HIPAA Notice of Privacy Practices for Federally Qualified Health Centers
Federally Qualified Health Centers (FQHCs) are HIPAA covered entities that provide comprehensive primary care across multiple payer types and often include behavioral health, dental, and SUD treatment services. Your HIPAA Notice of Privacy Practices must reflect this multi-service complexity and be updated to the HHS February 2026 model.
Quick facts for FQHCs and community health centers
- All FQHCs are HIPAA covered entities — the NPP requirement is non-negotiable
- FQHCs offering integrated SUD treatment likely need 42 CFR Part 2 language in their NPP since February 2026
- Multi-site FQHCs can use one NPP for the organization if all sites are part of the same legal entity
- FQHCs serving LEP populations should have a process for NPP translation or summaries on request
- The HHS February 2026 model is the current standard — pre-2026 NPPs are out of compliance
FQHCs and integrated behavioral health
Many FQHCs operate integrated behavioral health programs that include mental health and substance use disorder treatment. This creates a layered compliance picture:
- Mental health services. If your FQHC's behavioral health providers maintain psychotherapy notes (as defined at 45 CFR § 164.501), your NPP must include psychotherapy-notes disclosure language.
- SUD treatment programs. FQHCs that operate federally-assisted SUD treatment programs are Part 2 programs. Since February 16, 2026, the HHS model integrates 42 CFR Part 2 protections into the HIPAA NPP. If your FQHC is a Part 2 program, you need the combined HIPAA + Part 2 NPP. See Part 2 SUD language in your NPP.
- Dental services. FQHC dental departments are covered under the same FQHC NPP — no separate dental NPP is needed if the dental program operates under the same legal entity.
Language access and the NPP
FQHCs serve diverse patient populations including patients with limited English proficiency. HIPAA requires covered entities to inform patients in their language (if a significant portion of the patient population speaks that language) that translation of the NPP is available. This does not mean your NPP itself must be in multiple languages by default, but you must:
- Notify patients in their language that they can request a translated NPP
- Have translated versions or summaries available for your primary non-English patient languages
- Document when translations are requested and provided
Distribution requirements for multi-site FQHCs
- Provide to each new patient at first service at any FQHC site
- Post the NPP on your public website
- Post in each service delivery site's patient waiting area
- Have paper copies available for patients who request them
- Provide to existing patients when material changes occur
Frequently Asked Questions
Do FQHCs need a HIPAA NPP?▼
Yes. FQHCs are HIPAA covered entities by virtue of their Medicare and Medicaid claims submission. The NPP is required by 45 CFR § 164.520 regardless of HRSA designation.
Does our SUD treatment program require Part 2 NPP language?▼
Yes, if your FQHC is a federally-assisted SUD treatment program. The 2024 Part 2 Final Rule and February 2026 model integrated Part 2 protections into the HIPAA NPP. FQHCs that "hold themselves out" as providing SUD diagnosis, treatment, or referral under federal assistance must use the combined model. See Part 2 SUD language.
Can our FQHC use the same NPP as our affiliated hospital?▼
Only if the FQHC and hospital are part of an Organized Health Care Arrangement (OHCA) and share an NPP that discloses the arrangement. Otherwise, each legal entity needs its own NPP. Consult your compliance team before sharing an NPP across affiliated entities.
Does our Look-Alike health center need a HIPAA NPP?▼
Yes. FQHC Look-Alikes receive HRSA designation and typically bill Medicare and Medicaid electronically, making them HIPAA covered entities with the same NPP obligations as full FQHCs.
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