89th Legislature

HB 3666

Overall Vote Recommendation
Vote No; Amend
Principle Criteria
Free Enterprise
Property Rights
Personal Responsibility
Limited Government
Individual Liberty
Digest

HB 3666 updates the internal auditing framework for Texas state agencies by amending Chapter 2102 of the Texas Government Code. The bill seeks to modernize and strengthen internal audit programs by explicitly aligning them with recognized global standards, including the Global Internal Audit Standards and the Professional Practices Framework issued by The Institute of Internal Auditors. It also requires compliance with generally accepted government auditing standards.

The legislation redefines the purpose of internal auditing to emphasize not only evaluation of agency operations but also the enhancement of value creation, risk management, governance, and long-term sustainability. HB 3666 mandates that each state agency must maintain a program of internal auditing, including developing an annual risk-based audit plan, performing audits of key operational areas such as financial systems and information technology, and ensuring compliance monitoring of agency contracts. Importantly, internal auditors must maintain independence from agency management responsibilities to preserve the objectivity of their evaluations.

Additionally, the bill formalizes the duties of internal auditors by requiring them to conduct economy and efficiency audits, program results audits, communicate audit results, and participate in periodic quality assurance and external peer reviews. By setting a uniform, internationally benchmarked standard for public sector internal auditing, HB 3666 aims to improve transparency, strengthen internal controls, and boost public trust in the administration of state government programs.

The originally filed version of HB 3666 proposed amendments to Chapter 2102 of the Texas Government Code to update the internal auditing standards used by Texas state agencies. It primarily focused on clarifying definitions related to internal auditing, aligning internal audits with internationally recognized standards, and reinforcing the independence and objectivity of auditors. It mandated agencies to prepare risk-based annual audit plans and included new duties for internal auditors to conduct economy, efficiency, and program result audits. Additionally, it required that internal audit programs conform to the Global Internal Audit Standards and other professional ethics frameworks.

In comparison, the Committee Substitute refines these concepts further. The substitute adds more specificity regarding the scope of audits by emphasizing oversight of agency contracts and contract compliance monitoring. It places a stronger emphasis on quality assurance, mandating not just periodic quality reviews but also comprehensive external peer reviews in accordance with professional standards. Furthermore, the substitute version clarifies reporting lines, stating explicitly that internal auditors must report directly to the governing board or the agency administrator to ensure independence.

Author
Ken King
Giovanni Capriglione
Candy Noble
Co-Author
Ryan Guillen
Penny Morales Shaw
Fiscal Notes

According to the Legislative Budget Board (LBB), HB 3666 is not expected to have a significant fiscal impact on the State. Although the bill mandates enhancements to internal auditing practices at state agencies, such as requiring more formalized risk assessments, stricter adherence to professional standards, and expanded audit responsibilities, the LBB assumes that any additional administrative costs associated with implementing these requirements can be absorbed within agencies' existing resources.

Similarly, no significant fiscal implications are anticipated for local governments. The legislation targets internal auditing programs specifically at state-level executive agencies and thus does not impose any direct financial obligations on local government units. Agencies identified as impacted, such as the Health and Human Services Commission, Department of Transportation, and University Systems, are considered capable of managing any workload increases without the need for new appropriations or staffing expansions.

Overall, from a budgetary perspective, HB 3666 is designed to tighten oversight and enhance auditing rigor without creating measurable new costs for the State Treasury or local jurisdictions.

Vote Recommendation Notes

HB 3666 proposes revisions to the Texas Internal Auditing Act by updating the standards for internal audits conducted by state agencies. It replaces the requirement for agencies to follow both the Standards for the Professional Practice of Internal Auditing and generally accepted government auditing standards with the new Global Internal Audit Standards promulgated by The Institute of Internal Auditors. Additionally, the bill clarifies definitions, modifies auditor duties, and updates references to the types of agency systems subject to internal audit.

While HB 3666 purports to modernize auditing practices, it ultimately does not result in any real reduction in the size, cost, or inefficiency of government operations. Instead, it primarily updates internal methodologies without requiring agencies to identify redundant programs, eliminate inefficiencies, or consolidate administrative functions. In short, the bill creates the appearance of reform without delivering meaningful structural changes or taxpayer savings. This is particularly problematic given the bill’s passage through the House Committee on Delivery of Government Efficiency (DOGE), where a higher standard for measurable government streamlining should be expected.

The bill does not create new agencies, programs, taxes, or regulatory burdens on individuals or businesses. However, it also fails to impose any discipline on state agencies to reduce costs or increase performance accountability. By aligning Texas agencies with global auditing standards without a Texas-specific review mechanism, HB 3666 could inadvertently cede some degree of internal governance to external, non-Texas bodies over time, contrary to principles of limited and locally accountable government.

For these reasons, Texas Policy Research recommends that lawmakers vote NO on HB 3666 unless amended because it does not achieve substantive efficiency gains. The bill should be amended to include requirements for internal audits to explicitly identify redundant or ineffective programs, propose cost-saving measures, and mandate legislative or executive oversight before adoption of any future revisions to external auditing standards. These amendments would ensure that HB 3666 fulfills its intended purpose of improving government efficiency rather than simply updating technical procedures.

Until such substantive changes are made, HB 3666 risks reinforcing bureaucratic inertia under the guise of modernization and does not merit passage in its current form.

  • Individual Liberty: By improving internal government auditing practices, at least in theory, the bill could marginally protect individuals by promoting better oversight of government operations. Stronger internal controls could help detect abuses of power or misuse of public resources, indirectly protecting individual rights. However, because the bill merely adjusts audit standards without mandating aggressive findings or transparency improvements, the actual protection of individual liberty is speculative at best.
  • Personal Responsibility: The bill nominally supports internal agency accountability by clarifying the duties of internal auditors and encouraging risk-based audit practices. However, without mechanisms requiring agency leadership to act on audit findings or without real consequences for inefficiency or failure, the bill falls short of meaningfully promoting personal or institutional responsibility. It refines process but does not strengthen the consequences for poor governance.
  • Free Enterprise: The bill does not impose new regulations, taxes, or compliance burdens on private businesses or individuals. Nor does it directly touch market competition or economic freedom. As such, it is largely neutral from a free enterprise standpoint. However, stronger internal audits could, if paired with additional reforms, eventually create a fairer environment in areas where state agencies interface with private vendors or contractors. As written, though, no such effects are likely.
  • Private Property Rights: The bill does not directly impact private property rights. It is limited strictly to internal operations of state agencies and their internal auditing standards. There are no expansions of eminent domain, no property seizures, no new regulations, or intrusions into private property relations.
  • Limited Government: The bill is problematic from a limited government perspective. While it does not expand the size or funding of government, it also fails to take any affirmative steps to reduce waste, eliminate redundant programs, or streamline bureaucracy — goals central to the principle of limited government. Worse, by mandating state adherence to external global standards without built-in Texas oversight or opt-out provisions, it potentially weakens state control over government processes in the future. True defenders of limited government should expect not just harmlessness, but active efforts to constrain and shrink bureaucratic excess. HB 3666 does not meet that test.
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