Nv YY a“ f D- LEGAL, @. STATE OF FLORIDRECE'VE *Y GY DEPARTMENT OF HEA§GFEB 24 PH 3: 227 DEPARTMENT OF HEALTH Petitioner, vs. Case No. 97-21156 LINDA BASSING, Oo 22 / - Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through its undersigned counsel and files this administrative complaint before the Board of Physical Therapy against the Respondent, LINDA BASSING, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of Physical Therapy pursuant to Chapters 20, 455, and 486, Florida Statutes. 2. Pursuant to the authority of Chapter 20, 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. 3. Respondent is and has been at all times material hereto, a licensed PHYSICAL THERAPY ASSISTANT in the State of Florida, having been issued license number PT A001398. 4. Respondent's last known address is 7710 Shangrilla, Millington, Tennessee 38053. U wa 5. At all times material hereto, Respondent was employed by Olympia Health and Fitness (hereinafter "Olympia"). 6. On or about October 30, 1997, an inspection of Olympia's pool revealed deficiencies, including but not limited to: | | a. Chlorine and pH levels were outside (higher than) the normal ranges; b. Dis-infection and pH feeders were not working properly; and c. the pool's pumps were leaking. 7. On or about October 30, 1997, the Respondent signed and received a copy of the inspection form indicating the aforementioned deficiencies. 8. On or about October 30, 1997, the Respondent was informed that the pool was to remain closed until the deficiencies were corrected. 9. On or about November 3, 1997, the Respondent was observed providing aquatic therapy in the aforementioned pool. 10. Onor about November 3, 1997, the deficiencies had not been corrected. 11. Based on the foregoing, Respondent is subject to discipline pursuant to Section 486.125(1)(e), Florida Statutes, by failing to maintain acceptable standards of physical therapy as set for by the board. WHEREFORE, Petitioner respectfully request that the Board 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 the Respondent on probation, costs, and/or-any other relief that the Board deems appropriate. Wu Nw) SIGNED this__ |" Wh_ day of Mor Hi , 1999. Robert G. Brooks Secretary, Department of Health ancy M. Snurkows! Chief Attorney Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney FBN: 0112925 Agency for Health Care Administration General Counsel's Office - MQA Allied Health 2727 Mahan Drive Tallahassee, FL 32308 (850) 487-9644 RDD/tjs PCP: Lindeblad, Stoff & Davis DATE: 12-14-98 FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK jryphonue Q. Sum DATE, QU

Docket for Case No: 00-000621