Lauren DeWitt and Alyssa Sajczuk of Pepper Hamilton write:
A final rule from the Substance Abuse and Mental Health Services Administration establishes requirements for the exchange of patient information between substance abuse treatment programs and their agents and contractors. Published on January 3, the rule clarifies requirements for re-disclosure of confidential patient information by certain contractors and agents of substance abuse treatment programs under the Confidentiality of Alcohol and Drug Abuse Patient Records regulations (commonly referred to as “Part 2”). The rule permits re-disclosure of confidential patient information by lawful holders without patient consent, and sets the parameters for this re-disclosure.
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