Author Archives: Tracy Guarnieri

Many Covered Entities Must Update HIPAA NPPs to Address Part 2 Records

Due to 2024 changes to HIPAA, covered entities that receive or maintain substance use disorder (SUD) records from programs subject to 42 CFR Part 2 (Part 2 Programs) must update their Notice of Privacy Practices (NPP) to clearly explain how these records are handled.  This requirement applies even if the covered entity does not provide […]

Off the Record: How to Handle Psychotherapy Notes Under HIPAA

Not all behavioral health records are created equal. Under HIPAA, psychotherapy notes receive special protections that other behavioral health records do not. What Are Psychotherapy Notes? “Psychotherapy notes” are a very narrowly defined set of notes that exist only if the notes meet two requirements: (1) they may contain only the therapist’s impressions and analysis […]

Once Upon a Time, There Was a Human Research Subject . . . or Was There?

Human subjects research plays an important role in many of the medical and social advancements we enjoy today, but as a result of the horrifying and unethical experiments of the past (e.g., Nazi experiments, Tuskegee Syphilis study, Willowbrook State School experiments) human subjects research is now highly regulated and closely monitored.  Federal regulations require that […]