Privacy Policy

Effective Date: March 26, 2026

Functional Life Achievement, Inc. ("FLA," "we," "our," or "us") is a 501(c)(3) non-profit organization providing Early Intervention Program (EIP) services in New York City. We are committed to protecting the privacy and confidentiality of the personal information and protected health information (PHI) of the children and families we serve.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Health Insurance Portability and Accountability Act (HIPAA), the Family Educational Rights and Privacy Act (FERPA), New York State Public Health Law, and the regulations of the New York State Department of Health (NYSDOH) Bureau of Early Intervention.

1. Information We Collect

In the course of providing Early Intervention services, we may collect the following types of information:

Personal Information

• Parent/guardian name, address, phone number, and email address
• Child's name, date of birth, and gender
• Emergency contact information
• Insurance and Medicaid information
• Primary language spoken in the home

Protected Health Information (PHI)

• Medical history and developmental records
• Multidisciplinary evaluation reports
• Individualized Family Service Plans (IFSPs)
• Therapy session notes and progress reports
• Psychological, speech, occupational, and physical therapy assessments
• Applied Behavior Analysis (ABA) treatment records
• Service coordination records

Website Information

• Information submitted through our contact and referral forms
• Browser type, IP address, and general usage data collected via standard web technologies

2. How We Use Your Information

We use the information we collect for the following purposes:

• Treatment: To provide evaluations, therapy, and early intervention services to your child as authorized under your child's IFSP
• Service Coordination: To coordinate services among therapists, evaluators, and the NYC Early Intervention Official Designee (EIOD)
• Payment: To process claims with the New York State Department of Health, Medicaid, and applicable insurance providers
• Operations: To manage scheduling, quality assurance, staff training, and compliance with EIP regulations
• Communication: To respond to inquiries, send appointment reminders, and provide information about our services
• Legal Compliance: To meet our obligations under federal, state, and local laws and regulations

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share information only as follows:

• With the NYC Bureau of Early Intervention: As required for referral processing, IFSP development, service authorization, and compliance reporting under the NYS Early Intervention Program
• With Authorized Service Providers: Therapists, evaluators, and service coordinators directly involved in your child's care
• With Government Agencies: The NYSDOH, NYC DOHMH, and Medicaid for billing, auditing, and regulatory compliance
• With Your Consent: To other healthcare providers, schools, or agencies when you provide written authorization
• As Required by Law: In response to a court order, subpoena, or mandatory reporting obligations (e.g., suspected child abuse or neglect)

4. Your Rights

Under HIPAA and New York State law, you have the right to:

• Access: Request and obtain copies of your child's records
• Amendment: Request corrections to inaccurate information in your child's records
• Restriction: Request restrictions on certain uses and disclosures of your child's information
• Confidential Communication: Request that we communicate with you by a specific method or at a specific location
• Accounting of Disclosures: Request a list of certain disclosures we have made of your child's health information
• Complaint: File a complaint with us or the U.S. Department of Health and Human Services if you believe your privacy rights have been violated

To exercise any of these rights, please contact us using the information provided below.

5. Data Security

We implement appropriate administrative, technical, and physical safeguards to protect your information, including:

• Secure electronic health record systems with access controls
• Encrypted data transmission for electronic communications
• Locked storage for paper records
• Staff training on HIPAA compliance and confidentiality
• Business Associate Agreements with all third-party vendors who handle PHI

6. Record Retention

We retain your child's Early Intervention records in accordance with New York State regulations. Records are maintained for a minimum of six (6) years after the last date of service, or until the child reaches the age of 21, whichever is later. Records are securely destroyed after the retention period expires.

7. Children's Privacy

Our services are directed toward children under 3 years of age and their families. We collect information about children only as necessary to provide Early Intervention services and in compliance with applicable laws. All decisions regarding a child's information are made by the parent or legal guardian.

8. Website and Cookies

Our website may use cookies and similar technologies to improve your browsing experience. These technologies collect general usage data and do not collect protected health information. You may disable cookies through your browser settings, though some website features may not function properly.

9. Third-Party Links

Our website may contain links to third-party websites or services (such as JotForm for referral submissions). We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before submitting any personal information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Functional Life Achievement, Inc.
236 2nd Ave, New York, NY 10003
Phone: (212) 683-8905
Email: info@flanyc.com

You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights at hhs.gov/ocr.