Relating to the authority of the Harris County Hospital District to employ and commission peace officers.
LowStandard timeline
Low Cost
Effective:2025-09-01
Enforcing Agencies
Harris County Hospital District (Board of Managers)
01
Compliance Analysis
Key implementation requirements and action items for compliance with this legislation
Implementation Timeline
Effective Date: September 1, 2025
Compliance Deadline: While the authority begins in 2025, the District must begin the TCOLE agency application and budget approval process 12–18 months prior to commissioning the first officer.
Agency Rulemaking: No new state rulemaking is required. However, the District Board of Managers must adopt internal bylaws and Use of Force policies compliant with the Texas Commission on Law Enforcement (TCOLE) standards prior to operations.
Immediate Action Plan
Security Vendors: Audit current contracts immediately for termination risks and engage Harris Health procurement regarding transition timelines.
District Risk Management: Secure Law Enforcement Liability (LEL) coverage estimates and review sovereign immunity limits.
District HR: Establish a separate records retention schedule for peace officer personnel files (Brady disclosure compliance).
District Legal: Draft the application for TCOLE agency status and begin negotiating MOUs with local law enforcement agencies.
Operational Changes Required
Contracts
Vendor Agreements: Private security firms currently servicing Harris Health must review Master Services Agreements (MSAs) for "Termination for Convenience" clauses, as the District internalizes these functions.
Interlocal Agreements: The District must execute Memoranda of Understanding (MOUs) with the Houston Police Department and Harris County Sheriff’s Office to define jurisdictional boundaries and mutual aid protocols.
Employment Contracts: Specific employment agreements for peace officers must be drafted, addressing extra-duty restrictions and distinct disciplinary appeal procedures.
Hiring/Training
Licensure: The District cannot "grandfather" existing security guards into these roles. All hires must hold a permanent peace officer license under Occupations Code Chapter 1701.
Screening: HR must implement TCOLE-mandated psychological and physical fitness screenings, which are more rigorous than standard healthcare hiring protocols.
Reporting & Record-Keeping
TCOLE Filings: The District must file L-1 (Appointment) and L-5 (Separation) forms for all officers.
Statutory Reports: As a law enforcement agency, the District is now required to submit annual racial profiling reports and maintain specific Use of Force documentation.
Evidence Management: Strict Chain of Custody logs must be established for criminal evidence seized on hospital property.
Fees & Costs
Insurance: The District must procure Law Enforcement Liability (LEL) insurance. Standard General Liability policies typically exclude law enforcement acts (e.g., false arrest, excessive force).
Capital Expenditures: Budget allocations are required for police-specific equipment (body-worn cameras, secured evidence storage, marked vehicles).
Strategic Ambiguities & Considerations
Jurisdictional Scope: The statute authorizes employment but does not explicitly define the geographic limits of authority beyond District property. "Hot pursuit" and traffic stops immediately adjacent to hospital grounds present a liability risk. This must be resolved via strict Department Policy and MOUs, not left to officer discretion.
Chain of Command: The bill leaves the reporting structure of the new police force to the Board. Ambiguity regarding whether the Chief of Police reports to the CEO or directly to the Board creates potential conflicts of interest during internal investigations.
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Workplace violence at hospitals experienced by hospital employees at the hands of patients and patient family members is on the rise. There have been numerous reports of nurses and medical support staff being physically assaulted while trying to perform their jobs. While the Harris County Sheriff's Office currently provides security at county healthcare facilities, issues still persist due to staff shortages in law enforcement.
S.B. 434 grants the Harris County Hospital District the authority to employ and commission peace officers. Upon passage, S.B. 434 would allow Harris County Hospital District to join other hospital districts in Texas, such as the Dallas County Hospital District and the Tarrant County Hospital District, which already have the authority to employ and commission peace officers.
As proposed, S.B. 434 amends current law relating to the authority of the Harris County Hospital District to employ and commission peace officers.
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 Section 281.057(a), Health and Safety Code to authorize the boards of certain hospital districts, including the Harris County Hospital District, to employ and commission peace officers for the district, and to make a nonsubstantive change.
SECTION 2. Amends Article 2A.001, Code of Criminal Procedure, as follows:
Art. 2A.001.� PEACE OFFICERS GENERALLY.� Provides that certain individuals are peace officers, including an officer commissioned by certain hospital districts, including the Harris County Hospital District, under Section 281.057 (Employment of District Peace Officers), Health and Safety Code. Makes a nonsubstantive change.
SECTION 3.� Effective date: upon passage or September 1, 2025.
SB434 statutorily authorizes the Harris County Hospital District (Harris Health System) to establish an internal law enforcement agency, transitioning from private security or contract deputies to commissioned peace officers. This legislation creates a new liability framework for the District under 42 U. S.
Q
Who authored SB434?
SB434 was authored by Texas Senator Borris Miles during the Regular Session.
Q
When was SB434 signed into law?
SB434 was signed into law by Governor Greg Abbott on May 29, 2025.
Q
Which agencies enforce SB434?
SB434 is enforced by Harris County Hospital District (Board of Managers).
Q
How urgent is compliance with SB434?
The compliance urgency for SB434 is rated as "low". Businesses and organizations should review the requirements and timeline to ensure timely compliance.
Q
What is the cost impact of SB434?
The cost impact of SB434 is estimated as "low". This may vary based on industry and implementation requirements.
Q
What topics does SB434 address?
SB434 addresses topics including harris county hospital district, law enforcement, special districts & authorities, special districts & authorities--hospital and peace officers.
Legislative data provided by LegiScanLast updated: November 25, 2025
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