7, - ~ ©/-S171geb RECEIVED - LEGAL OOAPR25 PH 327 - STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, _ Petitioner, vs. . Case No. 99-00010 “6 DEBORAH ANN HULBERT, LCSW, Respondent. / ADMINISTRATIVE COMPLAINT . , COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Clinical Social Work, Marriage and Family, and Mental Health Counseling against DEBORAH ANN HULBERT, LCSW, 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 455, Florida Statutes; and Chapter 491, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter referred to as ; the “Agency,” 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. “créstriction. © congege cece qe een ir REI Ae tee > 3. ‘ Respondent is and has been at all times material hereto, a licensed Clinical Social . Worker, licensed in the State of Florida, having been issued license number SW 0004434. Respondent’s last known address is 1320 Northwest 3" Terrace, Cape Coral, Florida 33909. On or about June, 1997, the Complainant began therapy with the Respondent. On or about January, 1998, the Respondent employed the Complainant as her office manager. The Respondent authorized the Complainant to make purchases for the benefit of the Respondent’s practice with the purchases being charged to the personal credit accounts of the Complainant. . . The Respondent directed the Complainant to enter into a lease agreement for equipment used in the Respondent’s practice and the Respondent failed to make the lease payments. On at least one occasion (on or about March 8, 1998), the Respondent drove the personal vehicle of the Complainant. . On an application for a corporate credit card, the Respondent stated that she held a Ph. Dz. . The Respondent obtained prescription drugs for her personal use by using pre-signed scripts. . The Respondent has failed to respond to the Agency’s request for producing records of the treatment provided to the Complainant. COUNT I . Petitioner realleges and hereby incorporates paragraphs one (1) through twelve (12) above. “ mm 14, Based on the foregoing, Respondent has violated section 491.009(2)(s), Florida : Statutes, and disciplinary action may be taken for failing to meet the minimum standards of performaiice in professional activities when measured against generally prevailing peer performance. . COUNT II "15, Petitioner realleges and hereby incorporates paragraphs one (1) through twelve (12) above. 16. Based on the foregoing, Respondent has violated section 491.009 (2)(0), failing to respond within thirty (30) days to a written communication from the department concerning any investigation by the department. COUNT JI . 17. Petitioner realleges and hereby incorporates paragraphs one (1) through twelve (12) above. . 18. Based on the foregoing, Respondent has violated section 491.009 (2)(q), Florida Statutes through a violation of section 455.624(1)(m), Florida Statutes by making deceptive, untrue, or fraudulent representations in or related to the practice of a profession through a violation of section 817.567 (2), Florida Statutes. COUNT IV _19. Petitioner realleges and hereby incorporates paragraphs one (1) through twelve (12) above : 20. Based on the foregoing, Respondent has violated section 491.009 2)(q), Florida Statutes through a violation of section 455.624 (1)(n), Florida Statutes, by ising influence on 4 patient or client for the purpose of financial gain of the licensee. — k i , 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 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. sicnep this__| &f Wray of (a8 2000. Robert G. Brooks, M. D. - > D Secretary, Department of Health DEPARTMENT OF HEALTH DEPUTY CLERK cen Yahi RMiot eo r , BY: ‘Nancy M. Snurkowski DATE. 4 Ad- 200 Chief Attorney Genera! Counsel’s Office - MQA Practitioner Regulation — Legal COUNSEL FOR PETITIONER: / Deborah B. Loucks & . 0 200 Senior Attorney CR Or nek Ve eC oe oy oe Florida Attorney Number 0169889 Pe LO gatboant ” Cor nack > Agency for Health Care Administration Practitioner Regulation — Legal -Post Office Box 14229 “Tallahassee, Florida 32317-4229 Telephone: 850/ 487-9694 i all

Docket for Case No: 01-003778PL

Orders for Case No: 01-003778PL