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July 10, 2024   

The Part 2 Final Rules: What Health Plans Need to Know

This Bulletin is brought to you by AHLA’s Payers, Plans, and Managed Care Practice Group.
  • July 10, 2024
  • Lisa Pierce Reisz , Epstein Becker & Green PC
  • David Shillcutt , Epstein Becker & Green PC
  • Kevin Malone , Epstein Becker & Green PC

The Final Part 2 Rule, which better aligns Part 2’s confidentiality provisions for Substance Use Disorder (SUD) treatment records with the Health Insurance Portability and Accountability Act (HIPAA), became effective on April 16, 2024. These new rules impose significant new requirements for health plans, insurers, and managed care entities (collectively health plans). All health plans that receive and redisclose Part 2 records should also use the current compliance runway to better understand their own Part 2 obligations prior to the February 16, 2026 compliance deadline.


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