CARLOS ANIBAL MONCADA, RESPONDENT. ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Physical Therapy Practice against CARLOS ANIBAL MONCADA, 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 456, Florida Statutes; (formerly Chapter 455, Part II; see Chapter 2000-160, Laws of Florida), and Chapter 486, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), 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. STATE OF FLORIDA Oy , /p DEPARTMENT OF HEALTH Fp 29 ™ bo FY to, . HE4 pha y DEPARTMENT OF HEALTH, O I}. 053 | e la . PETITIONER, : vs. CASENUMBER: 00-08938 2. Respondent is, and has been at all time material hereto, a licensed Physical Therapist Assistant in the State of Florida, having been issued license number PTA 0018533. Respondent's last known address is 6403 East Shore Drive, Pensacola, Florida 32505-2043. 3. Respondent applied for licensure as a Physical Therapist Assistant in the State of Florida by examination on or about August 20, 1999, and was approved to sit for exam. Upon receiving a passing score, Respondent was issued a license. 4. However, pursuant to Section 486.102(3)(a), Florida Statutes, a licensing requirement for Physical Therapist Assistant is having graduated from a school giving a course of not less than 2 years for physical therapist assistants, which has been approved by the appropriate accrediting agency recognized’ by the Commission on Recognition of Post-secondary Accreditation or the United States Department of Education. 5. Respondent graduated from the Department of the Army, Academy. of Health Sciences. This institution is accredited by the Accrediting Commission of: the Council on Occupational Education, which is not the approved accrediting agency, and the Academy is a non-degree granting institution. 6. In addition, the Respondent has an Associate of Arts degree in "Professional Laws in Physical Therapy". This degree also does not meet Florida's education requirements for licensing. 7. Therefore, Respondent did not meet the education requirements for licensure as required by Section 486.102(3), Florida Statutes, and was issued a license through an error of the Depaitment or Board. : 8. Based on the foregoing, Respondent has violated Section 456.624(1)(h) Florida Statutes, by attempting to obtain or renew a license by fraudulent misrepresentation or through an error of the Board. 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 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 _| Ci day of Depema 2000. COUNSEL FOR PETITIONER: Shannon R. Fleming, Senior Attomey SXF Agency for Health Care Administration Practitioner Regulation - Legal Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 488-1474 DOM: MENGE, KudwsS, * davis PCP: Auge 27,200" , Robert G. Brooks, M.D. Secretary, Department of Health By: Nancy Snurkowski, Chief Attorney On Behalf of Agency for Health Care Administration DEPARTMENT OF H DEPUTY ClenK 7 CLERK Uchi R. Lenon DATE 7 (as ]07_ " 07/26/00

Docket for Case No: 01-000831PL