Part III – Disclosures without Patient Consent

March 19, 2024

Access the on-demand webinar series here.


The 42 CFR Part 2 (“Part 2”) regulations, promulgated and enforced by the Substance Abuse and Mental Health Services Administration (SAMHSA), protect the confidentiality of certain substance use disorder records, providing those records with more stringent protections than HIPAA.

Under Part 2, there are a limited number of exceptions to the patient consent requirement for disclosure, including exceptions for disclosures to auditors, qualified service organizations, law enforcement and courts, and emergency disclosures. When disclosing in these situations, Part 2 Programs must still meet specific compliance requirements. Under the 2024 Final Rule, Part 2 Programs are permitted to disclose records without a patient consent to public health authorities if the records are de-identified according to the standards established by the HIPAA Privacy Rule.

In this final webinar, our attorneys will provide an overview of:

  • Disclosures of Part 2-protected records permitted without patient consent
  • Compliance requirements related to such disclosures (written agreements, documentation in patient charts, court orders and subpoenas, etc.)
  • How to respond when receiving requests for substance use disorder records protected by Part 2

Please note: Health Center Compliance Premium Plan Subscribers are eligible for a 10% discount on this webinar series. For more information on our Premium Plan, click here or contact us.


The on-demand version of this webinar will be available for purchase one week after the conclusion of the live webinar. 

Target Audience

  • Compliance Officers
  • Privacy and Security Officers
  • Medical Records
  • Substance Use Disorder Providers
  • MAT Program Directors and Staff
  • Operations

Learning Objectives

After this webinar, you will be able to:

  • Recognize when disclosures of Part 2-protected records are permitted without patient consent
  • Identify compliance requirements related to such permitted disclosures
  • Develop a process to respond to requests for Part 2-protected records 
Course summary
Available credit: 
  • 1.00 Certificate of Attendance
  • 1.20 CPE
    FTLF is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors.
Course opens: 
02/09/2024
Course expires: 
04/20/2024
Event starts: 
03/19/2024 - 1:00pm EDT
Event ends: 
03/19/2024 - 2:00pm EDT

Dianne Pledgie

Dianne Pledgie serves as Partner and Compliance Counsel with the firm’s health care practice group, Dianne advises health centers on implementing effective compliance programs and on addressing top compliance risk areas. Dianne counsels health centers and other organizations on developing compliance programs that include the OIG’s seven elements, respond to identified compliance risk areas, and reflect the organization’s culture. Dianne also advises health centers and other organizations on patient privacy and confidentiality, including the HIPAA Privacy Rule and 42 CFR Part 2. She has experience responding to privacy and security incidents, including determining whether there has been a breach, notifying patients and the government, and creating corrective action plans. [Full Bio]

Participants can earn up to 1.20 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.

ATTENDEE REQUIREMENTS FOR CPE CREDIT

If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 3 of the polling questions during the webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, we will email you your CPE Certificate within two (2) weeks.

ADDITIONAL INFORMATION

  • Prerequisites: None 
  • Target Audience: compliance officers, privacy and security officers, medical records, substance use disorder providers, MAT program directors and staff and operations 
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to three (3) out of five (5) polling questions.

Feldesman Leifer LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

Available Credit

  • 1.00 Certificate of Attendance
  • 1.20 CPE
    FTLF is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors.
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Access to the recorded version of this webinar is included in your purchase.

You will have access to the recordings for 90 days after enrollment. Once posted to your account, you can view each webinar anytime on-demand during the access period identified in your purchase confirmation. For additional information on viewing and accessing webinars, view our full terms and conditions here.


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