Faegre Drinker continues to represent Illinois Health Practice Alliance (IHPA) in connection with its ongoing operations as an independent practice association (IPA). IHPA negotiates managed care contracts and assists in the management and operation of accountable and value-based care programs on behalf of its network of behavioral health service agencies. Most recently, we have assisted IHPA in its negotiations with the Cook County Sheriff’s Office to develop a pilot program to share treatment information about clients of IHPA’s participating providers who become incarcerated, in order to ensure continuity of care for such clients while in jail and after release.
This matter is particularly complex in that it requires the sharing of behavioral health information, including substance-use disorder treatment information covered by 42 CFR Part 2, and assurances that such information will not be used for purposes other than treatment, including purposes relating to the reasons for any individual’s incarceration.