Untitled Texas Attorney General Opinion: KP-0497

CourtTexas Attorney General Reports
DecidedAugust 29, 2025
DocketKP-0497
StatusPublished

This text of Untitled Texas Attorney General Opinion: KP-0497 (Untitled Texas Attorney General Opinion: KP-0497) is published on Counsel Stack Legal Research, covering Texas Attorney General Reports primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Untitled Texas Attorney General Opinion: KP-0497, (Tex. 2025).

Opinion

August 29, 2025

The Honorable Keith L. Cook Leon County Attorney Post Office Box 429 Centerville, Texas 75833

Opinion No. KP-0497

Re: Authority of the Health and Human Services Commission to regulate and license providers of Individualized Skills and Socialization services under chapter 103 of the Human Resources Code or other law (RQ-0555-KP)

Dear Mr. Cook:

Your inquiry pertains to the Texas Health and Human Services Commission’s authority to license, regulate, and penalize providers of Individualized Skills and Socialization (“ISS”) services as Day Activity and Health Services (“DAHS”) facilities. 1 You first ask whether the Commission has “authority to regulate and license providers of . . . []ISS[] services under Chapter 103[] [of the] Human Resources Code[] or any other state” statute. Request Letter at 1. If the Commission does have such authority, you also question whether the Commission may “assess administrative penalties against ISS service providers in an amount that is higher than” that provided in subsections 103.012(b) and 103.013(c) of the Human Resources Code. Id. But you do not challenge the propriety of any one rule—instead highlighting the Commission’s general regulation of ISS providers already classified as DAHS facilities, id. at 1–3—and we respond accordingly.

I. Chapter 103 of the Human Resources Code permits the Commission to license and regulate DAHS facilities.

State agencies, like the Commission, possess “only . . . those powers that the Texas Legislature has expressly conferred . . . and those implied powers that are reasonably necessary to carry out [their] statutory duties.” Tex. State Bd. of Exam’rs of Marriage & Fam. Therapists v. Tex. Med. Ass’n, 511 S.W.3d 28, 33 (Tex. 2017). It follows that the Commission may not “exercise what is effectively a new power, or a power contrary to a statute, on the theory that such a power is expedient for administrative purposes.” City of Austin v. Sw. Bell Tel. Co., 92 S.W.3d 434, 441 (Tex. 2002). Furthermore, while agency rules are presumed valid, that presumption can be

1 See Letter from Hon. Keith L. Cook, Leon Cnty. Att’y, to Hon. Ken Paxton, Tex. Att’y Gen. at 1 (rec’d Aug. 2, 2024), https://www.texasattorneygeneral.gov/sites/default/files/request-files/request/2024/RQ0555KP.pdf (“Request Letter”). The Honorable Keith L. Cook - Page 2

overcome if a rule exceeds an agency’s rulemaking authority. See Tex. Med. Ass’n, 511 S.W.3d at 33. This occurs when a rule’s provisions are not “in harmony with the general objectives of the act involved” as determined “from the plain text of the statutes that grant or limit the agency’s authority.” Id. (citations omitted). But harmony exists if a rule does not: (1) “contravene[] specific statutory language;” (2) “run[] counter to the general objectives of the statute;” or (3) “impose[] additional burdens, conditions, or restrictions in excess of or inconsistent with the relevant statutory provisions.” Id.

Chapter 103 of the Human Resources Code governs DAHS facilities, 2 see generally TEX. HUM. RES. CODE §§ 103.001–.016, and requires a “person” operating a facility to obtain a license, id. § 103.0041(a); see also id. §§ 103.003(6) (defining “person” as “an individual, corporation, or association”), .006(a) (stating that the Commission “shall issue a license to operate a [DAHS] facility to a person who has met the application requirements and received approval after an on- site inspection”). A DAHS facility is statutorily defined as “a facility that provides services under a [DAHS] program on a daily or regular basis but not overnight to four or more elderly persons or persons with disabilities who are not related by blood, marriage, or adoption to the owner of the facility.” Id. § 103.003(1-a); see also id. § 103.003(4)–(5) (defining “elderly person” and “person with a disability,” respectively). Chapter 103 also covers various requirements related to these facilities, including applications, inspections, licensing, early compliance reviews, and enforcement. Id. §§ 103.0041, .006–.009, .011–.016. It also requires the Commission’s executive commissioner to set standards for the facilities. Id. §§ 103.004(b), .005(2). In doing so, the executive commissioner is given discretion to establish standards for “the health and welfare of persons attending a facility;” “the eligibility of persons to attend a facility;” “the scope of services provided by a facility;” “adequate supervision for persons attending a facility;” “the professional staff and other personnel at a facility;” “adequate and healthful food service, where it may be offered;” “procedures for consultation with family members, case workers, or other persons responsible for the welfare of a person attending a facility;” and “prohibiting racial discrimination.” Id. § 103.004(b). The executive commissioner must also “set standards for the safety and sanitation requirements for a licensed facility.” Id. § 103.005(2). The chapter grants the executive commissioner rulemaking authority, including the authority to adopt rules that implement the chapter and establish licensing procedures. Id. §§ 103.004(a), .005(1).

