We have been getting further questions about the updated HIPAA form specifically in regrads to the requirement for 42 CFR Part 2.

We understand how confusing these paperwork updates can be.

This WILL NOT APPLY to many therapists in private practice but please assure to read in case you are the small percentage that it does apply to. This ONLY applies to therapists who fall under 42 CFR Part 2.

Before we clarify, please know that we updated the HIPAA form, again, to provide further clarity and have provided the link below for your convenience. The new updates are highlighted in yellow.

What is 42 CFR Part 2?

In simple terms, ALL of the following must be true for therapists in private practice who treat SUDs to fall under 42 CFR Part 2.

A clinician who provides counseling services for clients with SUDs (i.e. diagnosis, treat, and/or refer) AND also receives federal funding including medicare or medicaid.

Here is the MOST updated HIPAA form as of February 25, 2026.

It is always best to err on the side of caution hence why we have including this language in the HIPAA form. We encourage you to do so as well.