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Operating Under 42 CFR Part 2 in a Coordinated Network
How to coordinate across organizations without breaking Part 2 confidentiality. The consent model that actually works.
HelioBH EditorialSecurity & Compliance•Security & Compliance•8 min•
The Part 2 misconception
42 CFR Part 2 does not prohibit coordination. It requires that clients consent to what is shared and with whom.
The right model is per-partner, per-purpose consent captured once and enforced everywhere.
What an operating system enforces automatically
Consent status is checked on every cross-org read. Revocation propagates in real time. Every disclosure is logged with the consent it relied on.
This is the technical control auditors ask for and it is where handwritten consent folders always fail.
