¥ _ STATE OF FLORIDA | DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH’, PETITIONER, Qo = —- vs. : JOSE GUILLERMO CELPA, RESPONDENT . a ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner," and files this Administrative Complaint before the -Board of Acupuncture, hereinafter referred to as “the Board” and against, JOSE GUILLERMO CELPA, hereinafter referred to as "Respondent," and alleges: 1. Petitioner is the state agency charged with regulating the practice of Acupuncture pursuant to Section 20.43, Florida Statutes, Chapter 455, Florida Statutes, and Chapter 457, Florida Statutes. 2. Respondent is, and has been at all times material hereto, a licensed Acupuncturist in the State of Florida, having been issued license Number AP 0000519. Respondent's address of record is 6817 North Thacher, Tampa, Florida 33614. 1 Effective July 1, 1997, pursuant to Section 20.43, Florida Statutes, the Department of Health is the agency charged with regulating the practice of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling. 1 P12 ONC ad So) ~ 3. During or around May 1996, the Respondent began treating patients J.R., M.R., R.S., and M.S. for injuries that resulted from an accident. 4. In the initial report dated May 31, 1996, the Respondent utilized the designation “O.M.D.” which stands for Oriental Medical Doctor. 5. During or around June 17, 1996, the Respondent submitted claim forms to Material Damage Adjustment Corporation for the services he rendered to patients J.R., M.R., R.S., and M.S. 6. Respondent utilized the designation “M.D.” which stands for Medical Doctor. 7. Respondent also referred to himself as “Dr. Jose Celpa” on the Attending Physician’s General Report form that he submitted to Material Damage Adjustment Corporation. 8. Respondent is not licensed as a medical doctor in the State of Florida. 9. Based on the foregoing, Respondent has violated Section 457.109(1) (k), Florida Statutes, by making deceptive, untrue, or fraudulent representations in the practice acupuncture when such scheme or trick fails to conform to the generally prevailing standards of treatment in the community. WHEREFORE, Petitioner respectfully requests the Board of Acupuncture to enter an order imposing one (1) or more of the following penalties: revocation or suspension of the Respondent's VY oo ) « license, restriction of the Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent’s license on probation for a period of time and subject to terms and/or conditions, and/or any other relief which the Board deems appropriate. SIGNED this QQ)Vaday of | Latina lon’ , 1997. James T. Howell, M.D., M.P.H. Secretary Nancy M. Snurk Chief Attorney oe General Counsel’s Office - MQ: Allied Health an “Wd 82 Tr 00 COUNSEL FOR PETITIONER: cueaxghrchenud, Alexandria E. Walters DATE G- o-97 Staff Attorney Florida Bar No. 0110590 Agency For Health Care Administration P.O. Box 14229 ‘ Tallahassee, Florida 32317-4229 ph. (850) 487-9694 ar\ (850) 414-1991 /snxrp PCP: Fraser, Tsai PCP DATE: July 11, 1997

Docket for Case No: 00-003099PL