What share of posted notices have caught up?

Of substance use disorder treatment programs with public websites, what share post the Notice to Patients the 2024 rule requires — and of the notices that are posted, how many contain each element the rule requires?

The posted notice is the one piece of Part 2 compliance that is publicly checkable from outside. This study measures, at population scale, how much of the field has actually updated it.

A fresh, dated obligation

The 2024 Part 2 final rule's compliance date passed on February 16, 2026, and OCR began accepting Part 2 complaints the same day. Every Part 2 program in the country now has a current obligation under §2.22, and the publicly posted notice is the part of it anyone can check.

How a notice is read

The sampling frame is public directories — the SAMHSA Opioid Treatment Program Directory and FindTreatment.gov. A program is in scope if it holds itself out as providing SUD treatment and has a public website, since the posting duty attaches to programs with websites.

Most posted notices predate the rule

Interim read · population sample n=50 · frozen codebook v1.1 · July 10, 2026. 60% of sampled programs post either no clinical notice at all (24%) or a pre-2024 notice (36%). 10% post a fully current notice. The sample is rolling; figures update as it grows.
Result tier distribution
Share of sampled programs by posted-notice tier · population arm, n=50 · July 2026
Current 10.0%
Partial 30.0%
Outdated 36.0%
Missing 24.0%
Most-missing required elements
Share of assessed programs whose posted materials lack each 2024-rule element · frozen-codebook subset, n=28 (a program with no posted notice counts as lacking every element)
Redisclosure statement 78.6%
Single-consent statement 75.0%
Legal-proceedings statement 75.0%

A HIPAA notice is not a Part 2 notice

The gaps cluster in the Part 2-specific elements — the ones a recycled HIPAA Notice of Privacy Practices simply doesn't carry. A program can have updated its consent forms and still be posting a notice that predates the rule.

Because this is a rolling study, the number moves as the sample grows. The quarterly delta — how much the field has caught up — is the measurement that matters, and it's re-run on the same frame, not rebuilt.

This assesses what a program's posted documents say against what the 2024 rule requires — never an assertion about how the program handles records.

Aggregate only. No organization is named or identifiable in any published output. A complete notice does not prove compliant practice; an incomplete one does not prove the reverse.

For journalists and partners

A one-page findings brief — headline figure, tier chart, top missing elements, and the methodology one-liner — is available for citation.

One-page findings brief (PDF): available on request.
Reproduce a single read with the open skill: publishing to the open skills repository; available on request until it lands there.