‘DEPARTMENT OF HEALTH, U Nw STATE OF FLORIDA DEPARTMENT OF HEALTH Petitioner, 00- ot CF 2) vs. CASE NO.: 98-16978 GALE COLLINS ALLISON, Pe Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referréd to'as “Petitioner,” files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling against GALE COLLINS ALLISON, hereinafter referred toas “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)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality UY Nw 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 0004874. 3. Respondent’s last known address is 14706 Dartmouth Lane, Tampa, Florida, 33624. 4. Respondent was employed as a Social Worker with the Child Abuse Council on or about February 12,1998 through on or about March, 1998, about the time of the alleged incident. 5. While employed as a Social Worker at this facility, she began working with J.A., a 13 year-old female, on or about February 12, 1998. 6. In or around March 1998, Respondent became aware of a case of sexual abuse of J.A. by A.A., a 24 year-old male who lived in the same home as J.A., her three (3) siblings, and their mother. 7. J.A. was reportedly pregnant by A.A. 8. Respondent failed to report this case sexual abuse. 9. This case of sexual abuse was not reported until after J.A, whose pregnancy was considered high-risk, had delivered her baby, C.A. at Tampa General Hospital on or about March 4, 1998. UY YU 10. Respondent again failed to report this case of sexual abuse at this time. 11. The sexual abuse was finally reported by the Tampa General Hospital staff on or about May 5, 1998, after the infant C.A. had returned to Tampa General Hospital with an upper respiratory infection. 12. This sexual abuse case was reported to the Hillsborough County Sheriff's Office by Tampa General Hospital staff on or about May 5, 1998. COUNT ONE 13. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through twelve (12). 14. Based on the foregoing, Respondent has violated Section 491.009(2)(h), Florida Statutes, by violating Section 415.504, Florida Statutes, for failing to perform any statutory or legal obligation placed upon a person licensed, registered, or certified under this chapter. YU YU 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 relief which the Board deems appropriate. Zi) SIGNED this |4A day of fe 74999. Robert G- Brooks, M.D. Secretary, Department of Health DEPARTMENT OF HEALTH DEPUTY CLERK cLenK Webi RM pate_1/ 20/82 BY: Nancy M. Snurkowski Chief Attorney General Counsel’s Office Practitioner Regulation-Legal COUNSEL FOR PETITIONER Shannon Fleming .Ah=” Senior Attorney Florida Bar Number 0166677 Agency for Health Care Administration Practitioner Regulation-Legal P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-9694 SF/cb 10/13/99

Docket for Case No: 00-000852