en li amn A m A ww Ned _ STATEOFFLORIDA __ DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, — PETITIONER, - OO-H 3 7 vs. | . CASE NUMBER: 95-00390 THOMAS PERKINS, RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Chiropractic against THOMAS PERKINS, hereinafter referred to as "Respondent’, and alleges: | 1 _Effective July 1, 1991, Petitioner is ‘the state agency charged with regulating the practice of chicopractc pursuant t to Section n 20. 43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 460, Florida Statutes, Pursuant to the authority of Section 20. 436)(0, Florida Statutes, the Petitioner has contracted with the “Agency for Health Care Administrati complaint investigative, and prosecutorial services required 2. "Respondent is, | and has been at all times material hereto, a licensed chiropractic physicia in n the State of Florida, having been issued license number CH 0003309. Respondent's lastinown address i is 5 2013 Miccosukee Road, “Tallahassee, Florida 32308 5307, From on or about September 14, 1993 through on of about May 18, 1994, Patient C.C. presented to the Respondent for Chiropractic treatment. ge Sie gg 4, From on or about September 14, 1993 through on or about May 18, 1994, Patient C.C. presented to the Respondent for chiropractic treatment for a total of sixty-one (61) visits. 5. The Respondent’s patient medical records for Patient C.C. reflect the sixty-one visits; however the Respondent’s patient medical records failed to meet the minimum standards Justifying the course of chiropractic treatment in that: a) there is no documentation to justity the prolonged treatment program. b) there are little objective findings in the records to substantiate the ongoing need for care. c) there are no adequate SOAP notes to document care for eight (8) months. 6. . Based upon the foregoing, Respondent’s license to practice chiropractic in the State of Florida is subject to discipline pursuant to Section 460.413 (1)(m), Florida Statutes, for failing to keep legibly written chiropractic records that identify clearly by name and credentials the licensed chiropractic physician rendering, ordering, supervised, or billing each examination or treatment procedure and that justify the course of treatment of the patient, including, but not limited to, patient histories, examination results, test results, x-rays, and diagnosis of a disease, condition, or injury. 7 - . : . oe ww WHEREFORE, Petitioner respectfully request the Board of of Chiropractic to enter an ‘order i 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, and/or any other relief that the Board deems appropriate. | SIGNED this Dd day of , 1998. Douglas M. Cook, Director BY: Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration COUNSEL FOR. PETITIONER: Sais A. McCarthy Attorney Agency for Health Care Administration ; re Post Office Box 14229 ; ok et ptt tbe ches FILED. . : Tallahassee, Florida 32 3] Cth co QeARTMENT OF ree i. (904) 487-2225 ERAT CLENY DATE: Bloi\a%

Docket for Case No: 00-001139