STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 2000-10732 GREGORY SANTOME O}-OUS PL RESPONDENT. / ‘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 Practice against Gregory Santome, 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 456, Florida Statutes; (formerly Chapter 455, Part II: see Chapter 2000-160, Laws of Florida) 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 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 time material hereto, a licensed Physical Therapist Assistant in the State of Florida, having been issued license number PTA 0001264. Respondent's last known address is 350 South 17th Avenue, Apartment 1, Hollywood, Florida 33020-5138. 3. A Physical Therapy Audit was conducted for the 2/1/97 through 3/15/99 biennium in which every licensed physical therapist shall complete twenty-four (24) contact hours of continuing education courses and complete one (1) hour of HIV/AIDS education approved by the Florida Physical Therapy Association (FPTA) or American Physical Therapy Association (APTA) in the twenty-four months preceding each biennial renewal period as required by Rule. 4. The Respondent failed to comply with the continuing education requirements for the biennial renewal period. 5. Based on the foregoing the Respondent has violated Section 486.125(1)(h), Florida Statutes, through a violation of Rule 64B17-9.001, Florida Administrative Code, for failing to comply with the Continuing Education requirements for the biennial licensure renewal period. WHEREFORE, Petitioner respectfully requests that the Board of Physical Therapy Practice 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 of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this C M4 h day of hoe Wy y wh ) ara , 2000. Robert G. Brooks, M.D. By: Nancy Snurkowski, Chief Attorney ~ On Behalf of Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Shannon R. Fleming, Senior Attorney. Florida Bar # 0166677 DEPARTMENT OF HEALTH Agency for Health Care Administration DEPUTY CLERK Practitioner Regulation ~ Legal CLERK Wb P. O. Box 14229 Veh R Kenan Tallahassee, Florida 32317-4229 DATE tt / (S. feo (850) 488-1474 PCP: Jewel Menge & Mark St6ffiC,i }2 Sra gp DATE: October 31, 2000 BOT oc eteeee SRF/dja

Docket for Case No: 01-000458PL