By: Claudia Murray, RCC, RCCIR, FRBMA; Senior Vice President, Regulatory Affairs and Corporate Compliance Officer
Who: Practices, health plans, and providers who create or receive Substance Use Disorder (SUD) treatment-related records
Effective: February 16, 2026
Guidance from Chambliss, Bahner & Stophel, P.C. states, “Specifically, your NPP must include a separate statement that all SUD treatment-related records received from SUD providers regulated under Part 2, or any testimony conveying the contents of such records, cannot be “used or disclosed in civil, criminal, administrative, or legislative proceedings against” the person who received such treatment without his or her consent, or upon a court order issued after notice and hearing, as provided in Part 2. Any court order authorizing the use or disclosure of SUD treatment-related records must be accompanied by a subpoena or other legal requirement compelling disclosure before any such disclosure is made.”
MSN encourages all client practices to review their current Notice of Privacy Practices (NPP) and work with their legal counsel to implement the required notice.
To learn more, see Chambliss Law’s article on the upcoming compliance deadline.
Claudia Murray
RCC, RCCIR, FRBMA
Senior Vice President, Regulatory Affairs and Corporate Compliance Officer
Claudia brings an extensive background in Medicare regulations, law and billing processes having spent more than 20 years with the Medicare program in various roles. Prior to joining MSN Healthcare Solutions as their full-time compliance officer, Claudia headed a small consulting firm specializing in radiology and other hospital-based specialties. She consulted with MSN for 15 years in designing, implementing and advising on their compliance programs. Currently at MSN, Claudia is responsible for the myriad activities for HIPAA and corporate compliance as well as the Quality Payment Programs, bringing her full circle to CMS regulations and programs.
