February 16 Deadline For HIPAA Privacy Notice Update Rapidly Approaching

February 12, 2026

February 16, 2026, is the deadline for health care providers, group health plans and health insurers to update and redistribute their Health Insurance Portability and Accountability (“HIPAA”) Notice of Privacy Practices (“Privacy Notice”) to comply with recent federal rule changes strengthening protections certain Part 2 substance use disorder (“SUD”) records (the “SUD Rules”). Timely update of Privacy Notices and compliance with these related requirements is particularly critical for the following organizations, who regularly receive and handle SUD records:

  • Behavioral health providers;
  • Integrated delivery systems;
  • Health plans receiving SUD claims data; and
  • Third party administrators, utilization management, and other health plan service providers involved in the administration of behavioral health or substance abuse benefits.

HIPAA Privacy Notice Generally

The HIPAA regulations require most health care providers, group health plans and health care clearinghouses (“Covered Entities”) to provide a Privacy Notice that meets the content and distribution requirements of the HIPAA rules. See 45 C.F.R. § 164.520. Health plans generally must deliver the Privacy Notice to their members at enrollment.  Health care providers generally must present the Privacy Notice to patients at least once a year, try to obtain acknowledgement of receipt, display it at their service locations and “prominently post” it on their websites.

Noncompliance with these and other HIPAA requirements can trigger a wide range of adverse consequences, including:

  • Complicate the administration and defense of HIPAA compliance;
  • Fuel HIPAA complaints from PHI subjects or others;
  • Trigger OCR enforcement and the potential civil monetary penalties and corrective action plans;
  • Expose noncompliant health plan fiduciaries to fiduciary investigation and liability under the Employee Retirement Income Security Act;
  • Expose health care providers to licensure, ethical or other professional investigations and sanctions;
  • Expose health care providers and insurers to licensing or other state regulatory enforcement actions;
  • Violate stop-loss, liability or other contracts;
  • Expose health plans, their fiduciaries and other covered entities to added expense to respond to and defend complaints and investigations; and
  • Create reputational risk.

Privacy Notice Updates Due February 16, 2026

The Privacy Notice updates currently due by February 16, 2026, arise from the 2024 Final Rule aligning 42 CFR Part 2 with HIPAA jointly published by the Substance Abuse and Mental Health Services Administration (“SAMHSA”) and OCR to align the substance abuse privacy rules in 42 CFR Part 2 more closely with HIPAA.

While most of the SUD rules operational provisions already are in effect, Covered Entities that maintain SUD records subject to Part to have until February 16, 2026, to update and timely distribute their Privacy Notices to:

  • Explain how Part 2 records may be used and disclosed.
  • Describe patients’ rights to obtain an accounting of disclosures, request restrictions, file complaints and describe potential penalties for misuse.

Along with updating their Privacy Notices content, health plans and other Covered Entities also need to update their Privacy Notice postings and distributions.  Health plans generally are encouraged to follow best practices by treating the revisions as material revisions impacting their health plans and err in favor of broad distribution. Health plans generally should distribute the updated notice to plan participants within 60 days of a material revision or include notice of its availability in its next annual mailing and post an updated copy on the plan’s website. In contrast, health care providers must meet slightly broader distribution requirements, that generally require a health care provider:

  • Ensure the updated notice is provided to new patients at check-in and request a signed acknowledgement of receipt from the patient at least once a year;
  • Post the revised Privacy Notice in a clear and prominent locations in treatment areas as required by the Privacy Rule;
  • Make copies available upon request; and
  • Post electronically on websites

Beyond these specific actions in response to the 2024 Final Rule aligning 42 CFR Part 2, self-insured ERISA plans, their employer or other plan sponsors, fiduciaries, and service providers should take the following steps:

  • Update the plan’s HIPAA Notice;
  • Review and update as necessary HIPAA policies and practices, plan documents and other documentation to ensure compliance with new rule and updated HIPAA Privacy Notie ;
  • Communicate and coordinate with business associates and other service providers and vendors to verify their process and practices are updated to comply with the new requirements;
  • Conduct any necessary training and education for workforce members and business associates;
  • Document compliance efforts; and
  • Take steps to monitor compliance on an ongoing basis.

