HHS Updated Sample
Notice Of Privacy Practices
As indicated in Moreton’s January 21, 2026 client alert, as of February 16, 2026, due to statutory amendments, HIPAA covered entities (including health plans) are required to update their Notice of Privacy Practices (NPPs) to include information about substance use disorder patient records. On February 13, 2026, the Department of Health and Human Services (HHS) provided a new sample NPP template with the updated language. The updated NPP template can be accessed here: hhs.gov/hipaa/for-professionals/privacy/guidance/model-notices-privacy-practices/index.html
Health plan sponsors should update any NPP in their plan materials, posted on their website, etc. Note: Plan sponsors do not need to send a copy of the updated NPP to participants but should use the updated NPP in all plan materials and distribution going forward.