The Commission “establish[es] licensing procedures, standards, and requirements” for ISS providers already licensed as DAHS facilities. 26 TEX. ADMIN. CODE § 559.201(a). See generally id. §§ 559.201–.251 (“ISS Rules”). ISS, by definition, bears two critical features: First, it is a “program service” offered in three different Medicaid waiver programs: the Deaf Blind with Multiple Disabilities (“DBMD”) program, Home and Community-based Services (“HCS”) program, and Texas Home Living (“TxHmL”) program. Id. § 559.203(10); see also id. § 559.203(4), (5), (21). The definition cross-references the rules describing ISS within these Medicaid waiver programs. 3 Id. § 559.203(10) (referencing 26 TEX. ADMIN. CODE §§ 260.503,

2 Chapter 103 refers to the Department of Aging and Disability Services, which was merged into the Commission in 2017. See Crampton v. Weizenbaum, 757 F. App’x 357, 359 n.1 (5th Cir. 2018). 3 In addition to the ISS Rules, the Commission promulgated rules related to ISS in each applicable Medicaid waiver program. See generally 26 TEX. ADMIN. CODE §§ 260.501–.517 (relating to ISS for the DBMD program), 262.901–.927 (relating to ISS for the TxHmL program), 263.2001–.2027 (relating to ISS for the HCS program). The Honorable Keith L. Cook - Page 3

262.905, 263.2005). Second, ISS consists of “on-site” and “off-site” program services. Id. “On- site” ISS refers to program services “provided in a building or a portion of a building that is owned or leased by an [ISS] provider” and includes transportation from one on-site ISS location to another. Id. §§ 260.503(d)(1), 262.905(c)(1), 263.2005(c)(1), 559.227(e)(1). “Off-site” ISS, on the other hand, is “provided in a community setting chosen by the individual from among available community setting options,” including “transportation necessary for the individual’s participation in off-site” ISS. Id. § 559.227(f). It cannot be provided in “a building in which on-site” ISS is provided, 4 id. § 559.227(f)(3)(A), and entities providing off-site ISS alone must maintain a “designated place of business where records are kept,” id. § 559.205(e)(5).

The ISS Rules also direct that “[a]n entity may not establish or provide” ISS services without first being licensed in accordance with Chapter 103 and the ISS Rules. Id. § 559.205(a). Consistent with that directive, an ISS “provider” is defined to mean “[a] provider licensed as a DAHS provider by [the Commission] to provide [ISS] services.” Id. § 559.203(11).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

TGS-NOPEC GEOPHYSICAL CO. v. Combs
340 S.W.3d 432 (Texas Supreme Court, 2011)
Cities of Austin v. Southwestern Bell Telephone Co.
92 S.W.3d 434 (Texas Supreme Court, 2002)
United States v. Juanetta Martin
555 F. App'x 358 (Fifth Circuit, 2014)
Crosstex Energy Services, L.P. v. Pro Plus, Inc.
430 S.W.3d 384 (Texas Supreme Court, 2014)
Texas State Board of Examiners v. Texas Medical Ass'n
511 S.W.3d 28 (Texas Supreme Court, 2017)
Levinson Alcoser Associates, L.P. v. El Pistolón II, Ltd.
513 S.W.3d 487 (Texas Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Untitled Texas Attorney General Opinion: KP-0497, Counsel Stack Legal Research, https://law.counselstack.com/opinion/untitled-texas-attorney-general-opinion-kp-0497-texag-2025.