Contracts
Review Master Service Agreements (MSAs) for "cooperation" and "audit access" clauses. You must flow down FWA compliance requirements to all subcontractors immediately; under this regime, you are strictly liable for "waste" or "abuse" committed by your downstream vendors.
Hiring/Training
Update employee handbooks to explicitly address "waste" (inefficiency) and "abuse" (misuse of position), not just fraud. Train finance and procurement staff that "inefficient" spending is now a compliance violation subject to clawback, even if the expenditure was technically legal.
Reporting & Record-Keeping
Implement "Justification Logs" for all TWC-related grant or contract expenditures to prove *necessity*, not just receipt. Prepare IT systems for data interface requests; the law authorizes TWC to utilize technology to detect irregularities, which may result in demands for direct API access or bulk data dumps from your payroll or accounting systems.
Fees & Costs
No new statutory fees. However, organizations should budget for increased administrative costs related to audit defense and potential clawbacks for expenditures deemed "wasteful" by TWC auditors.
