Feb. 16, 2026 Deadline: HIPAA Training & Privacy Notice Updates
By February 16, 2026, all HIPAA-covered entities — including dental practices — must update their Notice of Privacy Practices (NPP) to include specific information about how they handle substance use disorder (SUD) treatment records protected under federal law (42 CFR Part 2). They must also train their workforce on these updates.
Two training courses are now available in ComplyBetter to help meet this requirement:
2026 HIPAA Privacy Rule Update: SUD Records: A focused 10-minute module covering only the new SUD protections.
Assign this to team members who have already completed HIPAA training this year and just need training on the new updates.
2026 HIPAA Compliance Training (1 CE Hour): Our full annual HIPAA course, now updated to include the SUD requirements.
Assign this to anyone due for their annual HIPAA training.
Both courses are available through your office management tool and Discover New page.
Remember: All ComplyBetter features and courses are online, on-demand and included in membership at no extra cost!
What to Do by Feb. 16 to Be Compliant
Log-in to ComplyBetter and assign the appropriate training course to your team through your office management tool (must complete training by February 16).
Update and post your new Notice of Privacy Practices in a prominent location in your office and on your website if applicable (a template is available in the above courses and was emailed to office administrators - if you would did not receive this email, please contact us).
Have copies of the updated NPP available for patients who request them.
Provide the updated NPP to new patients at intake.
Questions about this requirement? Contact the ComplyBetter team.
Get Started with ComplyBetter
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Contact our expert team to learn more or schedule a demo.
Additional Information
What are SUD Records?
SUD records include information related to a patient’s identity, diagnosis, or treatment for substance use disorder that comes from a federally assisted SUD program, such as an addiction treatment facility. These records are protected under stricter rules than typical health records covered by HIPAA.
What Dental Offices Should Know
While most dental offices do not create SUD records, you still may receive SUD records as part of coordinating care with another provider or facility. These records are protected under stricter rules and must be handled differently.
Here are some of the key updates you need to know to be compliant:
You can use SUD records for treatment, payment, and healthcare operations just like other PHI.
You cannot disclose SUD records in legal proceedings against the patient without their written consent or a court order — even if subpoenaed.
For most dental practices, this won't change daily operations. But your team should understand that if you see SUD records in a patient's history, they aren't treated the same as other medical records when it comes to legal requests.
What About Reproductive Health Privacy Rules?
You may have heard about HIPAA changes related to reproductive health information. Those provisions were vacated by a federal court in June 2025 and are no longer in effect — you do not need to include reproductive health language in your NPP.
What Needs to Be in Your Updated Notice of Privacy Practices?
Your updated NPP must include:
How SUD records may be used and disclosed
Patient rights related to SUD information
Your legal duties to protect these records
Limitations on use in legal proceedings
Restrictions on redisclosure
ComplyBetter users can access an updated NPP template in the courses above, or contact us for sample language to add to your current NPP.