On November 28, 2022, the Department of Health and Human Services (HHS) issued proposed changes to regulations implementing amendments Congress made in 2020 to the confidentiality of substance use disorder (SUD) records law. These long-awaited (and overdue) proposals paint an important picture of things to come, especially with respect to enforcement. Below are three key […]
The CARES Act made important changes to 42 CFR Part 2 rules by aligning use and disclosure rules more closely with HIPAA. This is an important development and will require some operational tweaks by Part 2 Providers such as obtaining initial consent and ensuring the use of a Notice of Privacy Practices.