20 Mar Task Force Provides Recommendations to SAMHSA Regarding 42 CFR Part 2
The HCTTF generally supports the changes published earlier this year to the Part 2 Regulations including modifications that allow for consent to be executed to an intermediary. However, we believe that the Final Rule did not sufficiently address additional barriers to delivering high-value care under modernized care delivery models for the targeted patient population. Two specific concerns and recommendations for mitigation are provided below.
Task Force Response Summary
1. Effective Date of Supplemental Rule. We urge SAMHSA to finalize the Supplemental Rule as soon as possible and to implement simultaneous effective dates for both the Final Rule and Supplemental Rule.
2. Definition of Health Care Operations. The Task Force recommends that the definition of population health management and/or the list of services permitted for the purposes of health care operations be amended to include care coordination and case management.
Letter submitted on March 17, 2017