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Check here for news, notes and occasional ponderings from the Executive Director of CFHA.

 

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Top tags: 42 CFR Part 2  MAT  substance abuse 

42 CFR Part 2 & Integrated Care

Posted By Neftali Serrano, Friday, September 7, 2018
OK, so here are the minutes (attached) from our call last week on the implications and current consensus related to 42 CFR Part 2 and integrated settings. The bottom line:

1. Ironically the law encourages truly integrated design for substance abuse treatment. If you do not advertise as a substance abuse treatment center and/or do not have providers solely dedicated to substance abuse treatment and do provide MAT or other substance abuse services AS PART OF primary care or standard behavioral health care then most clinics are interpreting the law as not applying to them. In this case the default regulation comes from HIPAA, not 42 CFR Part 2.

2. There are a great many resources out there now to guide clinics and they all seem to have arrived at the above consensus opinion of the law. Here are a few of them:

https://chhs.unh.edu/sites/default/files/substance-use-disorder-privacy-part-2-idn-workbook-unh-1017.pdf

https://www.chcf.org/wp-content/uploads/2018/07/OvercomingDataSharingChallengesOpioid.pdf

https://www.samhsa.gov/about-us/who-we-are/laws-regulations/confidentiality-regulations-faqs

Download File (PDF)

Tags:  42 CFR Part 2  MAT  substance abuse 

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Oops, We Screwed Up & Other Notes From The Desk of The Executive Director

Posted By Neftali Serrano, Friday, September 7, 2018

You ever have one of those weeks where nothing seems to go right and the list of to-dos grows bigger instead of smaller? Well, welcome to my world this week. And since I imagine more than a few of you are also feeling the crunch as the fall clinic and academic season heats up, I thought we could commiserate. In the midst of it all I hope you can remember how valuable your work is and how each of us in our own small way are making a dent in the universe of healthcare. So, recoup this weekend and let’s give it another go next week!

And now some quick notes for your consideration:

We Messed Up The BOD Voting Process & Need To Start Over I told you we had a rough week. The good news is we have an outstanding slate of candidates for our board. The bad news is we messed up some procedural aspects of the voting process, specifically, we forgot to isolate the early career professional candidates, so we will re-start the voting process next week. So, please, do not vote until you hear from us again. We apologize!

Good News, Bad News The great news is that we are going to have a lot of people show up in Rochester. The bad news is that we have so many people showing up that we ran out of hotel rooms for Thursday-Friday nights. We are close to an agreement with another hotel, also connected to the convention center where sessions will be held, so stay tuned and check integratedcareconference.com for more info real soon. (In case you are wondering, we are on pace to break our all-time record attendance.)

42 CFR Part 2 We had a great phone call last week. Here are the minutes including helpful links: I won’t go into detail here because your eyes have probably already glazed over. So check it out when you have the time.

There’s so much more going on that we will share with you in the coming weeks and at our conference! Talk soon.

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