¥ oo , wo, | & , “ STATEOF FLORIDA am +E gp DEPARTMENT OF HEALTH Up , &P BOARD OF PHYSICAL THERAPY b Onis, AN 3 ‘DEPARTMENT OF HEALTH, , MEG Siig on 98 Petitioner, Case No. 97- 12657 ee we Og-127 & DAVID M. SEIDNER, Respondent, oe ADMINISTRATIVE | COMPLAINT COMES Now, the Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as. “Petitioner,” represented i in this matter by the Agency for “Health Care Administration, and files __ this Administrative Complaint | before the Board of Physical Therapy, against ,David M. Seidner, hereinafter referred to as -uRespérident.” and alleges: 1. Petitioner is the state agency charged with regulating the practice of physical - therapy pursuant to Section 20. 43, Florida Statutes, and Chapter 455 and 486, Florida Statutes. 3.” Pursuant to the authority of Section 20.43(3)(f), Florida Statutes, (Supp. 1996), “the 2 Petitioner has ‘contracted with the ‘Agency for Health Care Administration to provide ~ consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quali 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 THERAPIST, sn the State of Florida, having been issued license number PT 0005152. ke. - Z 4. Respondent’s last known address is 8184 Wiles Road, Coral Springs, Florida- 33067. 5. . On or about November 3, 1994, Respondent renewed his license and signed an ” affirmation stating that he had completed the required twenty-four hours of continuing education and HIV/AIDS course. 6. The Board of Physical Therapy conducted a continuing education audit of licenses for the 1993-1995 biennium, requiring licensees to submit proof of completion of the aforementioned continuing education. The Respondent’s license was selected for audit. 7. Respondent has failed to submit proof of completion of the required 24 hours of continuing education. COUNT if - 8. ; Petitioner realleges and incorporates by reference the allegations of fact contained ~ in paragraphs one (1) through seven (7) as if fully stated herein. | 9. Based. on the foregoing, the Respondent is subject to discipline pursuant to Section 486.125 (1h), Florida Statutes, by violating Rule 64B17-9.001, Florida Administrative Code, which states the requirement to complete twenty-four contact hours of continuing education courses approved by the Board in the twenty-four months preceding each biennial renewal period as established by the Department. "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 Respondent's license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of Respondent on probation, and/or any other relief the Board deems appropriate. : perpen ete By SIGNED this th aay ot SObr WA, i990 Douglas M. Cook * Director FILED DEPARTMENT OF HEALTH + Nancy M. Snurko - Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR PETITIONER: ‘Susan B. Bodell ff Senior Attorney Florida Bar Number 0987859 Agency for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 ‘Tallahassee, FL 32317-4229 (850) 487-9697 SBB\jeg

Docket for Case No: 00-001272