Access to substance use disorder (SUD) treatment is a critical issue for women with HIV. This study examined differences in SUD diagnoses, comorbid psychiatric diagnoses, and predictors of SUD treatment initiation among a racial/ethnically diverse sample of HIV-positive women (N=228) and a demographically similar cohort of HIV-negative women (N=693). Diagnoses and service utilization data were obtained from electronic health records of members of a large integrated healthcare system in Northern California. Overall, HIV-positive women were less likely to initiate SUD treatment. Among HIV-positive women, being diagnosed with an amphetamine use disorder, comorbid depressive disorder, and anxiety disorder was more common among white woman, while cocaine diagnosis was more common among black women. Among HIV-negative women, a diagnosis of alcohol SUD, comorbid depressive disorder, and comorbid anxiety disorder was more common among white women; diagnosis of cannabis SUD and cocaine SUD was more common among black women; and a diagnosis of amphetamine SUD and depressive disorder was more common among Latina women. Multivariable logistic regression models showed that alcohol, cannabis, and opiate diagnoses were predictive of SUD treatment initiation for both cohorts, while amphetamine SUD, comorbid depressive disorder, and being white or Latina were predictive of SUD treatment initiation for HIV-negative, but not HIV-positive women. Findings suggest that clinicians need to be aware of differences in substances of abuse, comorbid psychiatric disorders, and to consider the demographic and social factors that may contribute to differences in SUD treatment initiation among HIV-positive and HIV-negative women.