Review To Confirm Continuing Adequacy Of Other Existing Privacy Notice Content Also Advisable

Along with implementing the changes necessary to ensure their Privacy Notices comply with the SUD Rules of 42 CFR Part 2 alignment, group health plans and other Covered Entities also should review and update their Privacy Notices to confirm other content continues to meet OCR’s Privacy Notice requirements.

Since OCR has not substantively revised the content requirements for Privacy Notices or its model Notice of Privacy Practices for many years, many group health plans and other covered entities take for granted that the existing content of their Privacy Notices remains compliant.  While OCR’s rules have not changed, group health plans and other Covered Entities often have experienced changes in staffing, addresses or other operational details that may make updates to their Privacy Notices required or advisable.  Failing to update Privacy Notices to reflect these changes can both violate HIPAA and fuel a wide range of potentially costly miscommunications and disagreements.  Consequently, group health plan sponsors, fiduciaries and service providers, as well as other Covered Entities also are encouraged to review their existing Privacy Notices for any updates required in response to these and other changes.

HIPAA Privacy Rule to Support Reproductive Health Care Privacy No Longer Required

Covered Entities currently do not have to change their Privacy Notices to add disclosures about new requirements for the disclosure of protected health information (“PHI”) relating to reproductive rights that OCR sought to require under its HIPAA Privacy Rule to Support Reproductive Health Care Privacy (“Reproductive Rights Rule”), as the U.S. District Court for the Northern District of Texas vacated those requirements in Purl v. United States Department of Health and Human Services, No. 2:24-CV-228-Z, (N.D. Tex. June 18, 2025).

Had the District Court not struck down the Reproductive Rights Rule last June, Covered Entities also would have been required by February 16, 2026, to revise their Privacy Notices to discuss OCR HIPAA rules restricting disclosures of protected health information (“PHI”) related to lawful reproductive health care.  

OCR adopted the Reproductive Rights Rule as part of a broader series of actions by the Biden Administration intended to mitigate the effect of the Supreme Court’s ruling in Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215 (2022). Dobbs restored state power to regulate abortion by reversing the Supreme Court’s decades-old decision in Roe v. Wade, which had recognized a woman’s right to abortion as part of a fundamental right to reproductive privacy.

In furtherance of these broader efforts to limit state efforts to regulate abortion and other reproductive rights, the Reproductive Rights Rule prohibited Covered Entities from using or disclosing PHI:

  • For criminal, civil, or administrative investigations into lawful reproductive health care
  • To identify a person for such investigations
  • For proceedings related to lawful reproductive health care

It also required Covered Entities and their business associates to:

  • Obtain a signed attestation before disclosing reproductive health information for certain law enforcement or oversight requests
  • Revise their Privacy Notice to describe these new protections

The federal district court’s ruling makes these updates unnecessary at this time.

If you have questions about these health plan exposures or other health care, workforce employee benefits or other regulatory compliance or investigations concerns, contact the author. 

For More Information

We hope this update is helpful. For more information about the or other health or other employee benefits, human resources, or health care developments, please contact the author Cynthia Marcotte Stamer via e-mail or via telephone at (214) 452 -8297.

Solutions Law Press, Inc. invites you receive future updates by following this publication using the link provided, registering on our Solutions Law Press, Inc. Website and participating and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.

About the Author

Cynthia Marcotte Stamer is a Martindale-Hubble AV-Preeminent (highest/top 1%) practicing attorney recognized as a “Top Woman Lawyer,” “Top Rated Lawyer,” and “LEGAL LEADER™” in Health Care Law and Labor and Employment Law; among the “Best Lawyers In Dallas” in “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law recognized for her experience, scholarship, thought leadership and advocacy on health and other employee benefits, insurance, healthcare, workforce, HIPAA and other data and technology and other compliance in connection with her work with health care and life sciences, employee benefits, insurance, education, technology and other highly regulated and performance-dependent clients.

Board certified in labor and employment law by the Texas Board of Legal Specialization and a Fellow in the American College of Employee Benefits Counsel, Ms. Stamer has more than 35 years of experience advising and representing health care providers, managed care and insurance organizations, employers, employee benefit plans and their fiduciaries and administrators, their administrative services, technology and other business associates and other clients about these and other workforce, employee benefits, internal controls and other operations and compliance concerns. 

