AI scribes for addiction and SUD psychiatry
AI scribes for addiction and substance-use-disorder psychiatry sit at the intersection of HIPAA and 42 CFR Part 2. No vendor advertises Part 2 conformance as a shipped feature; readiness is a contract-level negotiation. For clinicians who share SUD records with third parties — most opioid-use-disorder and MAT programs do — verify with each vendor before enabling the scribe on those visits. For clinicians whose SUD records stay entirely within their own practice, standard HIPAA controls generally suffice.
42 CFR Part 2 in one paragraph
42 CFR Part 2 protects the confidentiality of records of patients with a substance-use disorder held by federally assisted programs, and imposes stricter re-disclosure rules than HIPAA. It applies most clearly when SUD records leave the treating program — for coordination with a primary care physician, a court, or a payer. It does not turn every mention of substance use into a Part 2 record; the record has to originate from a federally assisted program specifically for SUD treatment.
Vendor readiness (as of July 2026)
No AI scribe we track ships a Part 2 conformance certification. Twofold, Freed, and Nabla have signaled willingness to negotiate additional contractual terms — restricted subprocessor use, tighter audit logging, and Part 2-aware BAAs — for practices that need it. Enterprise vendors (Abridge, Suki, DeepScribe, Commure) will handle Part 2 requirements case-by-case as part of a broader enterprise contract.
Questions to ask each vendor
Does your BAA acknowledge 42 CFR Part 2? Which subprocessors receive audio and derived text? Can we opt out of any model-training use of Part 2 records specifically? What is your incident response for a suspected Part 2 disclosure?
MAT and opioid-use-disorder visit workflow
From the scribe's perspective, a MAT follow-up looks like a standard psychiatric medication-management visit: buprenorphine or naltrexone dosing, adherence check, side effects, drug screen results, counseling engagement. The compliance layer — Part 2 handling, DATA-Waiver documentation where still applicable, state PDMP checks — is separate from what the scribe produces. Use the scribe for the note; use your standard MAT program controls for compliance.
Segmenting SUD content in the record
The scribe cannot decide which content belongs in a Part 2-protected record and which does not. Design the workflow so that Part 2-covered visits land in a segmented location in the EHR, and non-Part 2 psychiatric care stays in the general chart. Some EHRs support explicit Part 2 flags; others require practice-level convention.
Frequently asked
- Is any AI scribe 42 CFR Part 2 compliant out of the box?
- No product markets a Part 2 conformance certification as of July 2026. Readiness is a contract-level negotiation with individual vendors.
- Can I use an AI scribe in an OTP or MAT clinic?
- Yes, if the vendor's BAA accommodates the additional Part 2 restrictions and your program's compliance officer signs off. Do not enable it silently without that review.
- Does mentioning alcohol or cannabis in a psychiatric note trigger Part 2?
- Not by itself. Part 2 attaches to records from federally assisted SUD programs specifically. General psychiatric care that touches on substance use is HIPAA-governed unless the practice is itself an SUD program.
Scribes referenced in this guide
Related guides
- HIPAA and AI scribes: what psychiatrists must verify
The specific HIPAA, BAA, encryption, audio-retention, and 42 CFR Part 2 checks a psychiatrist should run before using any AI scribe with real patients.
- AI scribes for psychiatric medication-management visits
How AI scribes handle 20-minute psychiatric med checks — dose changes, side-effect review, adherence, DSM-5 reassessment, and structured medication lists.