Notice of Privacy and Practices

G.R.O.W. ABA – Notice of Privacy Practices

Guided Reinforcement for Ongoing Wellness LLC dba G.R.O.W. ABA Effective Date: September 30, 2026

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT A CLIENT MAY BE USED AND DISCLOSED AND HOW THE CLIENT AND/OR PARENT OR GUARDIAN CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Our legal duty

Federal and California law require G.R.O.W. ABA ("G.R.O.W.," "we," "us") to protect the privacy of client health information. The law also requires us to give the client and/or the client's parent or guardian (together, "you") this Notice describing our privacy practices, our legal duties, and your rights. We must follow the practices described in the Notice currently in effect.

This Notice takes effect on the date above and stays in effect until we replace it. We may change our privacy practices and this Notice when the law allows, and the changes may apply to all health information we hold, including information created or received before the change. Before a significant change, we will update this Notice, post it on our website and in our clinic, and make it available on request.

You may ask for a copy of this Notice at any time, and we will provide it promptly. To request a copy or learn more, use the contact information at the end of this Notice.

Uses and disclosures of protected health information

"Protected health information" (PHI) is information about the client, including demographic information, that may identify the client and relates to their past, present, or future physical or mental health, or to related services or payment. At G.R.O.W., this includes assessments, treatment plans, session data, progress reports, diagnoses, and insurance information.

We use and disclose PHI for treatment, payment, and health care operations, as follows.

Treatment. We use PHI to provide and coordinate ABA services. For example, your BCBA shares session data with your child's behavior technician, and we may send reports to your child's pediatrician or coordinate goals with a speech or occupational therapist.

Payment. We use and disclose PHI to bill and get paid, including submitting claims, verifying eligibility and coverage, obtaining authorizations, and responding to audits by health plans, Medi-Cal, regional centers, or school districts. We may share PHI with technology partners that help us manage billing.

Health care operations. We use and disclose PHI to run our practice, including quality review, evaluating staff performance, training and supervision, accreditation, credentialing, and licensing. We may share PHI with consultants and technology partners that support these activities, and with another provider that has a relationship with you, for their health care operations as the law allows.

With your authorization. You may give us written authorization to use or disclose PHI for any purpose. You may revoke it in writing at any time; revocation does not affect what we already did in reliance on it. Except as described in this Notice, we will not use or disclose PHI without your written authorization.

Family and others involved in care. We may share PHI with a family member, caregiver, or other person you identify, to the extent needed to help with the client's care or payment. We will give you a chance to object first. If you are not present, or in an emergency, we will use professional judgment about what is in the client's best interest.

Communications about care. We will contact you about schedules, treatment options, and progress through the parent portal, email, phone calls, text messages, and voicemail. We may send PHI to you through secure, encrypted systems, and we may share PHI with technology partners that help us manage these communications. You may ask us to use a different method.

Breach notification. If a breach of unsecured PHI occurs, we will notify you as required by law, by mail or by email if you have given us a current address. In some cases, our business associate may send the notice.

Business associates. We share PHI with vendors that perform services for us, such as our practice management and scheduling system, billing services, and IT support. Each signs a written agreement requiring it to protect PHI.

Public benefit. As the law permits or requires, we may use or disclose PHI:

  • As required by law
  • For public health activities, such as disease reporting
  • To report suspected child abuse or neglect, or abuse of elders or dependent adults, as mandated reporters
  • To health oversight agencies for audits, investigations, and licensing
  • In response to court or administrative orders and other lawful process
  • To law enforcement for limited purposes, such as a valid warrant
  • To avert a serious threat to health or safety
  • To coroners, for workers' compensation, and for specialized government functions, as authorized by law

When we may not use or disclose PHI without your permission

Except as described in this Notice, we will not use or disclose PHI that identifies the client without written authorization. We never do the following unless you give us written permission:

  • Use PHI for marketing
  • Sell PHI
  • Share psychotherapy notes, in most cases
  • Use PHI for research
  • Use photos, video, testimonials, or other identifiable information about the client on our website, social media, or promotional materials

