Substance Use Disorder Records Confidentiality: HHS Updates to Part 2 Regulations; February 2026 Compliance Deadline
Aligning Part 2 More Closely With HIPAA, Revised Patient Consent Requirements, New Enforcement Authorities and Penalties
A live 90-minute CLE video webinar with interactive Q&A
This CLE webinar will provide an in-depth look at the U.S. Department of Health and Human Services' (HHS) rule that overhauled the federal Part 2 regulations on the confidentiality of substance use disorder (SUD) patient records and what counsel and their clients should be doing now to come into compliance by Feb. 16, 2026. The panel will examine the extensive modifications that aligned Part 2 requirements more closely with HIPAA and will discuss the impact on Part 2 programs and other healthcare providers, including those who are not regulated by HIPAA as covered entities.
Outline
- Introduction: rule history
- HHS final rule
- Patient consent
- Patient rights and notice
- Other uses and disclosures
- Segregation of Part 2 data
- New definitions
- Safe harbor for investigative agencies
- Penalties and enforcement
- Breach notification
- Patient complaints
- Additional considerations
- Practitioner takeaways: assisting clients to prepare for compliance
Benefits
The panel will review these and other key considerations:
- How does the final rule align Part 2 SUD patient records confidentiality requirements more closely with HIPAA?
- What impact will the final rule have on Part 2 programs' current consent and notice documents? On information management?
- What should counsel and clients be doing now to prepare for the final rule's implementation?
Faculty
Beth Neal Pitman
Partner
Holland & Knight
Ms. Pitman advises healthcare systems and providers and healthcare information technology (IT) businesses when... | Read More
Ms. Pitman advises healthcare systems and providers and healthcare information technology (IT) businesses when navigating healthcare privacy and cybersecurity regulations, other healthcare regulations, and government reimbursement program matters. Her experience includes the development and ongoing management of comprehensive HIPAA compliance programs, including drafting and negotiating business associate agreements, policies and training. When a data breach or other privacy regulatory violation occurs, Ms. Pitman guides her clients through the process for responding to the breach and any subsequent federal or state government investigations. She also provides advice to clients related to the frequent changes associated with the many federal healthcare payment programs.
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Eddie Williams, III
Partner
Holland & Knight
Mr. Williams is experienced in assisting and advising clients with state and federal healthcare regulatory issues... | Read More
Mr. Williams is experienced in assisting and advising clients with state and federal healthcare regulatory issues including compliance, HIPAA, and data privacy. His specific work experience includes HIPAA gap analysis and compliance plan; analysis of privacy-related regulatory questions for a variety of healthcare entities; assisting long-term care clients with state licensure and Medicare/Medicaid applications, and residency and admission contracts; regulatory advice and counsel regarding healthcare regulation; assisting clients with responding to data breaches; assisting clients with pharmacy, healthcare clinic, healthcare clinic establishment and other licensure applications; and assisting clients with various local healthcare permits, including biomedical waste, group care home and food sanitation permits. Mr. Williams also has experience assisting clients from nonprofit corporations and religious institutions in obtaining IRS §501(c)(3) tax-exempt status, state tax-exempt status and charitable solicitation registration.
CloseEarly Discount (through 05/09/25)