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

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.
