Jillian Gordon Foerster’s articles from Dykema are most popular:
- within Privacy topic(s)
- with Inhouse Counsel
- in United States
- with readers working within the Healthcare industries
⚕🔎 Healthcare providers and self-insured plan sponsors: You have until February 16, 2026, to update your HIPAA Notice of Privacy Practices.
The new requirements focus on substance use disorder (Part 2) records and how they're treated differently under federal privacy law. Here are the changes you need to make in your NPP, and who's responsible for making those updates.
Key takeaways:
- NPP updates required by February 16 for entities that create or maintain Part 2 records
- New disclosures around legal proceedings, redisclosure, and fundraising
- Self-insured plans: this is likely your responsibility, not your insurer's
- No mass mailing required—just post online and include with next annual distribution
This is also a good time to review your entire privacy compliance program and make sure your practices align with your policies.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