Ms. Stamer is nationally sought out for her decades of leading-edge experience in the design, sponsorship, administration, and defense of health and other employee benefit, workforce, insurance, healthcare, data and technology, and other operations to promote legal and operational compliance, reduce regulatory and other liability, and advance other operational goals. This experience includes decades of work on HIPAA and other medical and other data and technology privacy, security and other management, including years of service as the Scribe leading the American Bar Association Joint Committee on Employee Benefits Annual Agency Meeting with the Department of Health and Human Services Office of Civil Rights, extensive advice to health plans and insurers, their sponsors, fiduciaries and service providers; managed care organizations, health care organizations, health care clearinghouses and other health data and technology providers; and others about HIPAA and other Federal, state and international privacy and data security; and extensive speaking and publications on these and related concerns.

Along with her decades of legal and strategic consulting experience, Ms. Stamer also contributes her leadership and experience to many professional, civic and community organizations. She currently serves as Co-Chair of the ABA Real Property Trusts and Estates (“RPTE”) Section Welfare Plan Committee, Co-Chair of the ABA International Section International Employment Law Committee and its Annual Meeting Program Planning Committee, Chair Emeritus and Vice Chair of the ABA Tort Trial and Insurance (“TIPS”) Section Medicine and Law Committee, and Chair of the ABA Intellectual Property Section Law Practice Management Committee. She also has served as Scribe for the Joint Committee on Employee Benefits (“JCEB”) annual agency meetings with the Department of Health and Human Services and JCEB Council Representative, International Section Life Sciences Committee Chair, RPTE Section Employee Benefits Group Chair and a Substantive Groups Committee Member, Health Law Section Managed Care & Insurance Interest Group Chair, as TIPS Section Medicine and Law Committee Chair and Employee Benefits Committee and Workers Compensation Committee Vice Chair, Tax Section Fringe Benefit Committee Chair, and in various other ABA leadership capacities. Ms. Stamer also is a former Southwest Benefits Association Board Member and Continuing Education Chair, SHRM National Consultant Board Chair and Region IV Chair, Dallas Bar Association Employee Benefits Committee Chair, former Texas Association of Business State, Regional and Dallas Chapter Chair, a founding board member and Past President of the Alliance for Healthcare Excellence, as well as in the leadership of many other professional, civic and community organizations. She also is valued and celebrated for her decades of policy advocacy and charitable, pro bono, community and other service and leadership to promote understanding and strengthening health care, workforce, saving, disability, aging and retirement and other key policies and challenges through her PROJECT COPE Coalition For Patient Empowerment initiative and many other pro bono service involvements locally, nationally and internationally.

Ms. Stamer is the author of many highly regarded works published by leading professional and business publishers, the ABA, the American Health Lawyers Association, and others. Ms. Stamer also often speaks and serves on the faculty and steering committee for many ABA and other professional and industry conferences and conducts leadership and industry training for a wide range of organizations.

For more information about Ms. Stamer or her health industry, health and other benefits, workforce and other experience and involvements, see the Cynthia Marcotte Stamer P.C. website or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

About Solutions Law Press™

Solutions Law Press™ provides health care, insurance, human resources and employee benefit, data and technology, regulatory and operational performance, and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education. These include extensive resources on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press™ resources or training.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating your profile here.

NOTICE: These statements and materials are for general information and purposes only. They do not establish an attorney-client relationship, are not legal advice or an offer or commitment to provide legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation considering the specific facts and circumstances presented in their unique circumstances at the particular time. No comment or statement in this publication is to be construed as legal advice or admission. Solutions Law Press and its authors reserve the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law constantly and often evolves, subsequent developments that could change the currency and completeness of this discussion are likely. Solutions Law Press and its authors disclaim and have no responsibility to provide any update or otherwise notify anyone of any fact or law-specific nuance, change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2026 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press. ™ For information about licensing for republication, please contact the author directly. All other rights reserved

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Posted by Cynthia Marcotte Stamer

Express Scripts Promises “Fundamental” PBM Practice Reforms To Settle FTC Lawsuit As Labor Department Proposes New PBM Compensation Transparency Requirements

February 4, 2026

Prescription benefit manager (“PBM”) Express Scripts, Inc. and its affiliated entities (collectively “ESI”) must adopt “fundamental” business practice changes intended to enhance transparency in its PBM practices under a “landmark settlement” that resolves its exposure to FTC charges that the nation’s three largest PBMs – ESI, Caremark Rx, and OptumRx and their affiliated group purchasing organizations (“GPOs”) – illegally used anticompetitive and unfair rebating practices to artificially inflate prices of and restrict patient access to insulin drugs made in a FTC lawsuit.

