HHS has updated its model Notice of Privacy Practices (NPP) materials to help covered entities and business associates comply with the Part 2 related NPP requirements that became enforceable on February 16, 2026. The materials include a model HIPAA health plan NPP, model HIPAA provider NPP, and a Model Part 2 Patient Notice that federally assisted Part 2 programs can use to satisfy the Part 2 patient-notice obligation (and that Part 2 programs that are also HIPAA covered entities or business associates may combine with a HIPAA NPP). As background, Part 2 rules apply to federally assisted programs that provide substance use disorder (SUD) diagnosis, treatment, or referral (including programs providing education, prevention, training, treatment, rehabilitation, or research for SUD). Some of the rules also extend to anyone who receives Part 2 records, including HIPAA covered entities and business associates. HHS finalized major updates to the Part 2 rules in 2024, implementing statutory reforms enacted in the CARES Act to better align those rules with the HIPAA privacy rule (while retaining heightened protections for Part 2 records).

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