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Diagnosing Health Care PodcastAuthor: Epstein Becker & Green, P.C.
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42 CFR Part 2 Final Rule: What's Changing and What Do You Need to Know?
Episode 91
Thursday, 13 November, 2025
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: https://www.ebglaw.com/subscribe. Visit: http://diagnosinghealthcare.com. This podcast is presented by Epstein Becker & Green, P.C. All rights are reserved. This audio recording includes information about legal issues and legal developments. Such materials are for informational purposes only and may not reflect the most current legal developments. These informational materials are not intended, and should not be taken, as legal advice on any particular set of facts or circumstances, and these materials are not a substitute for the advice of competent counsel. The content reflects the personal views and opinions of the participants. No attorney-client relationship has been created by this audio recording. This audio recording may be considered attorney advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.