Substance use disorder treatment records

G.R.O.W. does not provide substance use disorder (SUD) treatment. If we receive records from a federally assisted SUD program ("Part 2 records," protected by 42 CFR Part 2):

  • We will not use or disclose them, or testimony about them, in any civil, criminal, administrative, or legislative proceeding against the client without specific written consent, or a court order issued after notice and an opportunity to be heard, together with a subpoena or similar legal mandate.
  • If you give a single consent for treatment, payment, and health care operations, we may use and disclose those records for those purposes as HIPAA allows.
  • We do not conduct fundraising. If that changes, you will have a clear opportunity to opt out before Part 2 records are used for it.

Your rights

For a minor client, a parent or legal guardian generally exercises these rights, except where California law gives the minor control of their own information. Send written requests to our Privacy Officer at the address at the end of this Notice.

Access. You may inspect or get a paper or electronic copy of the client's PHI, with limited exceptions. Requests must be in writing. We may charge a reasonable, cost-based fee for copies.

Amendment. You may ask us in writing to amend PHI you believe is incorrect or incomplete, explaining why. We may deny the request in some cases, but will tell you within 60 days whether we agree.

Accounting of disclosures. You may request a list of certain disclosures we or our business associates made for purposes other than treatment, payment, and health care operations. The request must be in writing and cover no more than the prior six years. One list per 12 months is free.

Restrictions. You may ask us to limit how we use or disclose PHI. We are not required to agree, except when you ask us not to share information with a health plan about a service paid for in full out of pocket. Any agreement must be in writing and signed by our Privacy Officer, and we will honor it except in an emergency.

Confidential communications. You may ask us in writing to contact you by a specific method or at a specific location, such as a different phone number or address. We will agree to reasonable requests.

Paper copy of this Notice. You may request a paper copy at any time, even if you received it electronically.

Personal representative. A legal guardian or person with medical power of attorney may exercise these rights. We will verify their authority first.

Breach notification. You have the right to be notified of a breach of the client's unsecured PHI.

California protections

When California law, including the Confidentiality of Medical Information Act (Civil Code §56 et seq.), gives you more protection than HIPAA, we follow it:

  • Faster access: You may inspect records within 5 working days of a written request and receive copies within 15 days (Health & Safety Code §123110).
  • Addendum: You may add a written statement of up to 250 words per item you believe is incomplete or incorrect, which we will attach to the record.
  • Minors' records: When a minor may legally consent to their own care, the minor controls the related records.
  • Stricter limits: We will not share medical information with an employer, or for marketing, without written authorization.

Changes to this Notice

We may amend this Notice at any time. Until we do, we must follow the Notice currently in effect. An amended Notice will apply to all PHI we hold, whenever it was created or received. The current Notice is always posted in our clinic lobby, available at every appointment, and posted at [growaba.com/notice-of-privacy-practices].

Questions and complaints

Contact our Privacy Officer if you have questions or believe that:

  • We may have violated the client's privacy rights
  • We made an incorrect decision about access to PHI
  • We responded incorrectly to a request to amend or restrict PHI
  • We should communicate with you by a different method or at a different location

G.R.O.W. ABA Attn: Privacy Officer, Ian Angeles, 1342 Coronado Ave., Long Beach, CA 90804 562-766-1199 · [contact@growaba.com]

You may also file a complaint with:

  • U.S. Department of Health and Human Services, Office for Civil Rights: 200 Independence Avenue S.W., Washington, D.C. 20201 · 1-877-696-6775 · www.hhs.gov/ocr/complaints
  • Your health plan: For concerns about insurance coverage or decisions, call the member services number on the back of your insurance card.
  • Behavior Analyst Certification Board (BACB): For concerns about the professional conduct of a BCBA or RBT, visit bacb.com/notice.
  • California Department of Developmental Services: For clients receiving regional center-funded services, visit the DDS consumer rights complaint page. [Keep only if G.R.O.W. is a vendored regional center provider.]

We will not retaliate against you in any way for filing a complaint with us or with any agency.

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