Last Update: 08/01/2026 at 12:00 PM EST

HIPAA Part 2 Notice Updates

Coverage from Hunton Andrews Kurth LLP, JD Supra, and others

Articles

15

Active Days

43

The Topic

HIPAA Part 2 Notice Updates topic image

Federal privacy compliance for substance use disorder records is changing quickly as HIPAA notices, Part 2 confidentiality rules, and OCR enforcement are aligned across providers, health plans, and related vendors. Most coverage concentrates on required Notice of Privacy Practices updates, redisclosure limits, breach notification, and operational steps for compliance before and after the February 16, 2026 deadline.

First Article: 01/15/26

Latest Article: 02/26/26

Summary

  • The main shift is regulatory: HIPAA notice requirements are being updated to reflect 42 CFR Part 2 protections for substance use disorder records.
  • February 16, 2026 is the key operational deadline across most of the material, with some mailing and posting exceptions extending beyond that date.
  • OCR enforcement is now a central feature of the framework, with civil penalties, investigations, and corrective action plans tied to noncompliance.
  • Health plans, providers, Part 2 programs, and some digital health or vendor relationships may all need policy, notice, and agreement updates.
  • A repeated concern is redisclosure: once SUD information leaves its original protected setting, organizations must explain when federal protection may narrow or change.
  • Several items stress practical compliance work, including staff training, notice templates, business associate agreements, and vendor governance.
  • The cluster is coherent and current, with very little historical drift beyond one broader HIPAA enforcement overview.

History

This topic is new, but as new articles are added to it this area will summarize shifts, changes and expansions of the issues.

Featured

Timeline: 43 Days

Jan 15Jan 24Feb 2Feb 8Feb 17Feb 26

Additional Articles

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HHS.gov02-13-2026
HHS OCR enforces Part 2 confidentiality rules for federally assisted substance use disorder programs in the United States, with updates effective by 2026.
Pennmedicine02-16-2026
Penn Medicine published a February 16, 2026 privacy notice supplement in Pennsylvania detailing HIPAA and Part 2 protections for substance use disorder treatment records.
Risk Strategies02-17-2026
HHS updates HIPAA privacy notices to reflect Part 2 rules for US health plans in 2026.
Gunster02-23-2026
HIPAA covered entities and Part 2 Programs in the United States must update notices by February 16, 2026.
Gordon Feinblatt LLC / Kennedy Hagens02-16-2026
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 PC02-26-2026
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.
DOCS Education / Genni Burkhart02-16-2026
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.
Davis Wright Tremaine02-16-2026
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.
Quarles & Brady LLP02-19-2026
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.
RamaOnHealthcare02-18-2026
Healthcare entities must update privacy notices by the regulatory deadline to reflect new SUD protections and patient rights.
Nixon Peabody02-03-2026
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.
Foleyhoag02-16-2026
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.