User Story: 

As a Peer Recovery Specialist at Medical Home Development Group, she brings lived experience to her work, having been clean from substance use for six and a half years. In the past, she struggled with admitting her substance use to healthcare providers, fearing stigma and judgment. During one doctor’s visit, she denied using substances when asked, only for the doctor to inform her that her bloodwork revealed otherwise. Despite her continued denial, the doctor nearly prescribed a medication that could have caused severe reactions, including seizures, due to potential interactions with substances in her system. That moment was a wake-up call—she realized how critical it was for patients to be honest about their substance use to ensure their safety in medical settings. 

Now, she uses her personal story to educate others on the importance of transparency in healthcare. She encourages individuals to register their consent through the Health Information Exchange (HIE), explaining how sharing their medical and substance use history with providers can prevent dangerous drug interactions. When she shares her experience of nearly suffering severe consequences from a lack of disclosure, many patients immediately understand the risks and sign the electronic consent form without hesitation. 

Implementing 42 CFR Part 2 Updates:

In February 2024, the U.S. Department of Health and Human Services (HHS) finalized updates to 42 CFR Part 2, aligning substance use disorder (SUD) record confidentiality more closely with HIPAA. 

Key Changes:

  • A single consent now covers all future disclosures for treatment, payment, and healthcare operations (TPO). 
  • HIPAA-covered entities and business associates can redisclose SUD records per HIPAA guidelines. 

CRISP DC’s Response:

  • To comply with these changes, CRISP DC collaborated with legal and policy partners to update the SUD treatment consent process. 
  • October 1, 2024: The updated SUD consent form is available in the CRISP DC Consent Tool. 
  • January 6, 2025: 42 CFR Part 2 SUD data is shared via the HIE under the new consent framework. 
  • Hosting monthly webinars to share our findings from different organizations and to hear from individuals who have experience registering consent 

Key Features:

  • Consent workflow remains the same. 
  • Patients provide one-time consent for TPO. 
  • Consent can be set to “does not expire” but remains revocable anytime. 
  • Managed Care Organizations (MCOs) can submit and access SUD data through the HIE. 

Questions? 

If you have any additional follow up questions regarding the CRISP DC Consent Tool, please reach out to the eHealth DC team (Dr. Zarfishan Zahid, Renee Moore) or CRISP DC Project Lead Abby Lutz.