HIPAA Notice of Privacy Practices

Effective date: June 30, 2026

Our Commitment

Recovery Club America LLC, doing business as MindClub America, together with its subsidiaries and affiliated programs (including InHome Recovery) ("we," "us," or "our") is committed to protecting the privacy of your Protected Health Information ("PHI") – individually identifiable health information we create or receive in connection with providing or coordinating your care. We are required by law to maintain the privacy of your PHI, to provide you with this Notice of our legal duties and privacy practices, and to follow the terms of the Notice currently in effect.

How We May Use and Disclose Your PHI

We may use and disclose your PHI without your authorization for the following purposes:

• Treatment. To provide, coordinate, and manage your care – for example, sharing information among the providers and staff involved in your care, and synchronizing records with the electronic health record system your provider uses.
• Payment. To bill and obtain payment for the services you receive and to verify coverage. This may include billing your insurance or health plan, or charging the payment card on file.
• Health Care Operations. For quality improvement, training, care coordination, business management, and similar operational activities, including maintaining access and audit logs that record who accessed clinical records.

We may also use or disclose PHI to:

• Remind you of appointments and provide information about treatment alternatives or health-related services, consistent with your communication preferences;
• Persons involved in your care, such as a family member or guardian, to the extent permitted by law and, for minors, as governed by applicable state law; and
• Business associates who perform services on our behalf, under a written agreement requiring them to safeguard your PHI.

Uses and Disclosures That Require Your Written Authorization

The following uses and disclosures will be made only with your written authorization, which you may revoke at any time (except to the extent we have already acted in reliance on it):

• Most uses and disclosures of psychotherapy notes, where applicable;
• Uses and disclosures for marketing purposes;
• Disclosures that constitute a sale of PHI; and
• Other uses and disclosures not described in this Notice.

Substance Use Disorder Records (42 CFR Part 2)

Some of the care we provide is substance use disorder (SUD) treatment, including medication-assisted treatment and in-home drug & alcohol treatment. Information that would identify you as having a substance use disorder, created in connection with that treatment, is protected not only by HIPAA but also by federal law – 42 U.S.C. § 290dd-2 and 42 CFR Part 2.

Generally, we may not disclose information identifying you as someone who has a substance use disorder or is receiving SUD treatment from us unless:

• you give written consent that meets Part 2's specific requirements;
• the disclosure is authorized by an appropriate court order; or
• the disclosure is made to medical personnel in a medical emergency, to qualified personnel for an audit or program evaluation, or as otherwise permitted by 42 CFR Part 2.

Federal law and regulations do not protect information about a crime committed against our staff or on our premises (or any threat to commit such a crime), or reports of suspected child abuse or neglect, from being reported to appropriate authorities.

Prohibition on re-disclosure. When we disclose your Part 2-protected information with your consent, that disclosure is accompanied by a written notice that the information may not be re-disclosed by the recipient unless further disclosure is permitted by 42 CFR Part 2.

You may revoke a Part 2 consent at any time, except to the extent we have already acted in reliance on it.

Special Situations

We may use or disclose your PHI, without your authorization, when permitted or required by law, including:

• When required by law;
• For public health activities;
• To report suspected abuse, neglect, or domestic violence;
• For health oversight activities;
• In response to judicial or administrative proceedings (such as a subpoena or court order);
• For certain law-enforcement purposes;
• To avert a serious and imminent threat to health or safety;
• For workers' compensation as authorized by law; and
• For specialized functions such as military, national security, or correctional purposes, where applicable.

Your Rights Regarding Your PHI

You have the right to:

• Inspect and obtain a copy of your PHI that we maintain, in the form and format you request where readily producible, subject to limited exceptions;
• Request an amendment of your PHI if you believe it is incorrect or incomplete;
• Request an accounting of certain disclosures of your PHI;
• Request restrictions on certain uses and disclosures of your PHI;
• Request confidential communications – to receive communications by alternative means or at an alternative location;
• Receive a paper copy of this Notice upon request, even if you agreed to receive it electronically; and
• Be notified of a breach of your unsecured PHI.

To exercise any of these rights, contact us using the information below. We honor these requests through a manual process and within the timeframes required by law. Some requests must be made in writing, and certain rights are subject to limitations under the law.

Our Duties

We are required to maintain the privacy of your PHI, provide this Notice, abide by its terms while in effect, and notify affected individuals following a breach of unsecured PHI. We maintain administrative, technical, and physical safeguards – including encryption of PHI in transit and at rest – designed to protect your information. We reserve the right to change this Notice and to make the revised Notice effective for PHI we already have as well as PHI we receive in the future. We will post the current Notice and provide it as required by law.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with us using the contact information below, or with the U.S. Department of Health and Human Services, Office for Civil Rights. We will not retaliate against you for filing a complaint.

Contact

Attn: Kathy Richardson, CAO & Vice President – Privacy Official
Recovery Club America LLC d/b/a MindClub America
106 Mission Ct, Suite 201a
Franklin, TN 37067
Phone: (833) 833-9655
Email: [email protected]