Notice of Privacy Practices Policy

Transformational Life Consulting Medical

Notice of Privacy Practices Related to Your Protected Health Information (“PHI”)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Transformational Life Consulting (“TLCM”) is a rare and unique telehealth company, offering a triple Board-certified expert physician in allergy, immunology and lifestyle medicine. TLCM is committed to protecting the confidentiality of your health information and other personal health information that we collect, create or disclose while providing telehealth services to you.

We are required by federal law to maintain the privacy of your individually identifiable health information (known as "Protected Health Information" or "PHI") and to provide you with notice of our legal duties and privacy practices with respect to your PHI. This protection extends to any PHI whether in oral, written or electronic format. TLCM is required by law to abide by the terms of this Notice of Privacy Practices Related to PHI (this "Notice") currently in effect. Your other health care provider(s) may have different policies regarding the use and disclosure of your PHI created by and maintained by them. 

TLCM is committed to obtaining, maintaining, using and disclosing PHI in a manner that protects patient privacy in compliance with all applicable local, state and federal laws and regulations. We strongly urge you to read this Notice carefully and thoroughly so that you will understand both our commitment to protecting the privacy of your PHI and how you can participate in the protection of this information.

Your PHI at TLCM

TLCM collects your PHI to the extent necessary to provide services and to obtain payment for these services. This PHI may include your name, address, telephone number, social security number, date of birth, medical history, tests ordered, diagnosis, provider identification, financial responsibility, communication we have with you about your health, etc.  We will let you know promptly if a breach occurs that compromises the privacy or security of your information.

How TLCM May Use and Disclose Your Protected Health Information

The following categories detail the various ways in which we may use or disclose your PHI. While we cannot list every possible use or disclosure, all of the ways we use or disclose your PHI will fall into one of the following categories.

Treatment: We need to use your PHI to provide your medical care, and we disclose PHI to our employees and others who are involved in providing the medical care you need. As a telehealth provider, we use your PHI to assess and treat your health condition and we disclose your PHI to physicians or other authorized health care professionals (e.g., nurses, laboratories, imaging centers, etc.) to perform test and report back results. 

Payment: While we don’t currently bill or seek reimbursement from 3rd party insurance companies. TLCM is a cash-pay practice. If you would like to submit a superbill to your insurance provider for reimbursement, we will provide one to you, so that you may do so. 

Health Care Operations: We may need to use and disclose your PHI as necessary, and as permitted by law, for health care operations. TLCM may use or disclose your PHI in the course of activities required to support our health care operations, such as for quality improvement, compliance, staff training, or other practice administration initiatives. This information will be used in an effort to continually improve the quality and effectiveness of the health care services that we provide. We may also disclose your PHI to other health care providers or payors for their health care operations, but only if they already have a relationship with you or us and the purpose is for quality assurance activities, peer review activities, detecting fraud, or for other legitimate purposes. 

Disclosures to Business Associates: We may also disclose your PHI with our "business associates," such as our electronic health record vendor, that performs administrative services for us. We have a written contract with each of these business associates that contains terms requiring them to protect the confidentiality of your PHI. Although federal law does not protect PHI which is disclosed to someone other than another healthcare provider. 

Persons Involved in Your Care: We may disclose your PHI to individuals, such as family members, relatives, personal friends or others who are involved with your care or who help pay for your care. If you are able and available to agree or object, we will give you the opportunity to object prior to making these disclosures, although we may disclose this PHI in a disaster even over your objection if we believe it is necessary to respond to the emergency circumstances. If you are unable or unavailable to agree or object, our health care professionals will use their best judgment in communication with your family and others. To the extent permitted under federal and state law, we may disclose PHI of minors to their parents or legal guardians.  

