SB912

Regular Session

Relating to the verification of health care practitioner continuing education compliance through the establishment of continuing education tracking systems.

CriticalImmediate action required

Medium Cost

Effective:2025-09-01

Enforcing Agencies

Behavioral Health Executive Council • Board of Chiropractic Examiners • Executive Council of Physical Therapy & Occupational Therapy Examiners • Texas Board of Nursing • Texas Board of Pharmacy • Texas Department of Licensing and Regulation (for health-related licenses) • Texas Medical Board • Texas Optometry Board • Texas State Board of Dental Examiners

SB912

Critical

Relating to the verification of health care practitioner continuing education compliance through the establishment of continuing education tracking sy...

Critical Compliance Urgency

Requires immediate attention

Cost Impact

Medium

Effective

2025-09-01

Enforcing Agencies

Behavioral Health Executive CouncilBoard of Chiropractic ExaminersExecutive Council of Physical Th...Texas Board of Nursing+5 more

Primary Author: Sen. Cesar Blanco

89th Texas Legislature

jdkey.com

Compliance Analysis

Key implementation requirements and action items for compliance with this legislation

Implementation Timeline

Effective Date: September 1, 2025 (Law becomes statute).
Compliance Deadline:
September 1, 2026: System must be operational for Medical, Nursing, Dental, Pharmacy, Optometry, Chiropractic, PT/OT, and Behavioral Health boards.
September 1, 2028: System must be operational for health-related licenses managed by the Texas Department of Licensing and Regulation (TDLR).
Agency Rulemaking: Agencies must adopt rules establishing the Continuing Education Tracking System (CETS) prior to the compliance deadlines above. Critical Period: Late 2025 through Mid-2026 will determine fee structures and data standards.

Immediate Action Plan

Audit Renewal Workflows: Shift internal deadlines to require CE completion 60 days pre-expiration to allow for data transfer lags.
Review Vendor Contracts: Identify which of your CE partners are technically capable of digital reporting; terminate those who rely solely on paper.
Monitor Rulemaking: Assign a compliance officer to track the Texas Register for the specific fee structures proposed by your relevant licensing board (e.g., TMB, BON).
Update Budgets: Allocate funds for potential "Data Upload Fees" starting in FY 2026.

Operational Changes Required

Contracts

Employment Agreements: Amend practitioner contracts to place the burden of CETS verification on the employee. Require proof of "Green Light" status in the tracking system 30 days prior to license expiration.
CE Vendor Agreements: If you contract third parties to provide training, add indemnification clauses. If their failure to upload data causes a license lapse and lost revenue, they must be liable.
Speaker/Educator Contracts: Mandate that all contracted educators provide data in specific digital formats (CSV/API) compatible with the state vendor, not just paper sign-in sheets.

Hiring/Training

Credentialing Staff: Retrain credentialing teams immediately. They can no longer accept paper certificates as primary proof of renewal eligibility. They must learn to navigate the specific vendor portal selected by each board.
Practitioner Onboarding: New hires must be instructed that "paper certificates in a drawer" are no longer sufficient for renewal.

Reporting & Record-Keeping

Data Integration: CE Providers must prepare for API integration or bulk-upload workflows. The state system is now the "Single Source of Truth."
Roster Retention: Maintain digital rosters that mirror the state’s data schema to resolve disputes. If the system deletes a credit in error, you need the raw data to force a correction.

Fees & Costs

User-Pay Model: The Fiscal Note explicitly states the agencies will not pay for this system. Anticipate a "System Access Fee" or "Credit Upload Fee" charged by the vendor.
Budget Impact: Line-item this cost for 2026. Decide now if the organization will absorb these fees for employees or pass them to the practitioner.

Strategic Ambiguities & Considerations

Cost Allocation: The law prohibits state cost but does not cap vendor fees. It is currently unclear if the vendor will charge the CE Provider (per credit uploaded) or the Licensee (subscription model). This will be decided during rulemaking.
Data Entry Mandate: It is unclear if the rules will *force* CE Providers to upload data or allow practitioners to self-report. A provider mandate increases administrative overhead significantly.
System Failure Protocol: The statute lacks a "safe harbor" for technical failures. If the vendor's system crashes during a renewal window, there is no statutory mechanism for an emergency renewal.

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Legislative Timeline

This bill's path through the Texas Legislature

TopicsElectronic Information Systems Health Care Providers Occupational Regulation Occupational Regulation--health Occupations Continuing Education

Official Analysis

View HRO Analysis View All Bill Documents

Senate Authors

Sen. Cesar BlancoDemocrat · Primary Author

Coauthors (1)

Charles Perry (R)

House Sponsor

Rep. Ryan GuillenRepublican · Primary Sponsor

Bill Text(with markup)

View bill text in multiple formats on Texas Legislature website

Fiscal NoteView Original

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Frequently Asked Questions

Common questions about SB912

What does Texas SB912 do?

SB912 fundamentally shifts Texas healthcare licensure from a "trust and verify" audit model to a "verify then renew" hard-stop model. Effective September 1, 2026, licensing boards are legally prohibited from renewing a practitioner's license unless a centralized electronic system confirms Continuing Education (CE) compliance. This impacts every healthcare employer, practitioner, and CE provider in the state.

Who authored SB912?

SB912 was authored by Texas Senator Cesar Blanco during the Regular Session.

When was SB912 signed into law?

SB912 was signed into law by Governor Greg Abbott on June 20, 2025.

Which agencies enforce SB912?

SB912 is enforced by Behavioral Health Executive Council, Board of Chiropractic Examiners, Executive Council of Physical Therapy & Occupational Therapy Examiners, Texas Board of Nursing, Texas Board of Pharmacy, Texas Department of Licensing and Regulation (for health-related licenses), Texas Medical Board, Texas Optometry Board and Texas State Board of Dental Examiners.

How urgent is compliance with SB912?

The compliance urgency for SB912 is rated as "critical". Businesses and organizations should review the requirements and timeline to ensure timely compliance.

What is the cost impact of SB912?

The cost impact of SB912 is estimated as "medium". This may vary based on industry and implementation requirements.

What topics does SB912 address?

SB912 addresses topics including electronic information systems, health care providers, occupational regulation, occupational regulation--health occupations and continuing education.

Legislative data provided by LegiScanLast updated: November 25, 2025

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