os i haw STATE OF FLORIDA BOARD OF PHYSICAL THERAPY 95 pH 3: 32 DEPARTMENT OF HEALTH, - OlViaeh , : : : ADMINIS RAL VE PETITIONER, HEAGINGS vs. CASE NUMBER: 98-14981 NIKE ADAMEDES, [O-044 | LH 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 against NIKE ADAMEDES, 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 of Health Care Administration, hereinafter “Agency,” to provide consumer complaint, investigative, and prosecutorial s¢rvices required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and at all times material hereto, a duly licensed physical therapist, having been issued license number PT 0002508. ) 3. Respondent’s last known addfess is 649 NE 117" Street, Biscayne Park Village, Miami, Florida 33161-6253. UW UY 4. At all times material hereto, Respondent was the owner/operator of Physical and Sports Therapy Center (P&STC). 5.. In or about May of 1994, patient C.O. presented to P&STC for treatment following reconstructive knee surgery. 6. In or between May and November of 1994, C.O. made approximately _ sixty-six (66) visits to P&STC for treatment. 7. Following the first fifty (50) visits to P&STC, C.O. paid approximately $20 per visit while his insurer, Blue Cross / Blue Shield (BC/BS) paid approximately $100 per visit. 8. Patient C.O.’s contract with his insurer, stipulated that the insurer would only pay for the first fifty visits made to P&STC. 9. Patient C.O. reached an agreement with P&STC whereby if P&STC’s office manager could convince BC/BS to pay for the remaining sixteen visits, C.O. would not be responsible for any additional payment for treatment rendered in his final sixteen (16) visits to P&STC. 10. BC/BS subsequently submitted payment to P&STC for the aforementioned sixteen visits. 11. In or about October of 1997, P&STC filed suit against C.O. claiming that he owed them money ($300 per visit) for the aforementioned sixteen visits that were originally not covered by C.O.’s insurance, but were subsequently paid for by BC/BS. 12. Respondent, as owner and opetator of P&STC, is responsible for all actions taken on the part of P&STC. YY YU 13. Based on the foregoing, Respondent’s billing practices deceived clients subjecting her to discipline pursuant to Section 486.125(1)(h), Florida Statutes, by ‘violating Rule 64B17-6:001(2)(8), Florida ‘Administrative Code, which prohibits any physical therapist from exploiting the patient for financial gain. WHEREFORE, Petitioner respectfully requests 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 of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this LGhasy of rere. , 1999, Dr. Robert G. Brooks, M.D., Secretary - Department of Health ancy M. Snurkowski Chief Attorney Agency for Health Care Administration FILED Agency for Health Care adm inistration DEPARTMENT OF HEALTH Allied Health EPUTYCLERK P.O. Box 14229 CLERK Q. uw Tallahassee, FL 32317-4229 (850) 414-8576 ~ pate_B(7-99 CIS/ojs PCP: DATE:

Docket for Case No: 00-000414