Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: September 1, 2025
Compliance Deadline:August 1, 2025 (Recommended operational readiness date to ensure intake teams capture attorney data for services rendered on Day 1).
Agency Rulemaking: None. This statute amends the Civil Practice and Remedies Code; enforcement will occur through civil litigation and judicial interpretation, not agency rulemaking.
Immediate Action Plan
1.Audit Billing Software: Confirm by July 15, 2025, that your system can route original bills to an attorney's address without manual intervention.
2.Update Intake Packets: Add a mandatory section for "Legal Representation" on accident-related admission forms.
3.Segregate Legacy Data: Implement a hard logic block preventing attorney-direct billing for any date of service prior to September 1, 2025.
4.Revise Privacy Practices: Ensure your HIPAA Notice of Privacy Practices covers disclosures to legal counsel for payment operations.
Operational Changes Required
Contracts
Letters of Protection (LOPs): Update LOP templates to explicitly state that the provider will bill the attorney of record to satisfy statutory notice requirements.
Revenue Cycle Management (RCM) Agreements: If you outsource billing, amend vendor scopes of work to require "Attorney" as a valid primary billing recipient for PI accounts.
Collection Agency Contracts: Ensure collections vendors are aware that proof of mailing to an attorney is now valid validation of the debt for services post-9/1/2025.
Hiring/Training
Front Desk/Intake: Staff must be trained to request attorney contact information at the point of service for all accident/injury cases.
Billing Specialists: Staff must be trained on the "Strict Cut-Off." They cannot bill attorneys for services rendered prior to September 1, 2025; doing so fails to meet the statutory requirement for those legacy claims.
Reporting & Record-Keeping
Intake Forms: Create a specific field for "Attorney Name/Address" and a checkbox for "Patient Consent to Bill Attorney."
Proof of Mailing: Configure systems to retain metadata or certified mail logs proving the bill was sent to the attorney's address *as listed in your records*.
Opt-Out Documentation: The law allows billing the attorney "unless otherwise directed by the patient." You must create a mechanism to document if a patient verbally or in writing prohibits billing the attorney, forcing a reversion to direct patient billing.
Fees & Costs
Software Configuration: Expect one-time costs to update Practice Management Systems (PMS) or Electronic Health Records (EHR) to allow "Attorney" to function as a guarantor/payer for billing logic purposes.
No State Fees: There are no new filing fees associated with this bill.
Strategic Ambiguities & Considerations
"Related to" Scope: The law applies to services "related to a personal injury claim." It is unclear how courts will treat "mixed" visits (e.g., a patient treated for whiplash *and* a pre-existing chronic condition in the same encounter).
*Risk:* Billing an attorney for unrelated medical history could trigger HIPAA violations or defense arguments that the billing notice was improper.
Attorney Withdrawal: The statute does not explicitly define the provider's duty if an attorney withdraws representation between the date of service and the billing date.
*Risk:* If the attorney withdraws and returns the bill, the 11-month clock is still ticking. You must have a fallback protocol to bill the patient immediately.
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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.
Under current law, a health care provider is required to submit a bill to a patient or other responsible person not later than the first day of the 11th month after providing a health care service, and a failure to comply with this requirement results in the provider forfeiting their right to payment for the service. However, the bill author has informed the committee of concerns raised by some health care providers over parties in personal injury claims using this "timely billing" requirement to avoid paying the provider if the provider submits a patient's bills to the attorney representing the patient rather than to the patient directly, arguing that the attorney is not a responsible person for purposes of timely billing. H.B. 4145 seeks to close this loophole by allowing a health care provider to satisfy timely billing requirements by submitting a patient's bill related to a personal injury claim to the patient's attorney.
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. 4145 amends the Civil Practice and Remedies Code to authorize a health care service provider that provides services to a patient that are related to a personal injury claim for which the patient is represented by an attorney, unless otherwise directed by the patient or other responsible person, to satisfy the statutory requirement to provide the bill for the services to the patient or other responsible person not later than the first day of the 11th month after the date the services are provided by submitting the bill to the patient's attorney in accordance with that deadline.
H.B. 4145 applies only to a health care service provided on or after the bill's effective date. A health care service provided before the bill's effective date is governed by the law in effect immediately before the bill's effective date, and that law is continued in effect for that purpose.
HB4145 fundamentally alters the revenue cycle for health care providers treating personal injury (PI) patients by permitting providers to satisfy the statutory 11-month billing deadline by submitting bills directly to the patient's attorney. This legislation, effective September 1, 2025, mitigates the risk of payment forfeiture due to "lost" bills but requires immediate updates to patient intake forms and billing software logic to distinguish between attorney-represented and standard patients. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: August 1, 2025 (Recommended operational readiness date to ensure intake teams capture attorney data for services rendered on Day 1).
Q
Who authored HB4145?
HB4145 was authored by Texas Representative Paul Dyson during the Regular Session.
Q
When was HB4145 signed into law?
HB4145 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce HB4145?
HB4145 is enforced by Texas Civil Courts (via private litigation disputes).
Q
How urgent is compliance with HB4145?
The compliance urgency for HB4145 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB4145?
The cost impact of HB4145 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB4145 address?
HB4145 addresses topics including civil remedies & liabilities and health care providers.
Legislative data provided by LegiScanLast updated: November 25, 2025
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