HEB ISD establishes process to review administrator paid-contracts under new Texas law

The Hirsh Hills Bedford Independent School District on Aug. 11 presented a districtwide compliance process to implement changes required by a recently effective Texas law restricting compensated personal services by school administrators.

Cicely (HR presenter) briefed trustees on the statute, which took effect June 22, and described which employees the district believes are affected, the review criteria trustees will use and the submission workflow for approval. “Those impacted are those who have significant administrative responsibilities,” Cicely said, listing assistants, principals, coordinators, directors and those with “superintendent” in their title as affected groups.

The district described three statutory prohibitions the board must consider: administrators may not receive financial benefit for personal services to (1) businesses that do or could do business with the district; (2) educational vendors providing services to any school district; and (3) other public education entities such as districts, charters and education service centers. The presenter noted that exceptions exist for categories two and three but not for administrators who have “superintendent” in their title.

Board process and protections: District attorneys helped draft an approval framework requiring submission of a contract, memorandum of understanding or email agreement to the Board of Trustees. Trustees will evaluate submitted agreements against three criteria: whether the arrangement would harm the district, create a conflict of interest, and whether the services will occur on the administrator’s personal time. If all three are satisfied, the board may approve the contract.

Financial benefit and time definitions: The presenter said the bill does not define “financial benefit” or “personal time.” The district’s attorneys recommended interpreting financial benefit to include payments, stipends, honoraria and gift cards, but to exclude reimbursements for reasonable expenses such as mileage. The district expects “personal time” to mean time outside of contract days and work hours, or the employee must use leave time if services occur during contract days.

Operational steps: Human Resources will own communication and guidance, publish an FAQ, host a Google form (placed in administrators’ ClassLink launch pad) for submissions, and retain records for public information requests. The district also plans to integrate the topic into annual administrator training beginning in 2026.

Discussion vs. decisions: Trustees approved two email agreements under the new process later in the meeting (board action 9.03). The board asked clarifying questions about spousal employment and travel reimbursements; district staff said the statute targets the administrator as the service provider and does not capture a spouse’s employment, and reimbursements are handled through separate vendor or district gift policies.

Next steps: The district will notify administrators, implement the submission workflow, and return to trustees with any policy changes or clarifying legal guidance as attorney general opinions or case law become available.

Ending: Staff emphasized a conservative interpretation to protect employees and the district until state guidance develops.