Review confidentiality before exchanging substance-use records
HHS's updated Part 2 fact sheet explains protections for records within the federal substance-use confidentiality framework. Applicable organizations had to comply with the final rule's requirements by February 16, 2026. Scope matters; a mention of substance use does not automatically make every service a Part 2 program. HHS Part 2 scope and updated requirements
Determine which records and organizations fall within that framework. Review consent, patient notices, disclosure rules, and breach procedures with qualified advisers. The fact sheet describes special consent for separately maintained substance-use counseling notes. Do not assume a general information-sharing checkbox covers every record.
HIPAA also applies to covered organizations and their relevant vendors. HHS telehealth technology duties
Test a transfer using fictional information. Confirm who receives it, the authority for sharing, and how staff document the action. Give patients an understandable explanation of optional assistance and required information. Keep public-program navigation separate from unrestricted access to its clinical records.