On June 25, 2025, Connecticut Governor Ned Lamont signed into law Public Act No. 25-97, “An Act Concerning Various Revisions to the Public Health Statutes” (the Act). The Act includes a wide range of provisions affecting patient confidentiality, hospital and provider licensure, scope of practice, civil penalties, and Connecticut’s statewide health information exchange. Significant provisions of the Act are summarized below.

Changes Affecting Psychologist Patient Confidentiality Rules

Effective October 1, 2025, Connecticut patient confidentiality rules for psychologists will align with those rules in place for psychiatric mental health providers. The Act repeals the previous psychologist-specific confidentiality and privileged communication rules and amends the current rules for psychiatric mental health providers to include psychologists. Under the new rules established by the Act, psychologists may disclose communications and records without a patient’s consent in specific circumstances such as: 1) when such communications and records are necessary for the diagnosis or treatment of the patient and the patient is informed; 2) when the psychologist determines there is a substantial risk of imminent physical injury or to facilitate admission to a mental health facility; 3) to collect fees for services or to contract with the Department of Mental Health and Addiction Services, but such disclosure is limited; and 4) for the purposes of judicial proceedings.

Changes Affecting Providers’ and Health Systems’ Operations

Effective October 1, 2025, health systems and providers—including physicians, hospitals (both for-profit and non-profit), hospital-based facilities, freestanding emergency departments, urgent care centers, and any entities affiliated with a hospital or a hospital’s parent organization—will be prohibited from requiring patients to provide bank account information, credit or debit card numbers, or any other form of electronic payment method to keep on file as a prerequisite to providing services. Violation of this new prohibition constitutes an unfair trade practice under the Connecticut Unfair Trade Practices Act (CUTPA). Under CUTPA, courts can award damages and impose civil penalties of up to $5,000 for willful violations. This prohibition does not affect a patient’s obligation to pay for services or prohibit a provider from otherwise requesting or storing payment information.

The Act makes several minor changes to the timing of reports that health care institutions with 50 or more employees must make to the Department of Public Health (DPH), with all changes effective October 1, 2025. Currently, hospitals must report to DPH every six months regarding their ongoing compliance with at least 80% of nurse staffing assignments in their nursing plans. The Act shortens the time period in which hospitals must make this report from two months to within 14 days of the end of the most recent six-month period. Additionally, the Act affects when health care employers must report workplace violence incidents. Under existing law, health care employers must report workplace violence incidents annually to DPH; health care employers can now make this report by February 1 each year instead of January 1. For this reporting requirement, a “health care employer” is any institution with 50 or more full- or part-time employees. This includes, but is not limited to, hospitals, hospice facilities, home health agencies, outpatient clinics, clinical laboratories, facilities for the care or treatment of mental illness or substance use disorders, licensed residential facilities for persons with intellectual disabilities, and community health centers.

The Act increases the maximum civil penalty that the DPH or its licensing boards or commissions may impose against an individual health care provider to $25,000, up from $10,000. The Act does not create any new enforcement procedures for individual providers beyond increasing the maximum penalty cap. For details on updated DPH enforcement measures for DPH-licensed institutions, see our other blog post detailing these updates.

Changes Affecting Licensure and Scope of Practice

The Act removes one requirement for hospitals licensed by the DPH, effective June 25, 2025: such hospitals are no longer required to obtain Department of Children and Families (DCF) licensure to provide either inpatient or outpatient mental health services as part of DCF’s outpatient psychiatric clinic program.

Under the Act, starting July 1, 2025, MRI and radiologic technicians are now able to perform certain oxygen-related patient care activities in hospitals, including: 1) connecting or disconnecting oxygen supply; 2) transporting a portable oxygen source; 3) connecting, disconnecting, or adjusting the oxygen delivery system; and 4) adjusting the oxygen flow rate pursuant to a medical order. Existing law includes these activities within the scope of practice for other licensed health care providers, as well as certified ultrasound, nuclear medicine, and polysomnographic technologists.

Beginning January 1, 2026, Connecticut-licensed physical therapists must complete training on ethics and jurisprudence every two years as part of their existing continuing education requirements.

Finally, the Act expands emergency medical services (EMS) personnel’s authority by permitting EMS personnel to administer epinephrine via any FDA-approved method, including nasal spray, effective July 1, 2025.

Changes Affecting the Statewide Health Information Exchange

The Act includes certain provisions affecting the rollout and scope of Connecticut’s Statewide Health Information Exchange, known as “Connie,” which launched in 2021. Under existing law, Connecticut health care providers (with limited exceptions) must connect to Connie to facilitate ease and simplicity of medical records sharing within the state. Beginning immediately, the Act adds a new directive for the Office of Health Strategy (OHS) to conduct a study into the cost and impact of creating a more granular opt-out system for patients, which would allow patients to opt out of sharing specific types of patient health information and medical records with specific providers. Most health care providers in Connecticut were required to begin connecting with Connie in 2023, but existing law does not require full participation in Connie until OHS promulgates policies and procedures related to such participation. OHS has not yet implemented these policies and procedures and OHS had originally targeted mid-2025 as a publication date, but the study results are not required under the Act until September 30, 2026, which may further delay publication.

Starting October 1, 2025, the Act also includes Connie-related provisions aimed at protecting patient data and increasing transparency. Under the Act, if Connie experiences a breach, ransomware attack, or hacking event, Connie must notify all patients affected by the breach and perform necessary mitigation on behalf of affected providers. The Act also prohibits Connie from disclosing protected health information (as defined under the Health Insurance Portability and Accountability Act) in response to a subpoena unless the disclosure is fully compliant with applicable state and federal law.

This post was co-authored with Ivy Miller, legal intern at Robinson+Cole. Ivy is not admitted to practice law.