42 CFR Part 2 Training

Posted By Steve Alder on Dec 16, 2025

42 CFR Part 2 training is a functional requirement for workforces of healthcare facilities that provide substance use disorder services because it is impossible for workforces to comply with the Part 2 regulations if they do not know what restrictions apply to uses and disclosures of Part 2 protected information.

Although 42 CFR Part 2 does not contain a specific standard mandating 42 CFR Part 2 training, healthcare facilities that provide substance use disorder (SUD) services must comply with all applicable regulations relating to Part 2 uses, disclosures, consent, redisclosure warnings, and breach notifications.

It is not possible for workforces to comply with the regulations if they do not understand what Part 2 protected information is, how it can be used or disclosed, and why it needs protecting. Similarly, it is not possible for facilities to implement and enforce “confidentiality safeguards” (as required by §2.13 ) without providing 42 CFR Part 2 training so that workforce members are aware of what the safeguards are.

Who Should Provide 42 CFR Part 2 Training?

Healthcare providers and facilities that “hold themselves out” as providing SUD services should provide 42 CFR Part 2 training to all members of the workforce regardless of whether the provider or facility qualifies as a Part 2 program. If a unit within a general healthcare facility provides SUD services, all members of the unit’s workforce should be provided with 42 CFR Part 2 training.

In addition, any individual that receives Part 2 protected information as a “lawful holder”, or any member of a HIPAA covered entity’s workforce that receives Part 2 protected information under a TPO consent form, should also be provided with 42 CFR Part 2 training to ensure the limitations on further disclosures of Part 2 protected information are understood and complied with.

What Should Part 2 Training Consist Of?

Although, in theory, healthcare facilities could compile a training program consisting of Subparts B to E of the regulations, it is more effective to provide Part 2 training that explains why the regulations exist, what information is protected, and why it is important that the confidentiality of Part 2 protected information is maintained – not only for patients, but also for the facility and members of the facility’s workforce.

It is also advisable to provide Part 2 training in the context of real-life scenarios, and the compliance challenges workforce members will encounter. This will enable facilities to include practical advice on how to comply with the Part 2 regulations in situations that are relevant to workforce members’ roles. It will also help facilities identify where gaps in workforce knowledge exist.

Circumstances in Which Part 2 Training is Mandatory

42 CFR Part 2 training is described as a “functional requirement” above because it would be impossible for healthcare facilities to comply with the regulations if no training was provided. However, there are circumstances in which Part 2 training is mandatory or may apply to more types of healthcare facilities than those who provide SUD services.

For example, in California, New York, Pennsylvania, and Ohio, facilities offering SUD services are required to provide and document Part 2 training for licensing purposes. Facilities seeking SAMHSA certification as an Opioid Treatment Program must also be able to demonstrate that workforce members have received both HIPAA training and Part 2 training.

With regard to states that apply requirements similar to Part 2 to other healthcare services, many states require workforce members to receive confidentiality training when their roles involve access to mental health, reproductive health and/or behavioral health information or HIV/STI test results.

If you are unsure whether your healthcare facility is required to provide confidentiality training similar to 42 CFR Part 2 training to its workforce, you are advised to seek professional compliance advice.