The Final Rule introduces significant changes that facilitate the secure and efficient exchange of Part 2-protected information across networks! Join us on February 25th, 2025 from 2:30-3:30 pm EST.
The U.S. Department of Health and Human Services (HHS) has introduced major updates to the Confidentiality of Substance Use Disorder (SUD) Patient Records regulations under 42 CFR Part 2. These changes create new opportunities for secure information sharing while ensuring strong patient privacy protections. Although compliance is not required until February 16, 2026, organizations can start preparing now to update policies, implement consent workflows, and train staff.
Key Updates Include:
- TPO Consent: Patients can now give a single, broad consent for Treatment, Payment, and Healthcare Operations (TPO).
- Re-disclosure Flexibility: HIPAA-covered entities may redisclose Part 2 records under TPO consent.
- Public Health Disclosures: De-identified Part 2 records may be shared with public health authorities.
- No Segmentation Requirement: Part 2 records no longer need to be segregated from other health records.
- New Breach Notification Obligations: Direct notification is required for improper use or disclosure.
- Civil Monetary Penalties: Noncompliance after February 2026 may result in financial penalties.