Part 2 privacy-preserving site posting

Editorial approval scope: The team checked current source fidelity, scope boundaries, dates, arithmetic, reader usefulness, practical workflow, and general-information limitations.

Visibility and confidentiality must coexist

42 CFR 2.22 states both conditions. A sign visible only after a person enters a labeled SUD-only queue can expose service status. Review entrances, shared waiting areas, check-in screens, take-away copies, and staff directions.

Create a site register with program, legal entity, public identity, address, service setting, entrances, waiting and check-in paths, co-located services, participant or tenant relationships, opening and closure dates, notice version, placement, copy inventory, owner, and inspection evidence. Document how a person can read or take the notice without being singled out as a patient.

Walk the real visitor path

Inspect from parking, entrance, security, reception, kiosk, waiting area, hallway, service desk, and exit. Test regular, evening, weekend, alternate-entrance, mobile, temporary, and shared-campus operations. Ask whether looking at the display, scanning a code, or taking a copy exposes SUD service status to other visitors or staff without a need to know.

In a shared facility, use placement and public wording that fits the environment while preserving the complete approved notice. Distinguish program participants and separate organizations. A landlord, contractor, or co-located practice may need its own notice or route.

Accessibility is part of the site test

Check height, lighting, print size, language, screen-reader or QR alternative, mobility access, and availability of paper or electronic copies. A digital link can supplement the posting while the physical requirement still needs its own assessment.

Verify that the full notice is readable or clearly available, current, and not obscured by seasonal signage, construction, furniture, glare, or cleaning. Provide language and accessible copies through a route that does not force a person to announce the request publicly. QR and short links should be neutral, current, accessible, and usable without unnecessary login or tracking.

Maintain take-away copies in an ordinary, privacy-preserving location with restock thresholds. Inspect print version, language, accessibility instructions, and stock. A display behind staff may be prominent yet make private access impractical.

Govern changes and findings

Trigger review after opening, relocation, renovation, new service line, branding, participant change, notice revision, construction, kiosk change, or accessibility update. Reconcile facilities, licensing, website, scheduling, and program records to find sites missing from the register.

Classify findings as wrong version, hidden, inaccessible, privacy exposing, empty stock, broken electronic route, ambiguous entity, or another factual state. Assign correction owner, due date, interim protection, completion evidence, and independent follow-up. Preserve photographs carefully so they do not capture people, appointments, rosters, or incidental patient information.

Keep posting distinct from individual delivery

Physical display and take-away availability support public notice access. They do not automatically prove admission communication, first-service provision, emergency follow-up, email fallback, or response to a copy request. Track those outcomes in their own workflows while using one approved notice source.

Example across sites

A program reviews nine physical sites. Seven pass readability and privacy tests; one has a hidden notice and one places it beside a named SUD roster. Site readiness is 7 of 9 locations.

The program relocates the hidden notice and removes the roster exposure, then assesses who could view the roster and routes incident review as needed. It retests each site during ordinary hours and records corrected placement without photographing patients. Final readiness becomes 9 of 9.

Site-posting checklist

• Inventory every physical, shared, mobile, and temporary service site.
• Walk all visitor routes and evaluate disclosure through placement.
• Confirm current version, readability, language, and accessibility.
• Offer privacy-preserving take-away and electronic copy routes.
• Keep stock, links, and placement current through change control.
• Record findings, interim protection, correction, and follow-up.
• Measure site posting separately from patient-level delivery.

Owner controls

The 2024 final rule explains the updated notice context. Use a site inventory, placement standard, privacy walk-through, accessibility check, current-version control, photograph, copy stock, revision trigger, and quarterly review.

Monitor sites current, privacy tests passed, versions aligned, stock available, accessibility defects, broken links, overdue inspections, and unresolved findings. Audit from the site register into actual placement and from scheduled physical services back to an inspected location. Retest after every material site or notice change.

Sample at different operating times and stock levels. Opening-hour, weekend, and temporary-space checks can reveal locked copy cabinets, absent interpreters, moved displays, or a queue configuration that daytime managers never see. Reconcile the number of sites sent revised materials with confirmations that old stock was removed and the new display passed a privacy walk-through.