Ne U STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, an pha | . Petitioner, OO -O?PEO v. CASE NO.: 96-04000 DOMINICA J. PARROTT a/k/a DOMINICA PARROTT BRODSKY, Respondent. / ee ADMINISTRATIVE COMPLAINT DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner”, files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling against DOMINICA J. PARROTT, hereinafter referred to as “Respondent”, and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Clinical Social Work pursuant to Section 20.43, Florida Statutes, Chapter 455, Florida Statutes, and Chapter’ 491, Florida Statutes. Pursuant to the authority of Section 20.43(3)(f), Petitioner has contracted with the Agency for Health Care Administration to provide consumér complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards as appropriate, including the issuance of emergency orders of suspension or restriction. 2. Respondent is, and has been at all times material hereto, a licensed Clinical Social Worker in the state of Florida, having been issued license number SW 0003307. 3. Respondent’s last known address is 3317 North Shore Circle, Tallahassee, Florida 32312. YW Nw) 4, Respondent was hired by Florida Therapy Services, Inc. (F.T.S.) in June 1995 to provide counseling and therapy services for patients. Le 5. From about June 1, 1995 to about August 4, 1995, Respondent (as an F.T.S. employee) signed for therapy sessions in the progress notes of various patients’ charts, acting as a supervisor of Mental Health Technicians, when in actuality she was being paid to directly provide therapy services herself. 6. Respondent did not provide therapy services for the aforementioned sessions she signed off on. 7. Additionally, Respondent signed therapy session patient records for times during which she would have had to have been present at two different facilities at the same time. Those facilities were approximately thirty miles apart. 8. Respondent also failed to obtain written consent from either patients or responsible family members of patients, for the group sessions she allegedly participated in with patients. COUNT I 9. Based on the foregoing, Respondent has violated Section 491.009(2)(i), Florida Statutes, by willfully making or filing a false report or record. Such report or record includes only a report or record which requires the signature of a person licensed, registered, or certified under this chapter. COUNT i 10. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through eight (8) as if fully stated herein. VY VA 11. Based on the foregoing, Respondent has violated Section 491.009(2)(s), Florida Statutes, by failing to meet the minimum standards of performance in - *” , : professional activities when measured against generally prevailing peer performance, including the undertaking of activities for which the licensee is not qualified by training or experience. WHEREFORE, Petitioner respectfully requests the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling to enter an order imposing one or more of the following penalties: revocation or suspension of Respondent's license, restriction of Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent’s license on probation for a period of time and subject to terms and/or conditions, and/or any other =~ relief which the Board deems appropriate. Signed this [OR day « \egt@inow 1998 Robert G. Brooks, M. D. Secretary, Department of Health \ By: Nancy M. Snurkowski Chief Attorney General Counsel’s Office- MQA Allied Health COUNSEL FOR PETITIONER: Susan Branson F i Lf D Senior Attorney REY OF LIE Florida Bar Number 0648809 DEPARTMENT OF HEALTH Agency for Health Care Administration P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 487-9694 SB/th

Docket for Case No: 00-000850