UW | VU STATE OF FLORIDA REcEWWEBE LES LEGA} - DEPARTMENT OF HEALTH of PEBSER, BM Bi ou DEPARTMENT OF HEALTH AGRI Sion oF , ADHINIS TR ative Petitioner, E ARINGS vs. Case No. 97-09472 NANCY MARIE SQUITIERI, 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, NANCY MARIE SQUITIERI, 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. Respondent is and has been at all times material hereto, a licensed PHYSICAL THERAPIST in the State of Florida, having been issued license number PT 0003930. 3. Respondent's last known address is 904 Mcintosh Drive, Brandon, Florida 33510-3240. 4. At all times material hereto, Respondent was employed by Brandon Physical Therapy (hereinafter "BPT") and assigned to provide physical therapy treatment to Patient M.B. WW Nw, 5. On or about January 1995, Patient M.B. suffered a fracture of the left ulna and was subsequently referred to BPT for physical therapy. 6. On or about February 27, 1995, Respondent performed an ultrasound of Patient M.B.'s left ulna, administering the ultrasound over the incision site. 7. On or about March 3, 1995, Respondent performed an ultrasound of Patient M.B.'s left ulna, administering the ultrasound over the incision site. 8. On or about March 3, 1995, Respondent attempted manipulation of Patient M.B.'s left arm; during this manipulation Patient M.B. suffered another fracture of the left ulna near the site of the original fracture site. 9. On or about March 3, 1995, the Respondent's manipulation of Patient M.B.'s left arm caused the second fracture of Patient M.B.'s left ulna. 10. On or about March 6, 1995, Respondent performed an ultrasound of Patient M.B.'s left ulna, administering the ultrasound over the incision site. 11. Onor about February 27, 1995, March 3, 1995 and March 6, 1995, Patient M.B. did not have a physician's order for an ultrasound to be performed. 12. On or about March 3, 1995, Patient M.B. did not have physician's order for manipulation to be performed. 13. A reasonably prudent physical therapy practitioner, under similar conditions and circumstances would not have performed ultrasound or manipulation on the left ulna of Patient M.B. 14. Based on the foregoing, Respondent's license ‘is subject to discipline pursuant to section 486.125, Florida Statutes, by failing to maintain acceptable standards of physical therapy as set forth by Rule 64B17-6.001(2)(g), F.A.C., by failing to practice UU ao) physical therapy with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physical therapy practitioner under similar conditions and circumstances. WHEREFORE, Petitioner respectfully request that the Board of Physical Therapy 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. Signed this (Whey of Mtb VOM 19 Robert G. Brooks, M.D. Secretary, Department of Health Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration FILED COUNSEL FOR THE PETITIONER: DEPARTMEN Oem Reginald D. Dixon, Senior Attorney be ) p : ww FBN: 0112925 CLERK He Agency for Health Care Administration pate Ae AY-5 7 Allied Health Section Post Office Box 14229 - Tallahassee, Florida 32317-4229 (850) 414 - 8576 : RDD/rd PCP: Lindeblad, Stoff & Davis © DOM: 12-14-98 H:ABOARD\ACS\PT\ac97-09472.doc

Docket for Case No: 00-003808PL