SB1952

Regular Session

Relating to the administration and operation of the school health and related services program.

ModeratePlan for compliance

Low Cost

Effective:2025-09-01

Enforcing Agencies

Health and Human Services Commission (HHSC) - Designated as the sole state agency responsible for administration • Texas Education Agency (TEA) - Via Memorandum of Understanding

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

Effective Date: September 1, 2025.
Compliance Deadline: September 1, 2025. You must align internal compliance protocols with HHSC standards by this date.
Agency Rulemaking: HHSC and TEA must execute a Memorandum of Understanding (MOU) defining specific responsibilities. While the law is effective in September, the operational details will remain in a "regulatory gray zone" until this MOU is published and HHSC issues specific provider training protocols.

Immediate Action Plan

Redirect Compliance Feeds: Instruct compliance officers to monitor HHSC provider notices and the Texas Medicaid Provider Procedures Manual (TMPPM) as the primary source of truth, bypassing TEA advisories regarding billing.
Audit Vendor Contracts: Review all third-party billing contracts to ensure vendors are contractually obligated to follow HHSC (not TEA) standards.
Verify Insurance Coverage: Confirm that your Directors & Officers (D&O) or Errors & Omissions (E&O) liability policies cover Medicaid recoupment actions, as the "educational error" defense will no longer apply.
Establish ESC Contact: Appoint a liaison to your Regional Education Service Center (ESC) specifically to track the rollout of HHSC training materials.

Operational Changes Required

Contracts

Third-Party Billing Vendors: You must amend Master Services Agreements (MSAs) immediately.

Replace vague references to "state guidelines" with specific citations to HHSC regulations and the Texas Medicaid Provider Procedures Manual (TMPPM).
Update indemnification clauses to protect the LEA specifically against recoupments caused by vendor failure to adhere to new HHSC-mandated protocols.

Healthcare Staffing:

Update agreements with therapy and nursing staffing agencies to require participation in HHSC-administered training as a condition of payment.

Hiring/Training

Mandatory Training: The law mandates HHSC-administered training. Previous TEA-sponsored training credits may effectively expire on September 1.
Staffing: Ensure Special Education Directors and Finance Officers are subscribed to HHSC provider notices, not just TEA advisories.

Reporting & Record-Keeping

Audit Standards: Transition all documentation standards from educational (IEP-focused) to medical (Medicaid-focused). Records must explicitly prove medical necessity and include physician referrals/prescriptions to survive HHSC scrutiny.
Training Logs: Maintain rigorous logs of staff attendance at new HHSC training sessions; these will be requested during audits to verify provider qualifications.

Fees & Costs

Direct Costs: No new statutory fees are introduced.
Indirect Costs: Budget for administrative hours required for staff retraining and contract legal review.
Financial Risk: Expect increased recoupment risk as audits shift to a stricter medical standard.

Strategic Ambiguities & Considerations

The MOU (Section 1(d)): The specific division of labor remains undefined until HHSC and TEA sign the Memorandum of Understanding. It is currently unclear if TEA will retain any role in financial transfers or if they will serve a purely advisory function.
Training Frequency: The bill requires HHSC to "administer provider training" but does not define the frequency, format, or certification requirements. Watch the Texas Register for HHSC rulemaking that defines these parameters.

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Legislative Timeline

This bill's path through the Texas Legislature

TopicsEducation Education--school Districts Human Services Human Services--medical Assistance Education--primary & Secondary Education--primary & Secondary--charter Schools Regional Education Service Centers Staff Development & Training Education Agency, Texas Health & Human Services Commission

Official Analysis

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BILL ANALYSIS

Senate Research Center	S.B. 1952
89R1693 MM-F	By: Paxton; Sparks
	Health & Human Services
	4/11/2025
	As Filed

AUTHOR'S / SPONSOR'S STATEMENT OF INTENT

School Health and Related Services (SHARS) is a federally funded program that provides Medicaid reimbursement to participating local education agencies, including school districts and public charter schools. It delivers direct medical services to Medicaid-eligible special education students in the school environment, as specified in a student's individualized education program.

By granting the Health and Human Services Commission (HHSC) sole administration over the SHARS program, this bill prevents a recurrence of the situation in which Texas schools improperly billed SHARS due to inadequate oversight. HHSC's oversight helps ensure that Texas properly applies for and receives Medicaid reimbursement for school-based health services.

As proposed, S.B. 1952 amends current law relating to the administration and operation of the school health and related services program.

RULEMAKING AUTHORITY

This bill does not expressly grant any additional rulemaking authority to a state officer, institution, or agency.

SECTION BY SECTION ANALYSIS

SECTION 1. Amends Subchapter B, Chapter 532, Government Code, as effective April 1, 2025, by adding Section 532.00515, as follows:

Sec. 532.00515. SCHOOL HEALTH AND RELATED SERVICES PROGRAM. (a) Defines "local education agency" and "regional education service center."

(b) Provides that the Texas Health and Human Services Commission (HHSC), in accordance with Section 532.0051(a) (relating to providing that HHSC is the state agency designated to administer federal Medicaid funds), is the sole state agency responsible for administering the school health and related services program.