Other uses and disclosures: We are permitted or in some cases required by law to make certain other uses and disclosures of your PHI without your consent or authorization. Subject to conditions specified by law, we may release your PHI:

● for any purpose required by law;

● for public health activities, such as required reporting of disease, injury, and birth and death, and for required public health investigation;

● to certain governmental agencies if we suspect child abuse or neglect; we may also release your PHI to certain governmental agencies if we believe you to be a victim of abuse, neglect, or domestic violence;

● to entities regulated by the Food and Drug Administration if necessary to report adverse events, product defects, or to participate in product recalls;

● to your employer when we have provided health care to you at the request of your employer for purposes related to occupational health and safety (in most cases you will receive notice that information is disclosed to your employer);

● if required by law to a government oversight agency conducting audits, investigations, inspections and related oversight functions; in emergency circumstances, such as to prevent a serious and imminent threat to a person or the public;

● if required to do so by a court or administrative order, subpoena or discovery request (in most cases you will have notice of such release);

● to law enforcement officials to identify or locate suspects, fugitives or witnesses, or victims of crime, or for other allowable law enforcement purposes;

● to coroners or medical examiners for the purpose of identifying a deceased person, determining cause of death or another purpose authorized by law and to funeral directors as necessary to carry out their duties with respect to the deceased to the extent consistent with applicable law;

● if necessary to arrange an organ or tissue donation from you or a transplant for you;

● if you are a member of the military for activities set out by certain military command authorities required by armed forces services; 

● if necessary for national security, intelligence, or protective services activities; 

● for purposes related to your workers' compensation benefits;

● to researchers conducting research with respect to which your written authorization is not required as approved by an Institutional Review Board or privacy board, in compliance with governing law; and

● in the event TLCM is sold or merged with another organization, your PHI will become the property of the new owner.

Sensitive Categories of Health Information 

Federal and state laws provide additional confidentiality protections for certain categories of health information beyond what HIPAA requires. When your records include any of the following, additional authorization may be required before we can share this information, even for purposes HIPAA would otherwise permit:

● Substance use disorder diagnosis, treatment, or referral, protected under 42 CFR Part 2.

● Mental health and behavioral health treatment records.

● HIV/AIDS-related testing and treatment information.

● Genetic testing and genetic information, protected under the Genetic Information Nondiscrimination Act (GINA).

● Reproductive health care, protected under the 2024 HIPAA Reproductive Health Care Privacy Final Rule.

These protections apply whether the information was created by TLCM or received from an external provider. Please let us know if any of these categories apply so we can ensure appropriate handling. 

Authorization Required for Other Uses

TLCM must receive your written authorization prior to disclosing your PHI in any manner that is not set forth and described above. We will not sell your PHI.  If we choose to use and disclose PHI for marketing purposes, your authorization is specifically required.  If you would like to authorize us to disclose your PHI in a manner that is not set forth above, please provide a written authorization to our HIPAA Privacy Officer at the contact information below. Such written authorization must include the following information: name, address, telephone number and patient identification number or Social Security number. Please also note that there is always a potential for redisclosure by a recipient you authorize us to disclose your information to, unless they are separately bound by HIPAA to protect your information.

Your Rights Concerning PHI

You have certain rights relating to your PHI that we maintain and you can exercise these rights by making a written request to our HIPAA Privacy Officer at the contact information below. Subject to certain exceptions under applicable law, your rights to your PHI are as follows: 

Access: You or your designated representative have the right to access, review and/or obtain copies of your current PHI; provided, that, either you or your designated representative has delivered a written request to TLCM, unless access is otherwise prohibited including, but not limited to, instances in which state law is more restrictive than federal law. Furthermore, we may restrict your access to information we compile in reasonable anticipation of, or use in, civil, criminal or administrative actions or proceedings.

You may make requests to review or obtain copies of your PHI by contacting our HIPAA Privacy Officer in writing at the contact information below. TLCM may charge a reasonable fee for copies of your PHI. Under certain circumstances, should we deny your request, you have the right to ask for the denial to be reviewed by a licensed health care professional designated by TLCM. 

Amendments: You have a right to request that PHI that we maintain about you be amended or corrected. All amendment requests, in order to be considered by us, must be submitted to our HIPAA Privacy Officer, in writing, signed by you or your designated representative, and must state the reasons for the amendment/correction request. If we find the information is incomplete or incorrect, we may amend your PHI in accordance with our policy, but original information will not be removed. We will also make reasonable efforts to inform and provide approved amendments to those who possess your PHI and need to be informed of the amendment, including our business associates.

