STATE OF FLORIDA ' DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, BOARD OF PHYSICAL THERAPY PETITIONER, vs. oe CASE NUMBER: 2000-11031 SEAN THOMAS BORMAN, . OV NGA | 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 SEAN THOMAS BORMAN, hereinafter referred to as "Respondent", and - ere: alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the csc necinmaninettes ateeslahbatateonsaisicdetaisnidie. practice of Physical Therapy - pursuant to ‘Section 20. 43, Florida Statutes; Chapter 456, Florida oot 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 bye the Division of Medical Quality. Lies tebewcainte settee Seatac elated ocaaemnarn RE i : Assurance, ‘councils, ‘or boards as appropriate including the issuance e of emergency orders of | suspensi on or! 2. “Respondent has been at all time material hereto, been a duly licensed Physical Therapist in the State of Flori a, having’ been issued license number PTA 16759. Respondent Ss last known address i is 516 Green Springs Place, West Palm Beach, Florida 33409. . Complainant CH worked for the Respondent as a physical therapist. 4. Respondent directed CH to change dates of physical therapy evaluations in patient records. 5. Respondent's direction to change dates of physical therapy evaluations in patient records was heard directly by other employees of Respondent. 6. It is not acceptable practice for a Physical Therapist Assistant to direct anyone to change dates on evaluations in patient records. 7. ~ Based on the foregoing, Respondent has violated Section 486.125(1)(e), Florida Statutes, through a violation of Rule 64B17-6(2)(e), Florida Administrative Code, for participating in any form of communication containing misleading, statements, or engaging in unprofessional conduct. ; 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 Did day of gut 2001. Robert G. Brooks, M.D. ..... Secyetary, Department ealth By: Nancy Snurkowski, Chief Attorney On Behalf of Agency for Health Care Administration _ COUNSEL, Ro Mary Denise O'Brien, Senior Attomey — Florida Bar No. 306754 __ ~ Agency for Health Care Administration _.., General Counsel’s Office-MQA DEPARTMENT OF HE&ALy ~ POBox 14229 ; a TY CLERK -_ Tallahassee, Florida 32317-4229 CLERK Yahi g. keen ~~ (850) 488-1474 . PCP: Clendenin, Lendeblad and Menge DATE: 03/27/01 DATE GTo

Docket for Case No: 01-001962PL