Relating to a screening for the risk of commercial sexual exploitation of certain children.
ModeratePlan for compliance
Low Cost
Effective:2025-05-29
Enforcing Agencies
Department of Family and Protective Services (DFPS) • Texas Juvenile Justice Department (via local Juvenile Probation Departments)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: May 29, 2025 (Immediate effect due to supermajority vote).
Compliance Deadline:
Juvenile Justice Providers: Immediate (May 29, 2025). There is no funding contingency for this sector.
DFPS Providers (SSCCs/CPAs): Statutory compliance is contingent on legislative appropriation (expected Sept 1, 2025, for FY2026). However, liability exposure begins immediately; providers should treat May 29 as the operational start date.
Agency Rulemaking: The Child Sex Trafficking Prevention Unit (CSTPU) must formally select/publish the validated tool (likely the CSE-IT). DFPS must update the IMPACT system to accept this data by FY2026.
Immediate Action Plan
Immediate Audit: Review all open cases for children entering care within the last 45 days and schedule screenings immediately.
Update Workflows: Insert a mandatory "CSE Screening" checkpoint in your case management software that blocks file progression if incomplete by Day 40.
Verify Tool: Confirm with the Governor’s Office (CSTPU) that the *CSE-IT* is the designated tool and enroll Lead Case Managers in trainer-the-trainer courses.
Notify Insurers: Alert your Professional Liability carrier that you have adopted a formal CSE screening protocol to potentially safeguard against future negligence claims regarding trafficking.
Operational Changes Required
Contracts
SSCC Master Agreements: Expect amendments incorporating the "45-day screening completion rate" as a performance metric.
IT Vendor Agreements: Third-party case management software (e.g., extendedReach, Casebook) requires immediate change orders to add specific data fields matching the CSTPU-selected tool for export to the state IMPACT system.
Hiring/Training
Certification: Case managers and intake specialists must be trained and certified on the specific tool selected (likely the *Commercial Sexual Exploitation-Identification Tool* or CSE-IT).
Job Descriptions: Update qualifications for Intake Coordinators to require "CSE Risk Assessment Certification."
Reporting & Record-Keeping
The 45-Day Hard Stop (DFPS): Intake workflows must mandate screening completion no later than the 45th day of conservatorship.
Pre-Disposition Gate (Juvenile): Case files cannot be cleared for disposition hearings without a completed screening recorded in the file.
Justification Logs: For children under 10 (or outside the tool's standard age range), staff must document specific behavioral "concerns" that triggered the screening to justify the clinical decision.
Fees & Costs
Training Costs: While the state plans to outsource training in FY2026, providers needing immediate compliance may incur costs for private training on the CSE-IT.
IT Integration: Budget for software development hours to bridge internal systems with the upgraded IMPACT reporting requirements.
Strategic Ambiguities & Considerations
The "Under 10" Gap: The industry-standard tool (CSE-IT) is validated for ages 10+. The law requires screening younger children if "concerns exist," but the modified pediatric tool is not yet released. Providers must define internal protocols for documenting "concerns" for ages 0-9 to avoid negligence claims before the state tool is ready.
Funding Contingency Split: Section 3 makes DFPS implementation contingent on funding, but Section 2 (Juvenile Justice) does not. Juvenile providers are legally exposed immediately, regardless of whether the state provides additional funding.
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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.
According to the U.S. Department of Health and Human Services' Administration for Children and Families, up to half of child sex trafficking victims have spent time in the foster care system. The Child Sex Trafficking Prevention Unit within the governor's criminal justice division identified a validated and applicable universal screening tool for children ages 10 and up. The Office of the Governor worked with both the Department of Family and Protective Services (DFPS) and juvenile probation departments to implement screening for the most at-risk children. Despite the tool's current use, significant gaps in screening remain. According to data provided by DFPS, only 386 children were screened by DFPS in 2022, a fraction of the total number of children in foster care that year.
C.S.H.B. 451 seeks to require DFPS, for purposes of preventing children from falling through the cracks, avoiding further victimization, and better protecting children in the state's care, to screen children for risk of commercial sexual exploitation within 45 days of entering the state's conservatorship using a validated and evidence-informed screening tool, if validation guidelines based on the child's age indicate the screening is appropriate or concerns of commercial sexual exploitation exist. C.S.H.B. 451 also requires a risk and needs assessment completed by a juvenile probation department for each child under the department's jurisdiction to include a screening for the risk of commercial sexual exploitation using a validated, evidence-informed tool. The bill makes the governor's Child Sex Trafficking Prevention Unit, as outlined in the bill, responsible for selecting the screening tool.
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
C.S.H.B. 451 amends the Family Code to require a child who enters the conservatorship of the Department of Family and Protective Services (DFPS) to receive, not later than the 45th day after the date the child enters the conservatorship, a screening for risk of commercial sexual exploitation using a validated, evidence-informed tool selected by the Child Sex Trafficking Prevention Unit within the governor's criminal justice division if one of the following conditions applies:
·validation guidelines based on the child's age indicate the screening is appropriate; or
·concerns of commercial sexual exploitation exist.
C.S.H.B. 451 amends the Human Resources Code to require a risk and needs assessment completed by a juvenile probation department for each child under the department's jurisdiction to include the screening specified under the bill's provisions.
EFFECTIVE DATE
September 1, 2025.
COMPARISON OF INTRODUCED AND SUBSTITUTE
While C.S.H.B. 451 may differ from the introduced in minor or nonsubstantive ways, the following summarizes the substantial differences between the introduced and committee substitute versions of the bill.