(1) oversee the participation of local education agencies as providers in the school health and related services program, including the administration of provider training and the provision of information and guidance regarding the program to those providers, including guidance on applicable federal and state regulatory requirements; and

(2) collaborate with regional education service centers to provide resources, information, and other appropriate assistance to local education agencies participating or seeking to participate as providers in the school health and related services program.

(d) Requires HHSC and the Texas Education Agency to enter into a memorandum of understanding that specifically identifies the responsibilities of each agency with respect to operating the school health and related services program.

SECTION 2. Requires a state agency, if necessary for implementation of a provision of this Act, to request a waiver or authorization from a federal agency, and authorizes a delay of implementation until such a waiver or authorization is granted.

SECTION 3. Effective date: upon passage or September 1, 2025.

Senate Authors

Sen. Angela PaxtonRepublican · Primary Author

Joint Authors

Kevin Sparks (R)

House Sponsor

Rep. Lacey HullRepublican · Primary Sponsor

Bill Text(with markup)

S.B. No. 1952

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

	AN ACT
	relating to the administration and operation of the school health
	and related services program.
	BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:
	SECTION 1. Subchapter B, Chapter 532, Government Code, as
	effective April 1, 2025, is amended by adding Section 532.00515 to
	read as follows:
	Sec. 532.00515. SCHOOL HEALTH AND RELATED SERVICES PROGRAM.
	(a) In this section:
	(1) "Local education agency" includes a school
	district or open-enrollment charter school.
	(2) "Regional education service center" means a
	regional education service center established under Chapter 8,
	Education Code.
	(b) In accordance with Section 532.0051(a), the commission
	is the sole state agency responsible for administering the school
	health and related services program.
	(c) The commission shall:
	(1) oversee the participation of local education
	agencies as providers in the school health and related services
	program, including:
	(A) the administration of provider training; and
	(B) the provision of information and guidance
	regarding the program to those providers, including guidance on
	applicable federal and state regulatory requirements; and
	(2) collaborate with regional education service
	centers to provide resources, information, and other appropriate
	assistance to local education agencies participating or seeking to
	participate as providers in the school health and related services
	program.
	(d) The commission and the Texas Education Agency shall
	enter into a memorandum of understanding that specifically
	identifies the responsibilities of each agency with respect to
	operating the school health and related services program.
	SECTION 2. If before implementing any provision of this Act
	a state agency determines that a waiver or authorization from a
	federal agency is necessary for implementation of that provision,
	the agency affected by the provision shall request the waiver or
	authorization and may delay implementing that provision until the
	waiver or authorization is granted.
	SECTION 3. This Act takes effect immediately if it receives
	a vote of two-thirds of all the members elected to each house, as
	provided by Section 39, Article III, Texas Constitution. If this
	Act does not receive the vote necessary for immediate effect, this
	Act takes effect September 1, 2025.

LEGISLATIVE BUDGET BOARD
Austin, Texas

FISCAL NOTE, 89TH LEGISLATIVE REGULAR SESSION


April 14, 2025

TO:	Honorable Lois W. Kolkhorst, Chair, Senate Committee on Health & Human Services

FROM:	Jerry McGinty, Director, Legislative Budget Board

IN RE:	SB1952 by Paxton (Relating to the administration and operation of the school health and related services program.), As Introduced

No significant fiscal implication to the State is anticipated.

The bill would establish the Health and Human Services Commission (HHSC) as the sole state agency responsible for administering the School Health and Related Services (SHARS) program and define HHSC's responsibilities as such. The bill would require HHSC to enter into a memorandum of understanding with the Texas Education Agency to identify the responsibilities of each agency with respect to operating the SHARS program.

The bill would take effect immediately upon receiving a vote of two-thirds of all members elected to each house or, otherwise, on September 1, 2025.

It is assumed that any costs associated with the bill could be absorbed using existing resources.

Local Government Impact

No significant fiscal implication to units of local government is anticipated.

Source Agencies:

529 Health and Human Services Commission, 701 Texas Education Agency

LBB Staff:

JMc, NPe, ER, ESch

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Frequently Asked Questions

Common questions about SB1952

What does Texas SB1952 do?

SB1952 designates the Health and Human Services Commission (HHSC) as the sole administrator for the School Health and Related Services (SHARS) program, effectively removing the Texas Education Agency (TEA) from operational oversight. This legislation impacts all Local Education Agencies (LEAs), third-party billing vendors, and contracted healthcare providers by shifting the program from an educational support framework to a strict medical compliance model. Implementation Timeline Effective Date: September 1, 2025.

Who authored SB1952?

SB1952 was authored by Texas Senator Angela Paxton during the Regular Session.

When was SB1952 signed into law?

SB1952 was signed into law by Governor Greg Abbott on June 20, 2025.

Which agencies enforce SB1952?

SB1952 is enforced by Health and Human Services Commission (HHSC) - Designated as the sole state agency responsible for administration and Texas Education Agency (TEA) - Via Memorandum of Understanding.

How urgent is compliance with SB1952?

The compliance urgency for SB1952 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of SB1952?

The cost impact of SB1952 is estimated as "low". This may vary based on industry and implementation requirements.

What topics does SB1952 address?

SB1952 addresses topics including education, education--school districts, human services, human services--medical assistance and education--primary & secondary.

Legislative data provided by LegiScanLast updated: November 25, 2025

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