A private clinic is generally a public accommodation under Title III. A public provider is under Title II. Federal funding, which pays for a large share of behavioral health, brings Section 504. HIPAA applies to the record no matter which model produced it. None of these turn off because the hour was a video call or the homework was an app.
What changes is the modification. Weekly care can often absorb a reschedule. An intensive program that treats missed groups as noncompliance is punishing the executive dysfunction it enrolled. A residential rule about noise, movement, or eye contact is a policy modification question, not a housekeeping preference. A portal that is the only way to confirm a session is part of the service.
AI inside the model — a note aide, a reminder, a coaching tool, a chatbot on the intake page — is the same split as everywhere else on this site. It can be a cognitive accommodation. It can also be a new condition of receiving care. The patient has to be able to decline the parts that are not the treatment and still receive the treatment.