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 {{VERIFY: Feb 16 2026}}, and OCR's civil enforcement program for Part 2 went live {{VERIFY: enforcement start}}. Every Part 2 program in the country now has a current obligation under §{{VERIFY: 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

Figures pending citation review — bar lengths and percentages fill once the gate tokens clear. Sample is rolling (n={{VERIFY: n}}).
Result tier distribution
Share of sampled programs by posted-notice tier · n={{VERIFY: n}}
Current {{VERIFY: % current}} {{VERIFY: %}}
Partial {{VERIFY: % partial}} {{VERIFY: %}}
Outdated {{VERIFY: % outdated}} {{VERIFY: %}}
Missing {{VERIFY: % missing}} {{VERIFY: %}}
Most-missing required elements
Among posted notices, the elements a recycled HIPAA notice most often omits
Intermediary-disclosure list (§{{VERIFY: 2.24}}) {{VERIFY: freq}} {{VERIFY: %}}
Single-consent statement {{VERIFY: freq}} {{VERIFY: %}}
2024 accounting-of-disclosures change {{VERIFY: freq}} {{VERIFY: %}}

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): {{TODO: press one-pager}}
Reproduce a single read with the open skill: {{TODO: link part-2-notice-assessment skill when public repo confirmed live}}