Under the previous regulations, CMS was required to redact all substance use disorder claims from the RIF files. The amendment request to add the “gap” files can be combined with any other file request or submitted separately. In order to request the “gap” files, submit an amendment request through ResDAC with the following materials: a Request Letter for an Amendment, a DUA Update form, and a Specifications Worksheet (request materials can be found on the Data Request Materials Index). Please be aware that “gap” files will be in the new version K. Researchers who previously received redacted claim files will be able to request the missing records, in the form of “gap” files. Research Identifiable Files shipped or extracted in the VRDC after are no longer subject to the redaction. Under these changes to the Part 2 regulations, CMS is now permitted to include substance use disorder claims data in the Research Identifiable Files (RIFs). On January 17, 2017, the Substance Abuse and Mental Health Services Administration (SAMHSA) finalized changes to the Confidentiality of Alcohol and Drug Abuse Patient Records Regulations, 42 CFR Part 2.
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