Implementation Fact Sheet
Three key steps to implement the requirements of 2024 Part 2 Final Rule
On February 16, 2024, HHS released a Final Rule updating 42 CFR Part 2, the federal regulations governing the confidentiality of substance use disorder (SUD) treatment records. The Final Rule implemented changes required by Congress in the 2020 Coronavirus Aid, Relief, and Economic Security (CARES) Act to align certain aspects of 42 CFR Part 2 with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.
This resource is intended to assist Part 2 programs in complying with the requirements of the Final Rule by describing in detail 3 key steps that programs can take to support implementation.
This resource was authored by Jacqueline Seitz, JD.
Key Points
- The 2024 amendments to Part 2 went into effect on April 16, 2024, with a compliance date of February 16, 2026, when enforcement may formally begin.
- Organizations can take the following 3 key steps to implement the requirements of 2024 Part 2 Final Rule:
- Update consent forms and required notices
- Revise agency or organization policies and procedures
- Ensure staff knowledge by providing training
Related Resources
Archived recording of a national webinar during which the CoE-PHI team outlined the 2024 Final Rule changes to 42 CFR Part 2, applied learning to common scenarios through interactive case studies and discussed next steps regarding implementation of recent changes to the law.
Slide deck from July 2024 presentation to NASADAD membership, during which the CoE-PHI outlined recent changes to Part 2, the federal law that protects the confidentiality of substance use disorder (SUD) treatment records, and applied learning to common scenarios through interactive case studies. Considerations for next steps for state and municipal agency leaders regarding implementation of recent changes to Part 2 were also highlighted and discussed.