In Caremark Rx, Zinc Health Services, et al., In the Matter of (Insulin), the FTC sued the nation’s three largest PBMs, ESI, Caremark Rx, and OptumRx and their affiliated GPOs, for illegally driving up insulin prices and disrupting patient access to insulin by engaging in anticompetitive and unfair rebating practices.

Specifically, the FTC alleges these PBMs use of restrictive formularies that completely excluded certain drugs from coverage coerced pharmaceutical manufacturers to provide PBMs higher rebates to avoid exclusion of their products outright from the PBM formularies required for insurance coverage for tens of millions of patients. Leveraging this threat of exclusion, the FTC charges PBMs began demanding higher and higher rebates from drug manufacturers in exchange for placing those drugs on their restrictive formularies. While the race for higher rebates, in principle, should have reduced drug costs for patients, the FTC says the PBMs’ “insatiable demand for larger rebates” and manufacturers’ desire to preserve their own profits drove manufacturers steadily to increase the list price of their drugs. The FTC claims the resulting dynamic artificially inflated list prices disconnected from the actual cost of the drugs to insurers.

Since patients’ out-of-pocket expenses are directly or indirectly tied to these inflated prices, uninsured patients often pay the full list price, while insured patients with high deductibles or co-insurance also face higher costs based on these inflated list prices. As a result, as rebates and list prices rise in tandem, these groups of patients are burdened with higher out-of-pocket costs for their medications.

The FTC claims this broken system has far-reaching consequences. it causes opaque an drug pricing and reimbursement system, which benefits the PBMs and manufacturers, but deliberately obscures the full scope of harm and financial cost from insurers and patients unknowingly shouldering the burden of inflated list prices.

While the dynamic impacts many prescription drugs, the FTC says insulin is the poster child of this distorted system.

The FTC settlement resolves ESI’s liability exposure from the FTC lawsuit regarding insulin pricing and competition in return for it, making significant changes in its PBM pricing and other practices. Among other things, ESI agrees no longer to prefer drugs with high list prices on its standard formularies when cheaper equivalents exists. ESI also will delink its compensation from the savings it negotiates with drugmakers. ESI also commits to increase transparency, including reporting more data on drug spending and disclosing any kickbacks to brokers that help employers choose PBMs. ESI also agreed to reshore its group purchasing organization Ascent from Switzerland back to the United States.

GPOs, which aggregate PBMs’ members to improve their negotiating leverage with drugmakers, have been accused of facilitating shell games that allow PBMs to retain more drug rebates as profit. However oversight is tricky given no major GPOs are headquartered in the U.S.

The FTC predicts ESI deal will drive down patients’ out-of-pocket costs for drugs like insulin by up to $7 billion over a decade and bring millions of dollars in new revenue to community pharmacies by requiring Express Scripts to move its pharmacy reimbursement to a cost-plus model. If there’s noting that ESI reportedly .already was transitioning to a cost plus model. 

The FTC lawsuit continues against Caremark Rx, and UnitedHealth owned OptumRx and their affiliated GPOs.

The settlement announcement follows the U.S. Department of Labor e Department of Labor last week issued a proposed rule to improve transparency of fees collected by pharmacy benefit managers. If adopted as proposed, the rule will require PBMs to disclose rebates and other payments from drug manufacturers, compensation received when the price paid by a health plan for a prescription drug exceeds the amount reimbursed to the pharmacy, and payments recouped from pharmacies in connection with prescription drugs dispensed to a health plan. The proposal would also allow plan fiduciaries to audit the accuracy of PBM disclosures and provide additional relief if their PBM fails to meet its obligations under the rule.

