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Signed Into Law
Signed June 22, 2025Effective 2025-09-01
SB646

Regular Session

Relating to repayment of certain mental health professional education loans.

Government Affairs & Regulatory Compliance Analysis

SB646: Government Affairs Overview

SB646 fundamentally alters recruitment and retention strategies for mental health employers by significantly increasing state-funded loan repayment caps and expanding eligibility to Associate-level clinicians and School Counselors. Effective September 1, 2025, organizations must leverage these state funds to offset internal retention costs while strictly managing employment verification protocols to avoid liability.

Sen. Royce West·Senate Bill·Regular Session

Moderate
Low Cost
Effective:2025-09-01
Business Impact

Who SB646 Affects

This legislation has regulatory implications for the following Texas businesses and organizations:

Regulatory Priority: moderate

Notable regulatory updates (effective 2025-09-01). Consider how these changes may affect your operations.

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Education

Affected business types:

  • School districts
  • Charter schools
  • Private schools
  • Education service providers
View all education legislation

Key Operational Considerations

  • 1Job Descriptions: Immediately update postings for Licensed Master Social Workers (LMSW), LPC Associates, LMFT Associates, and School Counselors to list "State Loan Repayment Program Eligible."

Estimated Cost Impact

lowMinimal cost impact anticipated.

Enforcing Agencies

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SB646
Moderate
Relating to repayment of certain mental health professional education loans.
Moderate Compliance Urgency
Requires near-term attention
Cost Impact
Low
Effective
2025-09-01
Enforcing Agencies
THECB
Primary Author: Sen. Royce West
89th Texas Legislature
jdkey.com
01

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

  • Effective Date: September 1, 2025.
  • Compliance Deadline: May 1, 2025 (Recommended). Recruitment materials and offer letters should be updated by this date to attract Summer/Fall graduates eligible for the new cycle.
  • Agency Rulemaking: The Texas Higher Education Coordinating Board (THECB) must adopt rules defining "languages of need" and allocation procedures prior to September 1, 2025. Employers must monitor the Texas Register for these definitions to confirm bonus eligibility criteria.

Immediate Action Plan

  • Audit Recruitment Materials: Update all mental health job postings to reflect expanded eligibility for Associates and School Counselors by May 2025.
  • Implement "Strategic Delay": Advise qualifying hires starting in Summer 2025 to wait until September 1, 2025, to submit their initial loan repayment application to lock in the higher statutory caps.
  • Establish Verification Protocol: Create a formal process for verifying employee practice hours at specific rural sites and fluency in non-English languages to support their applications.
  • Revise Compensation Strategy: Analyze current retention budgets to determine if internal bonuses can be reallocated, given the state's increased contribution to employee debt relief.

Operational Changes Required

Contracts

  • Offer Letters: You must revise employment agreements to explicitly state that loan repayment awards are determined solely by the State of Texas. Do not guarantee specific dollar amounts in offer letters. Use the following disclaimer: *"Eligibility for the Texas Mental Health Professional Education Loan Repayment Program is determined by the THECB and subject to legislative appropriation; [Company Name] does not guarantee funding."*
  • Retention Agreements: Align internal retention contracts (e.g., non-competes or training repayment) with the state’s new 5-year incentive structure to maximize employee tenure without creating conflicting obligations.

Hiring/Training

  • Job Descriptions: Immediately update postings for Licensed Master Social Workers (LMSW), LPC Associates, LMFT Associates, and School Counselors to list "State Loan Repayment Program Eligible."
  • Language Verification: Establish an internal protocol (e.g., standardized testing) to verify fluency if an employee intends to apply for the $5,000 "language of need" bonus. HR attestation will likely be required.

Reporting & Record-Keeping

  • Site-Specific Tracking: For multi-site organizations, payroll and HR must track hours worked specifically at locations within counties of <150,000 population. Eligibility for the $10,000 rural bonus is site-specific, not just employer-specific.
  • Annual Certification: Designate a specific authorized official (e.g., HR Director) to sign THECB employment verification forms to ensure consistency and prevent fraud.

Fees & Costs

  • Cost Impact: Positive. This legislation allows employers to potentially reduce internal sign-on bonuses by substituting them with application assistance for this state-funded debt relief.
  • No New Fees: There are no new filing fees for employers.

Strategic Ambiguities & Considerations

  • The "10% Cap" Calculation: The statute states total assistance (base + bonuses) cannot exceed the base cap plus 10%. This creates a conflict where earning both the rural ($10k) and language ($5k) bonuses might exceed the cap for certain license types. Agency rulemaking must clarify if earned bonuses are forfeited if they breach this mathematical limit.
  • "Language of Need" Definition: The specific languages qualifying for the $5,000 bonus are currently undefined. While Spanish is expected, the evidentiary standard for "fluency" remains a regulatory gray zone until THECB rules are published.

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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.

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Information 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.

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Legislative Timeline

This bill's path through the Texas Legislature

Filed
Dec 18, 2024
Passed Senate
Apr 30, 2025
Passed House
May 28, 2025
Signed
Jun 22, 2025
Effective
Sep 1, 2025
TopicsEducationEducation--higherEducation--higher--student Financial AidHealth Care ProvidersMental Health & Substance AbuseCounseling & TherapyMarriage & Family Counseling & CounselorsProfessional CounselorsSocial Work & Social WorkersStudent LoansHigher Education Coordinating Board, TexasState FinancesState Finances--management & Control
03

Senate Authors

Sen. Royce WestDemocrat · Primary Author
Coauthors (3)

House Sponsors

Rep. Aicha DavisDemocrat · Primary Sponsor
Joint Sponsors

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

Related Legislation

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More from Sen. Royce West

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Related by Topic

View more Education legislation
Quick Reference

Frequently Asked Questions

Common questions about SB646

Q

What does Texas SB646 do?

SB646 fundamentally alters recruitment and retention strategies for mental health employers by significantly increasing state-funded loan repayment caps and expanding eligibility to Associate-level clinicians and School Counselors. Effective September 1, 2025, organizations must leverage these state funds to offset internal retention costs while strictly managing employment verification protocols to avoid liability.

Q

Who authored SB646?

SB646 was authored by Texas Senator Royce West during the Regular Session.

Q

When was SB646 signed into law?

SB646 was signed into law by Governor Greg Abbott on June 22, 2025.

Q

Which agencies enforce SB646?

SB646 is enforced by Texas Higher Education Coordinating Board (THECB).

Q

How significant are the changes in SB646?

The regulatory priority for SB646 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.

Q

What is the cost impact of SB646?

The cost impact of SB646 is estimated as "low". This may vary based on industry and implementation requirements.

Q

What topics does SB646 address?

SB646 addresses topics including education, education--higher, education--higher--student financial aid, health care providers and mental health & substance abuse.

Q

What are the key dates for SB646?

Key dates for SB646: Effective date is 2025-09-01. Rulemaking: Adopt rules establishing a process for allocating unused funds and determining 'languages of need' for new bonus eligibility. (Prior to 2025-09-01 (Implied)). Consult with legal counsel regarding applicability.

Q

Which Texas businesses are affected by SB646?

SB646 primarily affects healthcare providers and medical facilities. These businesses should review the legislation with their legal and compliance teams to understand potential impacts.

Need Strategic Guidance on This Legislation?

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.

Legislative data provided by LegiScanLast updated: January 11, 2026