5 hea aoe YW Ww STATE OF FLORIDA . DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, ’ Petitioner, vs. WILLIAM JOSEPH BOHS, Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, 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 WILLIAM JOSEPH BOHS, hereinafier referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of mental health counseling pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 491, Florida Statutes. . 2. Pursuant to the authority of Section 20.43(3)(), Florida Statutes (Supp. 1996), the ~ “Petitioner has contracted with the Agency for Health Care Administration to provide consumer jal services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate, including the issuance of emergency orders of ‘raiconornscicn | 3. — Respondent is, and has een at all times ‘material hereto, a licensed Mental Health Counselor in the state of Florida, having been issued license number MH 0001352. nla ERNE i Wo w 4. Respondent’s last known address is 5357 Congo Court, Cape Coral, Florida 33904- 5863. : 5. On or about January 1993, KE-Z. sought Respondent’s professional counseling services for her daughter K.E. 6. At the time K.E~Z. brought her daughter to Respondent, KE. was nine (9) years old and K.E.-Z. had recently divorced K.E.’s father. 7. After her parents’ divorce, K-E. began verbalizing to her mother about sex and stress in regard to her mother’s having a boyfriend. 8. Respondent counseled K.E. on two (2) occasions, the first without K.E.-Z. being present, and the second with K_E. “. Present along with K-E. and Respondent. 9. During the second session, ‘Respondent asked KE. inappropriate sexual questions “regarding Respondent’s penis and whether K.E.-Z. would like to engage in sexual contact with Respondent. 10. At the time Respondent counseled K.E., Respondent had suspicion to believe that KE. had been sexually abused. a | 11. | Respondent failed to report KE’s suspected sexual abuse to the Department of Health and Rehabilitative Services abuse registry. aoe = ovr sete fk Sue COUNT I ~12. — Petitioner realleges and incorporates by reference the allegations of fact contained in ‘paragraphs one (1) ough elev even (1 » as if fully stated herein. . 13. Bas d on the ‘foregoing, Respondent ‘has ‘Violated “Section 491.009(2)(k), Florida Statutes, by committing any act upon a patient or client which would constitute sexual battery or wo an”, which would constitute sexual misconduct as defined pursuant to Section 491.0111, Florida Statutes. ° COUNT I 14. Petitioner realleges and incorporates by reference the allegations of fact contained in paragraphs (1) through eleven (11) as if fully stated herein. 15. Based on the foregoing, Respondent has violated Section 491.009(2)(s), Florida Statutes, by failing to meet minimum standards of performance in professional activities. COUNT 10 16. Petitioner realleges and incorporates by reference the allegations of fact contained in paragraphs one @) through eleven ad 1) as if fully stated herein. 17. Based on the foregoing, Respondent has violated Section 491.009(2)(h), Florida Statutes, by failing to perform any statutory or legal obligation placed upon a person licensed or certified under this chapter. WHEREFORE, Petitioner respectfully requests the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling enter an Order imposing one or more of the following penalties: revocation or suspension of Respondent’s license, imposition of an . administrative fine, , issuance of a reprimand, placement of of the Respondent” s icense on probation, ; ‘andlor any other relief that the Board deems appropriate. 1999. Robert G. Brooks, M.D Secretary Department of H, FILED General Counsel’s Office-MQA Allied Health 00 APR 27 PH 3:41 DEPARTMENT OF HEALTH EPUTY CLERK By: Nancy M. Snurkowski cuenghtichemee 0 O Chief Attorney pate__ (“26 “OF WW _. COUNSEL FOR AGENCY: Susan L. Salamy ° Senior Attorney Florida Bar Number 0648809 Agency for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9670 SLS/kmg PCP:

Docket for Case No: 00-001778