ww) - Vv) Fin if tee STATE OF FLORIDA LB Of § DEPARTMENT OF HEALTH °0 gy 7 p _ BOARD OF MASSAGE THERAPY . M 3:3 DEPARTMENT OF HEALTH, PETITIONER, j 0-7 (35 “VS. i CASE NUMBER: 99-00355 VICTORIA D. BILAS, RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Massage Therapy against VICTORIA D. BILAS, hereinafter referred to as “Respondent,” and alleges: , 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of massage pursuant to Section 20.43, Florida Statutes; Chapter “455, Florida Statutes; and Chapter 480, Florida Statutes. Pursuant to the authority of ‘Section 20.43 (3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration’ hereinafter “Agency,” to provide consumer complaint, investigative, and prosecutorial services ‘required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, at all times material hereto a duly licensed massage therapist, having 5 been issued license number MA 0019300. vee eereg: cm ogmmme g rt 3. Respondent's last known address is 26368 Notre Dame Blvd., Punta ~~ Gorda, Florida, 33955. 4. On or about January 14, 1999, the Respondent placed an advertisement in the Charlotte Sun Herald advertising massage therapy, hypnotism and homeopathy. 5. The Respondent is not qualified to practice hypnotism or homeopathy. 6. In addition to the advertisement that she placed, the Respondent stated that she receives referrals for her services by word of mouth. COUNT I 7. Petitioner repeats and re-alleges paragraphs 1 through 6 above. 8. . Based on the foregoing, Respondent placed an advertisement for services beyond the scope “ofher license and is subject to discipline pursuant to Section 480.046 (1) @), Florida Statutes, for practicing beyond the scope permitted by law and performing professional responsibilities which the licensee knows or has reason to know that she is not competent to perform. vy WHEREFORE, Petitioner respectfully requests the Board of Massage Therapy enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, assess costs of investigation and prosecution and/or any other relief that the Board deems appropriate. SIGNED this / HO doy of | Yi 46 | yy , 1999. _ Robert G. Brooks, M.D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration _£4COUNSEL FOR PETITIONER: Gary L. Asbell, Senior Attorney Agency for Health Care Administration : a Practitioner Regulation - Legal FE iLED 4 P.O. Box 14229 DEPARTMENT OF HEAL Tallahassee, FL 32317-4229 EPUrY CLEe (850) 414-1981 cuenk ppt phomaed, CLA/fim . vane [OB

Docket for Case No: 00-000133