Regular Session
Government Affairs & Regulatory Compliance Analysis
Senate Bill 904 eliminates the Continuing Education (CE) grace period for new licensees and mandates a complete overhaul of consumer contracts to meet new "plain language" standards. Effective September 1, 2025, all hearing instrument fitters and dispensers in Texas must enforce immediate CE compliance for new hires and accept broader medical clearances for minors.
Sen. Judith Zaffirini·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
Mandatory Revision: Your standard "Purchase Agreement" and "30-Day Trial" documents must be rewritten. The law requires these documents to be in "plain language designed to be easily understood by the average consumer."
CE Requirements: The 24-month CE exemption for first-time license holders is repealed.
Medical Records: Update patient intake forms for minors. Remove requirements specifying that only specialists can sign medical waivers. Retain the physician's written statement in the patient's file to prove compliance during TDLR inspections.
Licensure Tracking: Update HR tracking systems to flag first-time licensees for CE auditing prior to their first renewal.
Budget Impact: While state fees remain unchanged, employers who reimburse CE costs must anticipate this expense occurring two years earlier than under previous law for all new staff.
"Plain Language" Definition: The statute mandates "plain language" but does not define the metric (e.g., Flesch-Kincaid Grade Level).
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 SB904
Senate Bill 904 eliminates the Continuing Education (CE) grace period for new licensees and mandates a complete overhaul of consumer contracts to meet new "plain language" standards. Effective September 1, 2025, all hearing instrument fitters and dispensers in Texas must enforce immediate CE compliance for new hires and accept broader medical clearances for minors.
SB904 was authored by Texas Senator Judith Zaffirini during the Regular Session.
SB904 was signed into law by Governor Greg Abbott on June 20, 2025.
SB904 is enforced by Texas Commission of Licensing and Regulation (TCLR) and Texas Department of Licensing and Regulation (TDLR).
The regulatory priority for SB904 is rated as "moderate". Businesses and organizations should review the legislation to understand potential impacts.
The cost impact of SB904 is estimated as "low". This may vary based on industry and implementation requirements.
SB904 addresses topics including occupational regulation, occupational regulation--health occupations, hearing disorders and health & human services commission.
Key dates for SB904: Effective date is 2025-09-01. Consult with legal counsel regarding applicability.
SB904 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.
