Medicaid Health Plans Face February 16 Deadline for Part 2 Substance Use Privacy Compliance

Health plans receiving substance use disorder (SUD) patient data from specialized treatment programs must comply with updated 42 CFR Part 2 regulations by February 16, 2026, including revisions to privacy notices and operational procedures. The regulations now carry HIPAA-level enforcement penalties after being largely unenforced historically, creating new compliance risk for Medicaid managed care organizations that handle SUD data. Plans must update both Part 2 and HIPAA notices of privacy practices to reflect stricter protections for SUD information compared to other health data.

Behavioral Health · Managed Care

This is outside commentary from Manatt Health, not part of Medicaid Monitor's independently scored news coverage.

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