HIPAA & 42 CFR Part 2 APCM Checklist for SUD Providers

Ensure AI-driven enrollment workflows capture specific consent for the disclosure of SUD records as required by 42 CFR Part 2.

Attach mandatory 'prohibition on re-disclosure' notices to any SUD patient data shared with external APCM partners.

Configure EHR and AI call logs to isolate SUD-related treatment data from general medical records unless explicit consent is provided.

Set system alerts for the expiration of patient consents to ensure APCM outreach stops immediately upon withdrawal.

Establish multi-factor verification for patients calling for MAT refills or relapse prevention support via AI interfaces.

Use AI transcription to log every minute of non-face-to-face MAT monitoring and care coordination for G0568-G0570 billing.

Ensure the 24/7 AI triage team has real-time access to the patient's individualized recovery and relapse prevention plan.

Track all automated and manual efforts to coordinate naloxone distribution as part of the APCM chronic care workflow.

Automate the screening of housing and transportation barriers during APCM calls to justify high-complexity BHI coding.

Link SUD monitoring data to the patient’s AWV to demonstrate the medical necessity of continuous APCM enrollment.

Ensure Business Associate Agreements specifically acknowledge 42 CFR Part 2 responsibilities for handling SUD patient identities.

Verify that all recordings of MAT check-ins and relapse prevention calls are encrypted using AES-256 at rest.

Maintain logs of every staff member who accesses AI-generated summaries of SUD patient interactions.

Ensure AI models are trained on de-identified data to prevent the exposure of SUD patient names or specific treatment locations.

Implement encrypted 'warm transfers' from AI agents to live MAT coordinators for crisis or relapse interventions.