Seyfarth Synopsis: The Department of Health and Human Services has delegated enforcement authority to the Office of Civil Rights for 42 CFR Part 2, which protects the confidentiality of substance use disorder records. Covered entities must update their HIPAA documents to reflect these changes by February 16, 2026.
On August 25, 2025, the U.S. Department of Health and Human Services (HHS) Office of the Secretary authorized the Director of the Office for Civil Rights (OCR) to enforce the “Confidentiality of Substance Use Disorder (SUD) Patient Records” regulations found at 42 CFR Part 2, including the right to impose civil penalties, issue subpoenas and take corrective actions for noncompliance. These rules, finalized in February 2024, aim to protect the privacy of patients’ SUD treatment records, and require updates to HIPAA Privacy Policies and Notices of Privacy Practices.Continue Reading Enforcement of Substance Use Disorder Records
The Consolidated Appropriations Act of 2021 (“CAA”) offers significant relief for employers sponsoring flexible spending accounts. After much clamoring from the employer community, the IRS finally issued clarifying guidance in the form of Notice 2021-15 (the “Notice”). Check out our 
COVID-19 vaccines are finally here! Employers have a lot to think about in how this new tool in the fight against COVID-19 applies in the workplace, and whether it should be a mandatory aspect of employment. Check out the labor and employment considerations about the extent to which an employer should implement a vaccine policy,
Seyfarth Synopsis: On April 11, the IRS, DOL and HHS issued a series of FAQs clarifying the scope of the FFCRA/CARES Act mandates relating to COVID-19 testing for group health plans and health insurance issuers. This post highlights the key takeaways from those FAQs. 
Seyfarth Synopsis: On March 27, 2020, the House of Representatives followed the Senate’s lead in voting overwhelmingly to pass the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The President signed the legislation into law shortly thereafter. This blog post highlights the health and welfare benefit provisions contained in the law. Click 
Seyfarth Synopsis: On March 19, Senator McConnell introduced the Coronavirus Aid, Relief, and Economic Security (CARES) Act. While the Act largely focuses on economic relief for businesses and individuals, it did contain certain provision impacting benefit plans (for more on the potential impact for retirement plans, click 
Seyfarth Synopsis: On Wednesday afternoon, the Senate voted 90-8 to approve HR 6201 without changes. The law generally takes effect no later than 15 days after HR 6201 is signed (expected soon) and would sunset on December 31, 2020.