Relating to family support services provided under a Health and Human Services Commission program.

Contracts

• Subcontractor Indemnification: You must amend vendor agreements (especially for housing and job training) to include warranties that the vendor is not an "affiliate" of an abortion provider.
• Employment & Board Agreements: Update bylaws and employment contracts to explicitly prohibit simultaneous service on the board or staff of an abortion services provider. This is now a disqualifying event for state funding.
• Grandfathering Documentation: If you are a medical or mental health provider, locate and preserve your original HHSC contract dated prior to September 1, 2023. Without this, you are statutorily ineligible.

Hiring/Training

• Referral Ban Training: Staff must be trained that providing "information or education" regarding abortion services is prohibited. Update intake scripts to ensure no referrals are made to entities classified as abortion providers or their affiliates.
• Officer Vetting: Conduct immediate due diligence on all Directors and Officers. Any shared governance with an abortion provider triggers funding forfeiture.

Reporting & Record-Keeping

• Annual Certification: You must file a written annual certification with HHSC confirming adherence to the program's "life-affirming mission" and non-involvement in contradicting activities.
• Performance Outcomes: Prepare data systems to track long-term client outcomes (e.g., housing stability, workforce entry) rather than just service outputs. HHSC will mandate specific indicators shortly.
• Corporate Separation: Maintain distinct books, payroll, and physical premises from any entity that could be construed as an abortion provider to satisfy the "objective integrity" requirements.

Fees & Costs

• Funding Risk: The primary financial impact is the potential total loss of grant eligibility for non-compliance.
• Administrative Costs: Budget for legal review of corporate structure and increased reporting burdens, though providers with <$2M revenue may eventually see reduced administrative costs once the "simplified process" is defined.