HHS civil rights office says when states can use substance use records
Issue
On September 29, 2026, the HHS Office for Civil Rights explained when 42 CFR Part 2 lets state Medicaid agencies use substance use disorder records. States may use them to verify who is excluded from the 80-hour monthly work requirement, such as people in certain treatment programs.
Health centers with Part 2 programs can read the FAQ now.
Sources for this story
U.S. Department of Health and Human Services, Office for Civil RightsSources for your board packet
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Part of
- Medicaid work-requirement implementation
Verification systems and outreach
- Enforcement: privacy, fraud and audits
HIPAA rules and OCR enforcement
FQHC Talent. (2026, September 29). HHS civil rights office says when states can use substance use records. Source: U.S. Department of Health and Human Services, Office for Civil Rights. Retrieved October 6, 2026, from https://www.fqhctalent.com/intel/hhs-ocr-part-2-guidance-work-requirement-exclusions-september-2026