Regular Session
Government Affairs & Regulatory Compliance Analysis
HB923 fundamentally restructures the Texas Medical Disclosure Panel (TMDP) effective June 20, 2025, expanding its membership from 9 to 13 to include patient advocates and health literacy experts. While this does not invalidate current informed consent forms immediately, healthcare providers must anticipate a regulatory shift toward "plain language" disclosures and stricter patient-centric requirements beginning in 2026.
Rep. Cassandra Garcia Hernandez·House Bill·Regular Session
Health and Human Services Commission (HHSC) • Texas Medical Disclosure Panel
This legislation has regulatory implications for the following Texas businesses and organizations:
Standard regulatory changes (effective 2025-06-20). Review during normal business planning.
Affected business types:
lowMinimal cost impact anticipated.
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Key implementation requirements and action items for compliance with this legislation
Informed Consent Documents: No immediate changes are required for standard admission or procedure consent forms. However, General Counsel should prepare for a mandatory revision of these documents in 2026. The new panel composition makes it highly probable that current "legalese" in consent forms will be challenged.
Risk Management Monitoring: Designate a Risk Management Officer or Compliance Lead to monitor TMDP meeting minutes starting January 2026. No new certifications are required for clinical staff.
Internal Audits: Providers should audit their current utilization of TMDP disclosure forms. Ensure your facility is using the most current version *now*, so that when the panel updates the requirements, you are not two cycles behind.
Budget Neutral: There are no new state fees or licensure costs associated with this legislation.
"Health Literacy" Interpretation: The law mandates the appointment of a member with a background in "health literacy." The statute does not define the metric for this (e.g., 6th-grade reading level vs. 8th-grade). If the new panel adopts a strict health literacy standard, entire libraries of standard consent forms may need to be rewritten and reprinted to maintain the liability shield.
Public Interest vs. Provider Expertise: The law prohibits public members from having ties to healthcare or insurance industries. This creates a potential adversarial dynamic within the panel. While the "physician quorum" rule protects against clinical errors, the "public interest" mandate may lead to broader, more cumbersome disclosure lists.
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
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Common questions about HB923
HB923 fundamentally restructures the Texas Medical Disclosure Panel (TMDP) effective June 20, 2025, expanding its membership from 9 to 13 to include patient advocates and health literacy experts. While this does not invalidate current informed consent forms immediately, healthcare providers must anticipate a regulatory shift toward "plain language" disclosures and stricter patient-centric requirements beginning in 2026.
HB923 was authored by Texas Representative Cassandra Garcia Hernandez during the Regular Session.
HB923 was signed into law by Governor Greg Abbott on June 20, 2025.
HB923 is enforced by Health and Human Services Commission (HHSC) and Texas Medical Disclosure Panel.
The regulatory priority for HB923 is rated as "low". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of HB923 is estimated as "low". This may vary based on industry and implementation requirements.
HB923 addresses topics including health care providers, health, health--general, physicians and health & human services commission.
Key dates for HB923: Effective date is 2025-06-20. Rulemaking: Executive Commissioner must appoint new members to the Texas Medical Disclosure Panel, expanding the body to 13 members (including new public and attorney representatives). (2026-01-01). Consult with legal counsel regarding applicability.
HB923 primarily affects 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.
