Comment Letter

COGR Responds to HHS Notice of Proposed Rulemaking “Confidentiality of Substance Abuse Disorder Patient Records”

COGR, representing over 200 U.S. research institutions, submitted comments on the Department of Health and Human Services' proposed rule to align the confidentiality regulations for substance abuse disorder patient records (42 CFR Part 2) with HIPAA. COGR supports the alignment to reduce dual compliance burdens and enhance research capabilities, advocating for clearer allowances for creating de-identified and limited data sets and for permitting the use of such data without unnecessary restrictions or consent requirements, as allowed under HIPAA. The organization’s recommendations focus on facilitating essential research while maintaining strong privacy protections for research participants.

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