Whereas the introduced required a screening for risk of commercial sexual exploitation to be included in the developmentally appropriate comprehensive assessment received by a child after entering DFPS conservatorship, the substitute requires a child to receive the screening after entering DFPS conservatorship if one of the following conditions, which were absent from the introduced, applies:
·validation guidelines based on the child's age indicate the screening is appropriate; or
·concerns of commercial sexual exploitation exist.
With respect to the tool used by DFPS for the screening, the introduced specified that the tool is a validated screening tool, while the substitute specifies that the tool is a validated, evidence-informed tool.
With respect to the tool used by a juvenile probation department for the screening, the introduced specified that the tool is a screening tool, while the substitute specifies that the tool is a validated, evidence-informed tool.
Honorable Lacey Hull, Chair, House Committee on Human Services
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
HB451 by Thompson (Relating to a screening for the risk of commercial sexual exploitation of certain children.), As Introduced
Estimated Two-year Net Impact to General Revenue Related Funds for HB451, As Introduced: a negative impact of ($1,570,261) through the biennium ending August 31, 2027.
General Revenue-Related Funds, Five- Year Impact:
Fiscal Year
Probable Net Positive/(Negative) Impact to General Revenue Related Funds
2026
($973,342)
2027
($596,919)
2028
($146,621)
2029
($146,745)
2030
($146,621)
All Funds, Five-Year Impact:
Fiscal Year
Probable Savings/(Cost) from General Revenue Fund 1
Probable Savings/(Cost) from GR Match For Medicaid 758
Probable Savings/(Cost) from Federal Funds 555
Change in Number of State Employees from FY 2025
2026
($965,592)
($7,750)
($102,227)
4.0
2027
($591,593)
($5,326)
($69,731)
3.0
2028
($145,308)
($1,313)
($9,787)
1.0
2029
($145,431)
($1,314)
($9,795)
1.0
2030
($145,308)
($1,313)
($9,787)
1.0
Fiscal Analysis
The bill would require the Department of Family and Protective Services (DFPS) to screen for the risk of commercial sexual exploitation using a validated screening tool selected by the Child Sex Trafficking Prevention Unit no later than 45 days after a child enters the conservatorship of DFPS.
The bill would require juvenile probation departments to screen for risk of commercial sexual exploitation using a screening tool selected by the Child Sex Trafficking Prevention Unitbefore the disposition of a child's case.
Methodology
To date, the Child Sex Trafficking Prevention Unit has allowed DFPS to utilize the Commercial Sexual Exploitation-Identification Tool (CSE-IT) created by the West Coast Children's Clinic as an assessment tool for children 10 and older. This analysis assumes that DFPS would continue to utilize this screening tool and that it will be modified to assess children under the age of 10. To train current DFPS staff on the screening tool, it is assumed that those trainings will be outsourced in fiscal year 2026, to expedite the process to ensure current staff can comply with the assessment requirements. Any new staff in fiscal year 2026 and in each subsequent fiscal year will be trained internally. To achieve this, it is assumed DFPS would need 1.0 Training and Development Specialist V in each fiscal year.
It is also assumed that to ensure that assessments are done for all children and have the information be included in their case file, upgrades would be needed for the Information Management Protecting Children and Adults in Texas (IMPACT) system. The changes would integrate the screening tool into the system of record in IMPACT. Additionally, it is assumed that DFPS would include the Single Source Continuum Contractors in the design and development process to ensure their assessments are included in IMPACT. Currently, the screening tool is a standalone software that requires manual entry and is difficult to be used for monitoring and compliance. To upgrade IMPACT, this analysis assumes the need of 3.0 System Analyst V FTEs in fiscal year 2026 and 2.0 System Analyst V FTEs in fiscal year 2027.
It is assumed that any costs to the Texas Juvenile Justice Department could be absorbed within existing appropriations.
Technology
Technology related costs including the enhancements to the IMPACT system are estimated to be $674,604 in fiscal year 2026 and $456,482 in fiscal year 2027.
Local Government Impact
The fiscal impact to juvenile probation departments cannot be determined. The impact would depend on if the local jurisdiction is already providing assessments or if they would need to hire someone to conduct the assessments. Additionally, the impact would also depend on if the juvenile probation departments will be using the existing CSE-IT tool or if they would need to use and learn a new tool.
Source Agencies:
530 Family and Protective Services, Department of, 644 Juvenile Justice Department
LBB Staff:
JMc, NPe, ER, AN, NV
Related Legislation
Explore more bills from this author and on related topics
HB451 converts Commercial Sexual Exploitation (CSE) screening from a clinical best practice into a statutory mandate with strict liability implications. Single Source Continuum Contractors (SSCCs), Child Placing Agencies (CPAs), and Juvenile Probation vendors must immediately integrate a specific, state-validated screening tool into their intake workflows to meet hard deadlines for every child in care. Implementation Timeline Effective Date: May 29, 2025 (Immediate effect due to supermajority vote).
Q
Who authored HB451?
HB451 was authored by Texas Representative Senfronia Thompson during the Regular Session.
Q
When was HB451 signed into law?
HB451 was signed into law by Governor Greg Abbott on May 29, 2025.
Q
Which agencies enforce HB451?
HB451 is enforced by Department of Family and Protective Services (DFPS) and Texas Juvenile Justice Department (via local Juvenile Probation Departments).
Q
How urgent is compliance with HB451?
The compliance urgency for HB451 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of HB451?
The cost impact of HB451 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does HB451 address?
HB451 addresses topics including family, family--child protection, minors, minors--crimes against and minors--health & safety.
Legislative data provided by LegiScanLast updated: November 25, 2025
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