HIPAA Notice Requirements: Key Updates Due by February 16, 2026

Employers and health plan sponsors must update their HIPAA Notices of Privacy Practices by February 16, 2026.

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Published: 02.13.2026

The Health Insurance Portability and Accountability Act (HIPAA) regulations require updates to the Notice of Privacy Practices that health plan sponsors furnish to plan participants and health care providers furnish to patients. The updates must be made by February 16, 2026.
 
The regulations require changes to the Notice of Privacy Practices for information regarding certain substance use disorder treatment information and reproductive health information. Health plan sponsors and health care participants will want to consider:

• The measures they need to take to comply with the new notice requirements for protected health information originating at certain treatment centers for substance use disorders.
• Whether to make changes regarding reproductive health information, given that those regulations have been vacated by a federal district court.
• The extent to which other HIPAA-related documents should be amended.

The Bottom Line is the February 16 deadline is approaching, and employers should evaluate how they will respond and take appropriate action.
 
For insured health plans, the insurance carrier will generally bear the responsibility for preparing and providing the Notice. Self-insured plans will need to be prepared to address this and coordinate with their TPA.