We are allowed to deny the request for various reasons, including if TLCM did not create the information for which an amendment is required or if we believe the current information is accurate and complete. If we deny your amendment request, we will inform you in writing of this denial and explain the process involved to exercise your right to submit a written statement of disagreement.  You have a right to request that PHI that we maintain about you be amended or corrected. All amendment requests, in order to be considered by us, must be submitted to our HIPAA Privacy Officer, in writing, signed by you or your designated representative, and must state the reasons for the amendment/correction request. If we find the information is incomplete or incorrect, we may amend your PHI in accordance with our policy, but original information will not be removed. We will also make reasonable efforts to inform and provide approved amendments to those who possess your PHI and need to be informed of the amendment, including our business associates. We are allowed to deny the request for various reasons, including if TLCM did not create the information for which an amendment is required or if we believe the current information is accurate and complete. If we deny your amendment request, we will inform you in writing of this denial and explain the process involved to exercise your right to submit a written statement of disagreement. 

Accounting: You have the right to receive an accounting of certain disclosures made by us or our business associates of your PHI. This accounting will include only those disclosures made in the six years prior to the date on which the accounting is requested. This accounting will not include any disclosures to you or your authorized representatives, disclosures related to treatment, payment or health care operations, disclosures authorized by you, and certain other excluded disclosures. Requests must be made in writing and signed by you or your designated representative. The first accounting in any 12 month period shall be without charge, but we may assess a reasonable cost based-fee in connection with additional requests by you within the same 12 month period.  

Restrictions: You have the right to request restrictions on certain of our uses and disclosures of your PHI for treatment, payment, or health care operations. For example, you may request that we do not share your PHI with a certain family member. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate. We retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event we have terminated an agreed-to restriction, we will notify you of such termination.  

Confidential Communications: You have the right to request that we send communications of your PHI by alternative means or at alternative locations than our usual procedure. For example, you may request that we direct all correspondence to your attention at a family member’s address, that we contact you at work rather than home or that we contact you by mail instead of telephone. You must make your request in writing and we will make an effort to accommodate reasonable requests.

Revocation: You may revoke this written authorization at any time by notifying our HIPAA Privacy Officer in writing. Such revocation shall contain the same information as is required to be provided in the written authorization and will be effective and applicable to uses and disclosures from the time it is received. In the alternative, you may contact our HIPAA Privacy Officer to request a written authorization form or revocation of written authorization form. 

Right to Notice: You have the right to request a paper and/or electronic copy of this Notice at any time by contacting our HIPAA Privacy Officer.  How to Exercise Your Rights or Ask Questions: To exercise your rights or for any questions regarding this Notice, please contact our HIPAA Privacy Officer at: 

Phone: (602) 905-5155.

Email: [email protected]

Please include sufficient information for us to identify all of your records such as your name, address, and a telephone number where we can contact you. TLCM will consider your request and provide you a response within a reasonable timeframe. 

Complaints: If you believe your privacy rights have been violated, please let us know immediately by contacting our HIPAA Privacy Officer at [email protected]. Please make sure to include sufficient information for us to identify you and a brief description of the circumstances surrounding the violation. 

You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services by contacting the following:

The U.S. Department of Health and Human Services

200 Independence Avenue, S.W. 

Washington, D.C. 20201

Telephone: 202-619-0257 

Toll Free: 1-877-696-6775 

TLCM will not retaliate against any individual for filing a complaint. 

Changes to this Notice of Privacy Practices Related to PHI: TLCM reserves the right to amend this Notice at any time to reflect changes in our privacy practices. Any such changes will be applicable to and effective for all PHI that we maintain including PHI we created or received prior to the effective date of such amendment as TLCM is required to abide by the privacy practices currently in effect. TLCM will post any Privacy Policy changes to its website. Please review our website periodically to ensure you are aware of any such updates.  

This Notice is effective as of August 5, 2026.