The FTC and Labor Department actions are part of a series of federal activities undertaken in response to directives of President Donald Trump to provide greater healthcare transparency and bring down the cost of prescription medications and other healthcare costs. See, e.g. The Great Healthcare Plan; Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information; Delivering Most Favored-Nation Prescription Drug Pricing To American Patients (May 12, 2025).

PBMs, healthcare providers, health plans and their sponsors and their fiduciaries and service providers, pharmaceutical manufacturers and distributors, and consumers should carefully follow these and other developments do you understand there’re evolving responsibilities and opportunities under these changing rules and enforcement positions. receive updates on these another developments, follow this resource or email your contact information to the author.

If you have questions about this or other health care concerns, contact the author. 

For More Information

We hope this update is helpful. For more information about the  or other health or other employee benefits, human resources, or health care developments, please contact the author Cynthia Marcotte Stamer via e-mail or via telephone at (214) 452 -8297.

Solutions Law Press, Inc. invites you receive future updates by registering on our Solutions Law Press, Inc. Website and participating and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.

About the Author

Peer recognized as “Top Rated Lawyer” and “LEGAL LEADER™ “Top Rated Lawyer” and “Best Lawyer” for her work in Health Care Law, Labor and Employment Law; ERISA & Employee Benefits,” and “Business and Commercial Law,” Cynthia Marcotte Stamer is an A Martindale-Hubble “AV-Preeminent” (Top 1%) attorneys board certified in labor and employment law by the Texas Board of Legal Specialization and management consultant, author, public policy advocate and lecturer widely known for her more than 35 years of health industry and other management work, public policy leadership and advocacy, coaching, teachings, and publications including leading edge work on PBM, pharmacy and pharmaceutical and other health care, managed care, insurance, and insured and self-insured contracting, design, administration and regulation.. 

Author of numerous highly regarded works on health law and policy, Immediate Past Chair of the ABA International Section Life Sciences Committee and the current Tort Trial and Insurance Practice Section Medicine and Law Committee, past Chair of the ABA Health Law Section Managed Care & Insurance Interest Group and past Group Chair and current Welfare Benefit Committee Co-Chair of the ABA RPTE Employee Benefits & Other Compensation Group, Ms. Stamer is most widely recognized for her decades of pragmatic, leading edge work, scholarship and thought leadership on health and other privacy and data security and other health industry legal, public policy and operational concerns. 

Ms. Stamer’s work throughout her career has focused heavily on working with health care and managed care, health and other employee benefit plan, insurance and financial services and other public and private organizations and their technology, data, and other service providers and advisors domestically and internationally with legal and operational compliance and risk management, performance and workforce management, regulatory and public policy and other legal and operational concerns.  As a part of this work, she has continuously and extensively worked with domestic and international health plans, their sponsors, fiduciaries, administrators, and insurers; managed care and insurance organizations; third party administrators and other health benefit service providers; hospitals, health care systems and other health care providers, accreditation, peer review and quality committees and organizations; billing, utilization management, management services organizations, group purchasing organizations; pharmaceutical, pharmacy, and prescription benefit management and organizations; consultants; investors; EMR, claims, payroll and other technology, billing and reimbursement and other services and product vendors; products and solutions consultants and developers; investors; managed care organizations, self-insured health and other employee benefit plans, their sponsors, fiduciaries, administrators and service providers, insurers and other payers, health industry advocacy and other service providers and groups and other health and managed care industry clients as well as federal and state legislative, regulatory, investigatory and enforcement bodies and agencies.

