About this episode

The episode discusses the changes and implications of the 42 CFR Part 2 final rule regarding substance use disorder treatment records and its alignment with HIPAA.

By early 2026, substance use disorder (SUD) providers, health plans, clinicians, health information exchanges (HIEs), and vendors must meet new federal privacy standards for SUD treatment records or face Health Insurance Portability and Accountability Act (HIPAA)-level enforcement and penalties. On this episode, Epstein Becker Green attorneys Lisa Pierce Reisz , David Shillcutt , and Laura DePonio join Nichole Sweeney, General Counsel and Chief Privacy Officer at CRISP , to break down the 42 CFR Part 2 final rule: what's changing, what's staying the same, and what organizations often miss. The group explains how the final rule aligns with (but does not replace) HIPAA, why patient consent remains central, and what new operational risks are emerging. Key Takeaways: Adoption of HIPAA Penalties: Part 2 now adopts HIPAA's enforcement and penalty structure. Operational Readiness Challenges: Operational readiness, not technology, is the biggest challenge. Expanded Compliance Duties: Payors and HIEs face major shifts in data access and compliance duties. Visit our site for related resources and email contact information: https://www.ebglaw.com/dhc91 . Subscribe for email notifications…

People in this episode

Host: Epstein Becker Green

Guests: Lisa Pierce Reisz, David Shillcutt, Laura DePonio, Nichole Sweeney

Topics covered

• substance use disorder
• federal privacy standards
• HIPAA
• operational risks
• compliance duties

Keywords

• 42 CFR Part 2
• substance use disorder
• HIPAA
• privacy standards
• compliance
• health information exchanges
• operational readiness

Mentioned in this episode

Organizations: CRISP

More episodes of Diagnosing Health Care Podcast

• DOJ's Bulk Sensitive Data Transfer Rule: Key Insights for Health Care Compliance Teams · April 16, 2026 · 44 min
• The Down-Low on Data for Value-Based Enterprises and Their Participating Providers · December 11, 2025 · 27 min
• Current Tailwinds in Women's Health - What Do They Mean for Your Business? · October 31, 2025 · 30 min
• Can Food Really Be Medicine? Transforming Health Care One Bite at a Time · July 31, 2025 · 38 min
• Breaking Down the Shifting Vaccine Policy Landscape · April 24, 2025 · 30 min
• Executive Actions Impact Federally Funded Research: What Institutions Should Do Now · April 10, 2025 · 43 min

Explore listener stats, chart rankings, contacts and more on the Diagnosing Health Care Podcast podcast page.