Substance Abuse Disorder Records (42 CFR Part 2) Final Rule Is Here!

The U.S. Department of Health and Human Services (HHS) Office for Civil Rights and Substance Abuse and Mental Health Services Administration (SAMHSA) have released a Final Rule revising standards for the Confidentiality of Substance Use Disorder Patient Records under 42 C.F.R. Part 2. It includes some welcome Part 2 amendments to better align Part 2 with the Health Insurance Portability and Accountability Act (HIPAA), but it also brings increased enforcement risks to an operationally tricky regulatory scheme. 
 
Attorneys Sarah Coyne and Ashleigh Giovannini will present a review of the new rule and a checklist of suggested action items to accomplish before enforcement begins in the third quarter of 2025.