Regular Session
Government Affairs & Regulatory Compliance Analysis
SB 528 fundamentally alters the governance structure for facilities contracting with the Health and Human Services Commission (HHSC) for inpatient competency restoration. Effective September 1, 2025, providers must execute formal Memoranda of Understanding (MOUs) with local city, county, and mental health authorities, while simultaneously implementing granular data tracking for mandatory annual performance reporting.
Sen. Charles Schwertner·Senate Bill·Regular Session
This legislation has regulatory implications for the following Texas businesses and organizations:
Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.
Affected business types:
lowMinimal cost impact anticipated.
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JD Key Consulting provides strategic guidance on Texas regulatory compliance and legislative impact for your business.
Key implementation requirements and action items for compliance with this legislation
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 SB528
SB 528 fundamentally alters the governance structure for facilities contracting with the Health and Human Services Commission (HHSC) for inpatient competency restoration. Effective September 1, 2025, providers must execute formal Memoranda of Understanding (MOUs) with local city, county, and mental health authorities, while simultaneously implementing granular data tracking for mandatory annual performance reporting.
SB528 was authored by Texas Senator Charles Schwertner during the Regular Session.
SB528 was signed into law by Governor Greg Abbott on June 20, 2025.
SB528 is enforced by Health and Human Services Commission.
The regulatory priority for SB528 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB528 is estimated as "low". This may vary based on industry and implementation requirements.
SB528 addresses topics including criminal procedure, criminal procedure--general, mental health & substance abuse, safety and mental incompetency.
Key dates for SB528: Effective date is 2025-09-01. Rulemaking: Establish rules requiring facilities to execute Memoranda of Understanding (MOUs) with local counties, municipalities, and mental health authorities. (Unspecified (Post-Effective Date)); Define the form and manner of the required annual facility performance report. (Unspecified (Post-Effective Date)). Consult with legal counsel regardi
SB528 establishes the following penalties: administrative/contractual penalty of Contract termination or non-renewal for Failure to execute required MOUs or submit annual performance data to HHSC.. Consult with legal counsel for specific applicability to your situation.
SB528 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.
