Because of their role as safety net providers, health centers are on the front lines of responding to the opioid crisis. We developed this new workshop to help health centers and their staff identify and address key and emerging risk areas related to providing services in response to the opioid epidemic.

Day One: Risk Management Strategies in Responding to the Opioid Crisis

A health center’s ability to respond effectively is informed in large part by its ability to identify and mitigate the risks associated with identifying and treating patients with substance use disorders (and specifically opioid use disorders). This workshop follows the patient-provider relationship, identifying the major risks when prescribing opioids, participating in medication assisted-treatment services and distributing naloxone, as well as offering solutions for managing those risks in the health center.  FTLF attorneys also will update attendees on the compliance landscape relevant to substance use disorder services, including current audit and evaluation priorities of the federal government. 

Session topics will include:

• Starting, managing and terminating the patient-provider relationship
• Risk management strategies related to providing MAT services and Naloxone
• Pharmacy risk management  

Day Two: The Ins and Outs of Part 2**

In response to the opioid epidemic, many health centers have created new substance use disorder programs or enhanced their programming, often without a clear understanding of whether they must comply with 42 CFR Part 2 (“Part 2”), the federal confidentiality regulations protecting certain substance use disorder records. The Part 2 regulations provide more stringent federal protections than HIPAA.  For example, patients must consent in writing to the disclosure of their substance use disorder records for purposes of treatment, payment and health care operations unless one of a limited number of exceptions applies. 

Day Two of this workshop will focus on determining whether Part 2 applies to the health center’s current or planned substance use disorder services or to records it receives. FTLF attorneys will discuss the key compliance requirements under Part 2, including the patient consent and notice requirements, exceptions to the patient consent requirements, and disclosures to qualified service organizations and auditors. 

Session topics will include:

• Determining whether health center programs and/or personnel are covered by Part 2
• Identifying the required elements of a Part 2-compliant patient consent form
• Determining whether records protected by Part 2 may be disclosed under an exception to the consent requirements

**Note: registrants who attend both trainings do not need to stay for Day Two of Responding to the Opioid Crisis because it is a repeat of the material covered on Day Two of Managing Patient Privacy & Confidentiality.**