required by the Di s 4 % yp “< Oy “ez. & STATE OF FLORIDA es, DEPARTMENT OF HEALTH TES. %, et v3 n° Sy, DEPARTMENT OF HEALTH . & Petitioner, O O-7/ Abo O vs. CASE NO. 98-23109 . ROBERT DUVALL, : Respondent. ; S ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner”, and files this Administrative Complaint before the Board of Physical Therapy - against ROBERT DUVALL, hereinafter referred to as “Respondent”, and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Physical Therapy pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 486, 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 ‘Prosecutoria services of Medical Quality Assurance, councils, or boards as appropriate. 2. "Respondent is, and has been at all time material hereto, a licensed Physical Therapist in the State of Florida, having been issued license number PT 4042. 3. Respondent's last known address is 2138 Scenic Highway, Suite B, Snellville, C GA 30278 4, : The Respondent wi was as granted 2 a Florida Physical Therapy ficense on or “about December 10, 1984. Ue ) , 5. The Respondent is also licensed to practice as a physical therapist in the State of Georgia. “6 Respondent caused an MRI to be ordered for a patient in Georgia at the wrong hospital by calling the prescription in at that hospital as if he was one of the staff of the treating physician. a Respondent also held himself out to be the treating physician at another hospital in order to get another patient a MRI scheduled. 8. Respondent is not licensed to practice medicine and is not a physician or physician’s assistant. . 9. The Georgia Board of Physical Therapy disciplined the Respondent for knowingly engaging in making untrue representations to a patient and for engaging in unprofessional or unethical conduct harmful to the public. 10. On or about November 7, 1997, the Georgia Board of Physical Therapy placed Respondent’s physical therapist license on probation for 270 days, fined him $250.00 and ordered him to cease and desist the practice of medicine. COUNT ONE i. - Petitioner realleges and incorporates by reference paragraph one (1) : through ten (10). 12. _ Based on the foregoing, Respondent has violated Section 486.125(1)(g), Florida Statutes, by having his license acted upon by another state. wo oy WHEREFORE, Petitioner respectfully requests that the Board of Physical 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 ofa reprimand, placement of the Respondent on probation, and/or any other relief that the Board.deems appropriate. P70) SIGNED this day of 34999. Robert G. Brooks, M.D. Secretary, Department of Health FILED DEPARTMENT OF HEALTH DEPUTY CLERK Nancy M. Snurkowski CLERK Yahi RMdont Chief Attorney General Counsel’s Office-MQA pate_!/2G/A000 Allied Health COUNSEL FOR PETITIONER: Shannon R. Fleming Senior Attorney Agency for Health Care Administration pean cee I en ee peice ne 1 me RRA ene a rs

Docket for Case No: 00-001260