4 ENvision cf 4 STATE OF FLORIDA fms . os i AGENCY FOR HEALTH CARE ADMINISTRATION AGENCY FOR HEALTH CARE ADMINISTRATION, Petitioner, vs. Case No. 95-17902 Marion G. Strong, ia) S76 Respondent . / ADI T I ‘OMPLA 78 The Petitioner, the Agency for Health Care Administration, hereinafter referred to as "Petitioner, " files this Administrative Complaint before the Board of Opticianry against Marion G. Strong, hereinafter referred to as "Respondent," and alleges: 1. Petitioner is the State agency charged with regulating the practice of Opticianry pursuant to Chapters 455 and 484, Florida Statutes, and the rules promulgated thereto. 2. Respondent is, and has been at all times material hereto, a licensed Optician, license number DO 0001237. 3. Respondent 's address of record is 108 West Robertson Street, Brandon, Florida 33511. Y U 4. Respondent is the owner of Strong Vision and Hearing Center and uses the alias of Jill Strong in her business. 5. ‘on ox about July 16, 1994, patient M.K. presented to Strong Vision Center and was examined by Mark L. Klugman, D.O. 6. Dr. Klugman provided patient M.K. with a prescription for corrective lenses. 7. Patient M.K. presented the prescription to Respondent and requested contacted lenses. 8. Patient M.K. was unable to see clearly with the lenses provided in the strength written by Dr. Klugman. 4 9. Respondent provided M.K. with contact lenses which were not in the strength specified in the prescription. 10. %In or around September 1995, M.K. contacted Respondent to obtain a copy of her prescription. Respondent provided M.K. with a card which stated the strength of the contacts dispensed by Respondent. 11. M.K. was unable to obtain contact lenses with the card provided by Respondent. 12. Respondent altered the prescription written by Dr. Klugman and provided M.K. with the altered prescription. Y U 13. On or about January 30, 1995, during an interview with an Agency investigator, Respondent admitted that she provided M.K. with contact lenses from Dr. Klugman‘s prescription for corrective lenses. Further, Respondent admitted that she altered Dr. Klugman’s prescription by writing in the strength of the contacts which she actually dispensed. 14. Based on the foregoing, Respondent has violated Section 484. 013(3), Florida Statutes, by engaging in the diagnosis of the human eyes, attempting to determine the refractive powers of the human eyes, or in any manner, attempting to prescribe for on treat diseases or ailments of human beings. WHEREFORE, Petitioner respectfully requests the Board of Opticianry to enter an Order pursuant to Chapter 484, Florida Statutes and Rule 59U-8.020, Florida Administrative Code, imposing one or more of the following penalties: revocation or suspension . of the Respondent’s license, imposition of an administrative fine not to exceed $1,000 for each count, issuance of a reprimand, placement of the Respondent. on probation for a period of time and subject to such conditions as the Board may specify, and/or any other relief which the Board deems appropriate. VU OY SIGNED this (Wh aay of N rar Y W , 1996. Douglas M. Cook / Director By: . General Counsel's Office-MQA Chief Attorney-Allied Health COUNSEL OR OTHER QUALIFIED REPRESENTATIVE FOR DEPARTMENT: Angela T. Hall, Staff Attorney ‘ Agency for Health Care , Administration a Le ore P.O. Box 14229 steno D Tallahassee, Florida 32317-4229 HEALTH cape OR “ARE ADMI (904) 487-3908 DEPUTY CLengs RATION oes a Cee Sh cin) DOK > PCP: E. Whited & J. Winterling PCP date: July 11, 1996

Docket for Case No: 00-000596