Relating to the Texas Physician Health Program and the regulation of certain occupations by the Texas Medical Board; expanding the applicability of surcharges.
ModeratePlan for compliance
Low Cost
Effective:2025-09-01
Enforcing Agencies
Texas Medical Board
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: September 1, 2025
Compliance Deadline:December 1, 2025 (Surcharges and new application requirements apply to filings submitted on or after this date).
Agency Rulemaking: The TMB is required to adopt rules implementing these changes by December 1, 2025. Expect a "regulatory gray zone" between September and November 2025 where the law is active but fee structures are not yet finalized.
Immediate Action Plan
1.Audit Roster: Identify all employees holding TMB-regulated allied health licenses (MRTs, LMRTs, Respiratory Care, Perfusionists, Acupuncturists).
2.Execute "Early Bird" Renewals: Instruct staff with renewals due in December 2025 or January 2026 to submit applications before December 1, 2025, to lock in current rates and delay new monitoring requirements for one cycle.
3.Adjust FY2026 Budget: Factor in the ~$16.25 increase per head for all affected allied health staff.
4.Monitor Rulemaking: Assign compliance staff to track TMB proposed rules in Fall 2025 regarding the definition of "relevant information" from the NPDB.
Operational Changes Required
Contracts
Staffing Agency MSAs: Update Master Service Agreements with allied health staffing vendors. Require warranties that placed staff (e.g., MRTs, Respiratory Therapists) are compliant with the new Texas Physician Health Program (TxPHP) requirements.
Employment Agreements: Review "Licensure Reimbursement" clauses. If you cap reimbursement at a fixed dollar amount, the new surcharges (approx. $16.25 increase) may trigger contract disputes or require payroll adjustments.
Hiring/Training
Credentialing Protocols: The TMB will now perform "continuous queries" on the NPDB. Credentialing staff must increase the frequency of license verification checks; a clear license can now be flagged with disciplinary data within 10 days of a federal report.
Adverse Action Reporting: HR teams must be trained that allied health professionals are now subject to mandatory TxPHP participation for substance or mental health issues as a condition of licensure.
Reporting & Record-Keeping
Profile Alignment: Internal credentialing files must mirror the TMB public profile. If the TMB updates a profile based on an NPDB hit, your internal records must reflect this immediately to avoid negligent credentialing liability.
Surcharge Accounting: Update accounts payable systems to recognize two new line items for allied health renewals: the TxPHP Surcharge and the NPDB Query Surcharge.
Fees & Costs
Budget Impact: Anticipate an increase of approximately $16.25 per licensee per renewal cycle.
Specific Fees:
TxPHP Surcharge: Capped at $15 (Fiscal Note estimates $5.25).
NPDB Query Surcharge: At cost (Fiscal Note estimates $11.00).
Penalty: Failure to pay these surcharges results in automatic denial of licensure or renewal.
Strategic Ambiguities & Considerations
"Relevant Information" Threshold: The statute allows the Board to query the NPDB for "relevant information." It is currently unclear what level of federal data (e.g., minor administrative flags vs. major malpractice payments) will trigger a public profile update for allied health professionals.
TxPHP Referral Triggers: The Board has discretion on requiring TxPHP participation. Rulemaking must clarify the threshold for mandatory referral versus voluntary self-referral for these newly affected occupation groups.
Final Fee Schedule: While estimates exist, the exact dollar amounts will be set during the October/November 2025 Board meetings.
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The 88th Texas Legislature, Regular Session, 2023, passed H.B. 1998, which reorganized the funding mechanism for the Texas Physician Health Program (TxPHP) from a participation fee to a surcharge on license renewals. TxPHP provides confidential early intervention, assessment, treatment referral, and post-treatment monitoring for health professionals under the Texas Medical Board's (TMB) jurisdiction who may be unable to practice safely due to an impairing or potentially impairing health condition. The program's participants include physicians, physician assistants, surgical assistants, perfusionists, medical students, and other license holders governed by TMB. Since all TMB licensees�not just physicians�are participating in this program, the intent of H.B. 1998 was for this surcharge to apply to all licensees.
However, the Legislative Budget Board has informed TMB that the language of H.B. 1998 only allows the collection of license renewal surcharges from physicians and physician assistants. Yet the program remains available to all license holders. S.B. 2480 would rectify this issue by explicitly permitting TMB to collect TxPHP license renewal surcharge fees from all TMB licensees, as initially intended.
Key Provision:
Amends Subchapter B, Chapter 153 of the Occupational Code, authorizing TMB to collect surcharges on all licensees regulated by the board to administer the Texas Physician Health Program.
Committee Substitute:
Texas Legislative Council version of the introduced text.
As proposed, S.B. 2480 amends current law relating to the administration of the Texas Physician Health Program, the disciplinary authority of the Texas Medical Board, and imposes a surcharge.
