October 25, 2019
The Honorable Elinore F. McCance-Katz, M.D., Ph.D.
Assistant Secretary for Mental Health and Substance Use
Substance Abuse and Mental Health Services Administration
Department of Health and Human Services
5600 Fishers Lane
Rockville, MD 20857
RE: Confidentiality of Substance Abuse Disorder Patient Records
Dear Assistant Secretary McCance-Katz:
The Medical Group Management Association (MGMA) is pleased to submit the following response to the Substance Abuse and Mental Health Services Administration (SAMHSA) Proposed Rule, Confidentiality of Substance Abuse Disorder Patient Records. We appreciate the agency’s efforts to address the nation’s opioid epidemic and improve care coordination for individuals with a substance use disorder (SUD). Ensuring that clinicians have access to pertinent patient information is vital to the treatment process. However, how patient medical records are shared under 42 CFR Part 2 (Part 2) can significantly increase the chance of inappropriate access and the potential of patient discrimination. The regulatory environment should be structured to encourage patients to share their information with trusted care partners while not serving as a barrier to those seeking SUD treatment.
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