A major HIPAA compliance deadline, February 16, 2026, is approaching for colleges, universities, hospitals, and healthcare systems. All HIPAA-covered entities must update their Notices of Privacy Practices (NPPs) to comply with newly revised federal Privacy Rule requirements, with a strong focus on substance use disorder (SUD) privacy protections.
These updates affect how institutions handle sensitive health information across clinical, academic, and administrative environments. For organizations operating in blended higher‑education and healthcare settings, these changes represent a significant privacy and compliance shift.
Why the 2026 NPP Deadline Matters for Higher Education
Many colleges and universities operate HIPAA-covered components, including:
- Student health centers
- Campus hospitals and academic medical centers
- Counseling and behavioral health services
- Teaching clinics and training programs
- Athletic training and sports medicine units
These units manage protected health information (PHI), including highly sensitive SUD-related data, which places them directly under the updated HIPAA and 42 CFR Part 2 requirements. Institutions that share information across departments must reassess longstanding internal data‑flow assumptions to avoid compliance exposure.
Key HIPAA NPP Changes Colleges & Healthcare Providers Must Address
- Stricter Protections for SUD Treatment Records
The new rules more closely align HIPAA with 42 CFR Part 2, significantly limiting how SUD treatment information can be used or disclosed. Traditional HIPAA exceptions for treatment, payment, and operations may no longer apply in many scenarios.
- Limits on Use in Campus or Internal Proceedings
SUD records generally cannot be used in:
- Student conduct proceedings
- Title IX investigations
- Academic decisions
- Athletic eligibility reviews
…unless the individual provides explicit written consent or a court order is obtained. This represents a major compliance shift for institutions used to more flexible internal access.
- New Redisclosure Notice Requirements
Revised NPPs must explicitly inform patients or students when their information may be redisclosed once shared with outside organizations (e.g., community providers, specialists, partner clinics). This increased transparency is now a core compliance expectation.
- Fundraising Opt‑Out Obligations
If PHI is used for fundraising, individuals must be offered a clear, simple opt-out.
This directly affects:
- Academic medical centers
- University foundations
- Advancement teams connected to health services
Clear opt-out language is now critical to both trust and compliance.
- Removal of Invalidated Reproductive‑Health Language
Language added in response to vacated 2024 federal rules must be removed. Outdated or incorrect reproductive‑health privacy content can itself create new compliance risks.
What Hospitals and Health Systems Must Update
Healthcare systems face similar requirements and should verify that NPPs:
- Reflect expanded SUD protections
- Explain redisclosure risks
- Include compliant fundraising opt-outs
- Remove invalidated rule references
- Align HIPAA policies with 42 CFR Part 2
Organizations should also review policies, workforce training, and Business Associate Agreements (BAAs) to ensure consistency and compliance readiness.
For example, an NPP update does not itself create a separate legal obligation to amend BAAs. However, if a business associate will process Part 2 records in connection with performing services for a covered entity, the covered entity should update BAAs and applicable vendor terms to contractually bind the business associate to comply with any applicable Part 2 requirements.
How CampusGuard Supports NPP Compliance
CampusGuard can help higher education and healthcare organizations prepare through:
- HIPAA & 42 CFR Part 2 gap assessments
- NPP revisions and compliance alignment
- HIPAA awareness training for campus and clinical teams
- Business Associate Agreement reviews
- Broader privacy‑program modernization
Our approach minimizes disruption while reinforcing regulatory readiness.
Key Takeaways
The February 16, 2026, NPP update deadline marks a major milestone in HIPAA’s evolving privacy landscape. Institutions handling SUD information, healthcare data, or cross-departmental PHI should begin updating their NPPs now. Early action reduces risk, ensures compliance, and supports safer, more transparent information practices.
CampusGuard can provide expert guidance to help colleges, universities, hospitals, and health systems meet these new privacy requirements with confidence. Contact us to get started.
