Jul 2 2010 13:38 Jul O02 2010 12:35PM APD 8504100665 STATE OF FLORIDA AGENCY FOR PERSONS WITH DISABILITIES AGENCY FOR PERSONS WITH DISABILITIES, License No. 10-2202GH Petitioner, Vv. ADAMS GROUP HOME #¥ 2, owned and operated by Joyce Adams, Respondent. ADMINISTRATIVE COMPLAINT The AGENCY FOR PERSONS WITH DISABILITIES, (“Petitioner’ or “Agency’), issues this Administrative Complaint against Adams Group Home # 2, owned and operated by Joyce Adams, (or “Respondent’), and states the following as the basis for this complaint: 1. Petitioner is the state agency charged with regulating the licensing and operation of foster care facilities, group home facilities, and residential habilitation centers, pursuant to Section 20.197 and Chapter 393, Florida Statutes. 2. At all times material to this complaint, Respondent has held a group home facility license issued by the Agency for a residence at the following address: 7131 SW 16" Street, Pembroke Pines, Florida. P- Jul O02 2010 Jul 2 2010 13:39 12:35PM APD 8504100665 Section 393.0673(1)(a)(3}, Florida Statutes, provides that the Agency may revoke or suspend a license, or impose an administrative fine if the licensee has failed to comply with the applicable requirements of Chapter 393, Florida Statutes, or the rules applicable to the licensee. Page 1-14 of the Developmental Disabilities Waiver Services Coverage and Limitations Handbook, incorporated into rule through Rule 59G- 13.083(2), F.A.C., states that “parents of minors, spouses, guardians and guardian advocates of waiver participants are specifically excluded from payment for any services provided to their child, spouse or recipient served.” FACTUAL ALLEGATIONS On January 26, 2004, the applicant became the guardian advocate for B.B., an Agency client, who was residing in a group home operated by the applicant. Respondent is legally responsible for the care of the client. Since that date, the applicant has continued to render and subsequently receive reimbursement for waiver services on behalf of that individual. On March 3, 2004, the applicant became the guardian advocate for two additional Agency clients, L.M. and E.H., who were also residing in a group home operated by the applicant. Respondent is legally responsible for the care of the clients. Since that date, the applicant has continued to render and subsequently receive reimbursement for waiver services on behalf of those individuals. P- Jul 2 2010 13:39 Jul O02 2010 12:35PM APD 8504100665 COUNT 1 7. Based on the foregoing, the Respondent has violated the Developmental Disabilities Waiver Services Coverage and _ Limitations Handbook, incorporated into rule through Rule 59G-13.083(2), F.A.C., by receiving payment for waiver services provided to B.B., for whom the Respondent has simultaneously been a guardian advocate as of January 26, 2004. COUNT 2 8. Based on the foregoing, the Respondent has violated the Developmental Disabilities Waiver Services Coverage and Limitations Handbook, incorporated into rule through Rule 59G-13.083(2), F.A.C., by receiving payment for waiver services provided to L.M., for whom the Respondent has simultaneously been a guardian advocate as of March 3 2004. COUNT 3 9. Based on the foregoing, the Respondent has violated the Developmental Disabilities Waiver Services Coverage and Limitations Handbook, incorporated into rule through Rule 59G-13.083(2), F.A.C., by receiving payment for waiver services provided to E.H., for whom the Respondent has simultaneously been a guardian advocate as of March 3 2004. WHEREFORE, Petitioner respectfully requests entry of an order imposing the following penalties: revocation of licensure and/or any other relief authorized by Chapter 393, Florida Statutes, or the rules promulgated thereto, this honorable tribunal deems fair and equitable. P- Jul 2 2010 13:39 Jul O02 2010 12:35PM APD 8504100665 Dated: June 22, 2010 onathan Grabb Attorney, Office of General Counsel Agency for Persons with Disabilities 4030 Esplanade Way, Suite 380 Tallahassee, Florida 32399-0950 Cc/ Martha Martinez, APD Area 10 Administrator Attachments: Explanation of Rights Election of Rights Form P-

Docket for Case No: 10-004717

Orders for Case No: 10-004717