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 153, Occupations Code, by adding Section 153.053, as follows:
Sec. 153.053. SURCHARGE TO ADMINISTER TEXAS PHYSICIAN HEALTH PROGRAM. (a)-(b) Makes no changes to these subsections.�
(c) Provides that the Texas Medical Board (TMB) is authorized to collect the surcharge established in Subsection (a) (relating to requiring TMB collect an additional surcharge not to exceed $15 for certain registration permit fees) for all individuals licensed and regulated by TMB including all advisory boards and committees under Title 3 (Health Professions).
SECTION 2. Amends Subchapter B, Chapter 153, Occupations Code, by adding Section 153.055, as follows:
Sec. 153.055. SURCHARGE FOR CERTAIN SEARCHES RELATED TO LICENSE STATUS. (a)-(b) Makes no changes to these subsections.
(c) Provides that TMB is authorized to collect the surcharge established in Subsection (a) (relating to requiring that a surcharge to cover the cost of administering a continuous query on the National Practitioner Data Bank be collected from each license holder for certain initial and renewal registration permits) �for all individuals licensed and regulated by TMB including all advisory boards and committees under this title.
SECTION 3. Effective date: upon passage or September 1, 2025. �
Honorable Lois W. Kolkhorst, Chair, Senate Committee on Health & Human Services
FROM:
Jerry McGinty, Director, Legislative Budget Board
IN RE:
SB2480 by Campbell (Relating to the administration of the Texas Physician Health Program; the disciplinary authority of the Texas Medical Board; imposing a surcharge.), As Introduced
Estimated Two-year Net Impact to General Revenue Related Funds for SB2480, As Introduced: an impact of $0 through the biennium ending August 31, 2027.
The bill would make no appropriation but could provide the legal basis for an appropriation of funds to implement the provisions of the bill.
General Revenue-Related Funds, Five- Year Impact:
Fiscal Year
Probable Net Positive/(Negative) Impact to General Revenue Related Funds
2026
$0
2027
$0
2028
$0
2029
$0
2030
$0
All Funds, Five-Year Impact:
Fiscal Year
Probable Revenue Gain/(Loss) from Public Assurance 5105
Probable Revenue Gain/(Loss) from Physicians Health Program 5147
2026
$427,900
$204,225
2027
$427,900
$204,225
2028
$427,900
$204,225
2029
$427,900
$204,225
2030
$427,900
$204,225
Fiscal Analysis
The bill would amend the Occupations Code to authorize the Texas Medical Board (TMB) to collect a surcharge for the Texas Physicians Health Program and National Practitioner Data Bank for all individuals licensed and regulated by the agency. These surcharges are deposited into the General Revenue-Dedicated Account 5147, Texas Physician Health Program Fund, and General Revenue-Dedicated Account 5105, Public Assurance, respectively.
This bill would take effect September 1, 2025.
Methodology
Based upon analysis provided by the Texas Medical Board and the Comptroller of Public Accounts, this estimate assumes a licensee population of 77,800 that would pay the surcharge for the Physicians Health Program and National Practitioner Data Bank under the bill's provisions. This includes Physician Assistants, Acupuncturists, Medical Physicists, Certified and Non-Certified Medical Radiologic Technologists, Perfusionists, and Respiratory Care Practitioners. This estimate assumes a surcharge amount of $5.25 for the Physicians Health Program and $11.00 for the National Practitioner Data Bank. This estimate assumes that these fees will be paid on licensure and renewal, and due to licenses covering a two-year period, only half of the population would be paying the fee each fiscal year. In total, this would result in a gain of $204,225 each fiscal year in the Texas Physicians Health Program Fund and $427,900 each fiscal year in the Public Assurance Fund.
Local Government Impact
No fiscal implication to units of local government is anticipated.
Source Agencies:
304 Comptroller of Public Accounts, 503 Texas Medical Board
LBB Staff:
JMc, NPe, GDZ, BFa
Related Legislation
Explore more bills from this author and on related topics
SB2480 significantly expands the regulatory scope of the Texas Medical Board (TMB) by extending mandatory federal background monitoring and specific health program surcharges to all Board-regulated occupations, not just physicians. Effective December 1, 2025, healthcare entities employing Respiratory Therapists, Radiologic Technologists, Perfusionists, and other allied health professionals must adjust credentialing budgets and compliance monitoring to account for continuous National Practitioner Data Bank (NPDB) queries. Implementation Timeline Effective Date: September 1, 2025 Compliance Deadline: December 1, 2025 (Surcharges and new application requirements apply to filings submitted on or after this date).
Q
Who authored SB2480?
SB2480 was authored by Texas Senator Donna Campbell during the Regular Session.
Q
When was SB2480 signed into law?
SB2480 was signed into law by Governor Greg Abbott on June 20, 2025.
Q
Which agencies enforce SB2480?
SB2480 is enforced by Texas Medical Board.
Q
How urgent is compliance with SB2480?
The compliance urgency for SB2480 is rated as "moderate". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of SB2480?
The cost impact of SB2480 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does SB2480 address?
SB2480 addresses topics including occupational regulation, occupational regulation--health occupations, physicians and medical board, texas.
Legislative data provided by LegiScanLast updated: November 25, 2025
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