEOs). All entities managing health claims must transition to a single, state-designed questionnaire by February 1, 2026, creating a critical operational pivot point for claims adjudication systems.
Rep. Caroline Harris Davila·House Bill·Regular Session
This legislation has regulatory implications for the following Texas businesses and organizations:
Notable regulatory updates (effective 2025-06-20). Consider how these changes may affect your operations.
Affected business types:
Affected business types:
lowMinimal cost impact anticipated.
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 legislation leaves specific operational details to TDI rulemaking. Watch for the following during the stakeholder process:
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
Explore more bills from this author and on related topics
Common questions about HB388
Texas has mandated the standardization of the Coordination of Benefits (COB) process, effectively outlawing the use of proprietary carrier forms for health benefit plans, including those sponsored by Professional Employer Organizations (PEOs). All entities managing health claims must transition to a single, state-designed questionnaire by February 1, 2026, creating a critical operational pivot point for claims adjudication systems.
HB388 was authored by Texas Representative Caroline Harris Davila during the Regular Session.
HB388 was signed into law by Governor Greg Abbott on June 20, 2025.
HB388 is enforced by Texas Department of Insurance.
The regulatory priority for HB388 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB388 is estimated as "low". This may vary based on industry and implementation requirements.
HB388 addresses topics including insurance, insurance--health & accident, insurance, commissioner of and employee benefits & leave.
Key dates for HB388: Effective date is 2025-06-20. Rulemaking: Adopt rules establishing the mandatory uniform coordination of benefits questionnaire in collaboration with stakeholders. (2026-01-01). Consult with legal counsel regarding applicability.
HB388 primarily affects insurance companies and financial institutions, 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.
