Aligning Part 2 and HIPAA: A Practical Guide to Advising SUD Providers of Changes Under 42 C.F.R. Part 2
Healthcare attorneys Tayler Chambless and Harshita Rathore co-authored an article for the American Health Law Association (AHLA) examining the 2024 Final Rule aligning 42 C.F.R. Part 2 with the Health Insurance Portability and Accountability Act (HIPAA) and what it means for substance use disorder (SUD) providers and their business associates (BAs). In the article, Ms. Chambless and Ms. Rathore provide practical guidance on key compliance considerations, including single consent for treatment, payment and healthcare operations (TPO), redisclosure requirements, business associate agreements (BAAs) and qualified service organization agreements (QSOAs), operational safeguards, and the U.S. Department of Health and Human Services (HHS) Office for Civil Rights' (OCR) recalibrated enforcement focus. They also highlight the steps covered entities and BAs should take to update agreements, notices, policies and workflows in light of compliance deadlines and increased enforcement risk, including providing helpful checklists that organizations can reference when assessing current practices and making changes.
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