[ Monday, March 07, 2016 ]


Part 2 Changes Coming: If you're reading a HIPAA blog, you know about 45 CFR, especially Parts 160 and 164.  But if you're in the substance abuse field, you probably also know about "Part 2."

"Part 2" refers to 42 (not 45) CFR Part 2.  Those are special privacy rules applicable to federally-supported substance abuse treatment centers.  If you were at my PESI presentations in Houston or San Antonio last Thursday and Friday, you would have heard about the Part 2 rules and how, since they are more strict than HIPAA, they are not preempted by HIPAA.  Basically, Part 2 is a strict prohibition on releasing substance abuse treatment records, even more strict than HIPAA: virtually no releases are allowed without a specific authorization from the patient.

This strictness can sometimes be too much, apparently.  It also doesn't reflect the interconnectedness of health care services these days.  So HHS is proposing that Part 2 be amended to allow transfers of substance abuse record data among participants in an integrated care model.

The proposed rules are here; you can comment by clicking the box in the upper left corner.

Jeff [10:16 AM]

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