Lexology January 19, 2026
Health care providers and other HIPAA covered entities must update their Notice of Privacy Practices (“NPP”) by February 16, 2026 to incorporate new requirements. The new requirements stem from changes to the Privacy Rule designed to align HIPAA with the regulations governing substance use disorder (“SUD”) treatment records under 42 C.F.R. Part 2 (“Part 2”).
On April 26, 2024, the U.S. Department of Health and Human Services (“HHS”) issued a final rule that created new privacy protections for reproductive health information and integrated certain Part 2 requirements into the HIPAA Privacy Rule. Although subsequent court decisions vacated those portions of the final rule related to reproductive health privacy, HHS has confirmed that the provisions concerning SUD treatment records and related...
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