STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, BOARD OF CLINICAL SOCIAL WORK, MARRIAGE AND FAMILY THERAPY AND MENTAL HEALTH COUNSELING, | Petitioner, ~ vs. : Case Number: BRENDA STARR, Respondent. / ADMINISTRATIVE COMPLAINT _ COMES NOW, the Petitioner, Department of Health, hereinafter referred tc to as “Petitioner,” and files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling against BRENDA STARR, hereinafter referred to as “Respondent, “ and alleges: _1.. Petitioner is the state agency charged with regulating the practice of clinical social work 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 491, Florida Statutes. Pursuant to section 20.43 Gye), Florida Statutes, the Department 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. . 2. Respondent is, and has been at all times material hereto a licensed Clinical Social Worker in - the State of Florida, havingt been issued license nunbes sw 0004284, ; 3. ‘The last address of record for the Respondent is 21 2 Cypress Bend Drive South #801, of Pompano Beach, Florida 33069. eer REE cone cage one Seppe tt nese gene = ener spor sane es Sno a me TR ae 4, In 1994, patient GD sought mental health treatment from University Pavilion Hospital. At ’ that time, the Respondent was a masters level social worker working at the hospital. The Respondent did provide counseling services to GD at that time. . swe 5. The Respondent became a Florida licensed clinical social worker on or about February 5, 1996. 6. Beginning in 1994 and continuing until October 1999, the Respondent engaged ina sexual ; relationship with GD. The Respondent and patient GD cohabitated for brief periods of time during the duration of the sexual relationship. - , 7. Continuing until 1999, the Respondent billed Medicare for psychotherapy services provided “to patient GD. OO - 0 . ' 8. The statutes and rules governing the practice of clinical social work prohibit a licensee from engaging in a sexual relationship witha patient, Based on the foregoing, the Respondent has violated section 491.009 @®), Florida Statutes, by committing any act upon a patient or client which would constitute sexual misconduct : as defined in section 491.0111, Florida Statutes and 64B4-10.002 (2), Florida Administrative Code. WHEREFORE, Petitioner respectfully requests the Board of Clinical Social Work, Marriage and Family Therapy and Mental Health Counseling to enter an Order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license; restriction of 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__] OYA day of Prag , 2001. Robert G. Brooks, M. D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney - General Counsel’s Office Practitioner Regulation — Legal COUNSEL FOR PETITIONER: . Deborah B. Loucks Senior Attorney Florida Attomey Number 01 69889 Agency for Health Care Administration F | LED . Practitioner Regulation — Legal RTMENT OF HEALTH Post Office Box 14229, Mail Stop #39 DEPAR PUTY C Tallahassee, Florida 32317-4229 (850) 487-9694 per Snyecs. oo (Rens

Docket for Case No: 01-001903PL