Protecting Substance Use Disorder Records: Compliance Countdown for Updated 42 CFR Part 2 Requirements | Workshop Day 2

By February 16, 2026, health centers that provide substance use disorder (SUD) services and meet the definition of a Part 2 program must:

• Determine whether to adopt a single consent form for all future uses and disclosures for treatment, payment, and health care operations. If adopted, health centers must create the new consent form and revise their consent policies and procedures accordingly;
• Update their Notice of Privacy Practices to incorporate Part 2, including the new patient rights to request an accounting of disclosures and to request confidential communications under Part 2;
• Decide whether to adopt substance use disorder counseling notes to provide additional protections for certain clinical notes. If adopted, health centers must create additional consent forms and develop or revise their consent policies and procedures;
• Update their patient complaint policies and procedures to reflect the new patient right to file a complaint with both the Part 2 program and the U.S. Department of Health and Human Services (HHS); and
• Update their breach reporting policies and procedures to reflect new oversight by the Office for Civil Rights (OCR) for Part 2 compliance.

Join Dianne Pledgie for this strategically timed workshop, which will examine the major changes to 42 CFR Part 2 and provide compliance strategies and sample documents that can be implemented before the compliance deadline. This two-part workshop will guide attendees through:

• Determining whether Part 2 applies to SUD records created and maintained by the health center, or to SUD records received from other treating providers;
• Understanding the greater alignment between Part 2 and the HIPAA Privacy, Security, and Breach Notification Rules—while recognizing that Part 2 still requires separate patient consent and identification of Part 2-protected records; and
• Identifying and prioritizing the health center documents that need review, revision, or development to ensure compliance and avoid new penalties for non-compliance.

Whether your health center currently operates a Part 2 program or is expanding its substance use disorder services, this workshop will provide a solid understanding of the Part 2 compliance requirements; practical guidance for achieving compliance; and sample forms and policies to support your health center.

Audience:

• CMOs
• COOs
• Compliance Officers
• Risk Managers
• Clinical Leadership
• HIPAA Privacy Officers
• HIPAA Security Officers
• Behavioral Health Providers
• Substance Use Disorder Program Staff

Agenda Day 2:

• 1:00 – 2:00 pm ET – Part 2 Program Policies
• 2:00 – 2:50 pm ET – Patient Notices and Patient Rights
• 3:00 – 4:00 pm ET – Disclosures for Legal Proceedings

Presenter:

• Dianne Pledgie