Last Update: 04/05/2026 at 2:50 PM EST

Health Plans Tighten SUD Privacy Notices

Coverage from HHS.gov, Pennmedicine, and others

Articles

15

Latest Article

02/26

Active Days

43

Executive Summary

Group health plans must update privacy notices by February 16, 2026 to reflect Part 2 SUD rules and remove vacated reproductive health language.

  • HHS updates model Notice of Privacy Practices templates for Part 2 SUD information
  • Group health plan sponsors must revise HIPAA Privacy Notices by February 16, 2026
  • Notices must explain stricter confidentiality rules for certain SUD records
  • Previously added reproductive health language must be removed after court vacatur
  • Fully insured plans shift notice responsibility to carriers, not plan sponsors
  • OCR begins civil enforcement of Part 2 confidentiality on February 16, 2026
  • Noncompliance can trigger investigations, corrective action plans, and monetary penalties

Quick Facts

  • What: Updating HIPAA notices for Part 2 SUD confidentiality
  • Where: United States health plans and SUD programs
  • Why: To reflect stricter SUD privacy rules and current law
  • Who: HHS OCR and group health plan sponsors
  • When: Effective February 16 2026

Coverage Timeline: 43 Days

1Jan 15 '261Feb 31Feb 136Feb 161Feb 171Feb 181Feb 191Feb 231Feb 251Feb 26 '26

Featured Article

HHS.gov 02-13-2026
HHS OCR enforces Part 2 confidentiality rules for federally assisted substance use disorder programs in the United States, with updates effective by 2026.

Additional Articles

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Pennmedicine 02-16-2026
Penn Medicine published a February 16, 2026 privacy notice supplement in Pennsylvania detailing HIPAA and Part 2 protections for substance use disorder treatment records.
Quarles & Brady LLP 02-19-2026
Health plans and insurers in the United States must align notices with Part 2 confidentiality rules by February 16 2026 to reflect stricter substance use disorder record protections.
Gunster 02-23-2026
HIPAA covered entities and Part 2 Programs in the United States must update notices by February 16, 2026.
Gordon Feinblatt LLC / Kennedy Hagens 02-16-2026
HIPAA covered entities and Part 2 programs must update notices by February 16 2026 in the United States to reflect Part 2 confidentiality alignment.
Buchanan Ingersoll & Rooney PC 02-26-2026
US Department of Health and Human Services finalizes 42 CFR Part 2 confidentiality rule in the United States to strengthen privacy protections for substance use disorder records.
Risk Strategies 02-17-2026
HHS updates HIPAA privacy notices to reflect Part 2 rules for US health plans in 2026.
Foleyhoag 02-16-2026
HHS Office for Civil Rights begins civil enforcement of 42 CFR Part 2 confidentiality in the United States on February 16, 2026 to safeguard substance use disorder records.
Davis Wright Tremaine 02-16-2026
Group health plan sponsors must update HIPAA Privacy Notices by February 16 2026 to reflect Part 2 confidentiality rules and remove vacated reproductive health language.
RamaOnHealthcare 02-18-2026
Healthcare entities must update privacy notices by the regulatory deadline to reflect new SUD protections and patient rights.
The HIPAA Journal / Steve Alder 01-15-2026
OCR enforces HIPAA penalties against health care entities in the United States from 2020 through 2026.
Hunton Andrews Kurth LLP 02-16-2026
Healthcare entities must update HIPAA notices by February 16 2026 to reflect Part 2 confidentiality changes affecting SUD records nationwide.
DOCS Education / Genni Burkhart 02-16-2026
HIPAA covered practices update notices by February 16 2026 to reflect Part 2 confidentiality for substance use disorder records in medical and dental settings in the United States.
Nixon Peabody 02-03-2026
US health care providers and Part 2 programs must update notices by February 16 2026 as OCR enforcement begins under the HIPAA Privacy Rule in the United States.

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JD Supra 02-25-2026
Who: U.S. Department of Health and Human Services and SAMHSA; What: finalize rule updates to confidential SUD information; When: by February 16 2026; Where: United States federal health system.