She also has extensive experience helping health care systems and organizations, group and individual health care providers, health plans and insurers, health IT, life sciences and other health industry clients prevent, investigate, manage and resolve  sexual assault, abuse, harassment and other organizational, provider and employee misconduct and other performance and behavior; manage Section 1557, Section 504, Civil Rights Act and other discrimination and accommodation, and other regulatory, contractual and other compliance; vendors and suppliers; contracting and other terms of participation, medical billing, reimbursement, claims administration and coordination, Medicare, Medicaid, CHIP, Medicare/Medicaid Advantage, ERISA and other payers and other provider-payer relations, contracting, compliance and enforcement; Form 990 and other nonprofit and tax-exemption; fundraising, investors, joint venture, and other business partners; quality and other performance measurement, management, discipline and reporting; physician and other workforce recruiting, performance management, peer review and other investigations and discipline, wage and hour, payroll, gain-sharing and other pay-for performance and other compensation, training, outsourcing and other human resources and workforce matters; board, medical staff and other governance; strategic planning, process and quality improvement; meaningful use, EMR, HIPAA and other technology,  data security and breach and other health IT and data; STARK, ant kickback, insurance, and other fraud prevention, investigation, defense and enforcement; audits, investigations, and enforcement actions; trade secrets and other intellectual property; crisis preparedness and response; internal, government and third-party licensure, credentialing, accreditation, HCQIA and other peer review and quality reporting, audits, investigations, enforcement and defense; patient relations and care;  internal controls and regulatory compliance; payer-provider, provider-provider, vendor, patient, governmental and community relations; facilities, practice, products and other sales, mergers, acquisitions and other business and commercial transactions; government procurement and contracting; grants; tax-exemption and not-for-profit; privacy and data security; training; risk and change management; regulatory affairs and public policy; process, product and service improvement, development and innovation, and other legal and operational compliance and risk management, government and regulatory affairs and operations concerns. to establish, administer and defend workforce and staffing, quality, and other compliance, risk management and operational practices, policies and actions; comply with requirements; investigate and respond to Board of Medicine, Health, Nursing, Pharmacy, Chiropractic, and other licensing agencies, Department of Aging & Disability, FDA, Drug Enforcement Agency, OCR Privacy and Civil Rights, Department of Labor, IRS, HHS, DOD, FTC, SEC, CDC and other public health, Department of Justice and state attorneys’ general and other federal and state agencies; JCHO and other accreditation and quality organizations; private litigation and other federal and state health care industry actions: regulatory and public policy advocacy; training and discipline; enforcement;  and other strategic and operational concerns.

Author of publications on “Transparent PBM Contracting,” “ACOs, Direct Contracting: Legal & Practical Challenges For Employers, Providers & TPAs,” “The Medicare Advantage Contracting Manual,” “Third Party Administrator (TPA) Contracting Principles and Strategies and a multitude of other highly regarded publications and presentations,  Stamer is widely recognized for her thought leadership on PBM and other managed care and health plan contracting and design, and a multitude of other health care, health plan and other health industry matters.  In addition, Ms. Stamer contributes her time and leadership to numerous policy, professional, civil and other organizations including service as the, the American Bar Association (ABA) International Section Life Sciences Committee Vice Chair, a Scribe for the ABA Joint Committee on Employee Benefits (JCEB) Annual OCR Agency Meeting and a former Council Representative, Past Chair of the ABA Managed Care & Insurance Interest Group, former Vice President and Executive Director of the North Texas Health Care Compliance Professionals Association, past Board President of Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency, past North Texas United Way Long Range Planning Committee Member, and past Board Member and Compliance Chair of the National Kidney Foundation of North Texas, and a Fellow in the American College of Employee Benefit Counsel, the American Bar Foundation and the Texas Bar Foundation, Ms. Stamer also shares her extensive publications and thought leadership as well as leadership involvement in a broad range of other professional and civic organizations. For more information about Ms. Stamer or her health industry and other experience and involvements, see www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

About Solutions Law Press, Inc.™

Solutions Law Press, Inc.™ provides human resources and employee benefit and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press, Inc.™ resources. 

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating your profile here.

NOTICE: These statements and materials are for general information and purposes only. They do not establish an attorney-client relationship, are not legal advice or an offer or commitment to provide legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation considering the specific facts and circumstances presented in their unique circumstance at the particular time. No comment or statement in this publication is to be construed as legal advice or an admission. The author reserves the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law constantly and often rapidly evolves, subsequent developments that could impact the currency and completeness of this discussion are likely. The author and Solutions Law Press, Inc. disclaim and have no responsibility to provide any update or otherwise notify anyone of any  fact or law specific nuance, change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2026 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press, Inc.™ For information about republication, please contact the author directly. All other rights reserved.

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Posted by Cynthia Marcotte Stamer