
On Feb. 13, 2026, the U.S. Department of Health and Human Services (HHS) released updated model Notices of Privacy Practices (Privacy Notices) under the Health Insurance Portability and Accountability Act (HIPAA) for health plans and health care providers to use. HIPAA-covered entities must update their Privacy Notices if they receive or maintain patient records regarding substance use disorder (SUD) treatment provided by a federally assisted treatment program (i.e., a “Part 2 program”). The deadline for making this update was Feb. 16, 2026.
As background, Part 2 is a federal law that protects the confidentiality of patient records for individuals receiving services for SUDs, which are called Part 2 records. A final rule issued by HHS in April 2024 requires covered entities to update their HIPAA Privacy Notices if they receive or maintain Part 2 records. The updated Privacy Notices must address how the covered entity may use and disclose Part 2 records, the entity’s responsibilities with respect to the records and individuals’ privacy rights. According to HHS, its updated model Privacy Notices reflect the changes for Part 2 records.
Employers with self-insured health plans should ensure their HIPAA Privacy Notices are updated for the new privacy requirements for Part 2 records. Employers with fully insured health plans that have access to protected health information should also ensure their HIPAA Privacy Notices are updated for the new requirements. Health plans that use HHS’ model Privacy Notice should customize it by entering their own information.
Contact us to see how you could minimize risk:
- Employee Benefits|
Recent News
How an Extra Biweekly Payroll Period in 2026 Impacts Payroll
For employers that run biweekly payroll, 2026 introduces a unique scheduling challenge.
Employee Spotlight: Lane Trust
Please help us welcome Lane to the Seubert Team as a Strategic Risk Advisor!
Employers Should Prepare for 2026 RxDC Reporting
Group health plans and health insurance issuers must annually submit detailed information on prescription drug and health care spending to the CMS.
DOL Announces Proposed Independent Contractor Rule
The DOL announced a proposed rule to rescind its 2024 final independent contractor rule and replace it with an analysis of employee classification under the FLSA.
Improving the Effectiveness of Cybersecurity Training
Workforce cybersecurity training is a critical part of a company’s security risk management program.
Stop-Loss Insurance: A Critical Tool in Today’s Employee Benefits Strategy
Rising healthcare costs, catastrophic claims, and specialty drug spend are driving increased reliance on stop-loss insurance — making it a critical component of modern employee benefits and risk management strategies.

