In late November, HHS proposed long-awaited changes to regulations at 42 C.F.R. Part 2 (“Part 2”) governing the confidentiality of substance use disorder (“SUD”) records as required under the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. Generally, HHS is attempting to align Part 2 requirements with the HIPAA (“Health Insurance Portability and Accountability Act”) Privacy Rule. The most significant changes are those to the rules governing consent for entities subject to Part 2’s restrictions to use, disclose, and redisclose Part 2 records with respect to treatment, payment, and health care operations (“TPO”) activities.