On September 10, 2025, the U.S. Court of Appeals for the Fifth Circuit dismissed an appeal of a June 2025 federal district court ruling in Purl et al. v. Department of Health & Human Services vacating new HIPAA Privacy Rule protections for uses and disclosures of information related to lawful reproductive health care. Although Covered Entities no longer need to comply with the new Privacy Rule provisions addressing reproductive health care, the federal court ruling did not disturb the new Privacy Rule requirements addressing substance use disorder treatment records covered under 42 CFR Part 2. Accordingly, medical practices and other Covered Entities must still update their HIPAA Notice of Privacy Practices by February 16, 2026 to address limitations on the use and disclosure of substance use disorder treatment records covered under Part 2. 

MSMS is working on updates to its HIPAA Guide to reflect these latest regulatory changes.