STATE OF FLORIDA EDUCATION PRACTICES COMMISSION RICHARD CORCORAN, as Commissioner of Education, Petitioner, vs. CASE NO. 156-2409 MICAH HARRELL, Respondent. ; ADMINISTRATIVE COMPLAINT Petitioner, Richard Corcoran, as Commissioner of Education, files this Administrative Complaint against MICAH HARRELL. The Petitioner seeks the appropriate disciplinary sanction of the Respondent’s educator’s certificate pursuant to sections 1012.31 5, 1012.795, and 1012,796, Florida Statutes, and pursuant to Rule 6A-10.081, Florida Administrative Code, Principles of Professional Conduct for the Education Profession in Florida, said sanctions specifically set forth in sections 1012.795(1) and 1012.796(7), Florida Statutes. The Petitioner alleges: JURISDICTION 1, The Respondent holds Florida Educator’s Certificate 711488, covering the areas of Guidance and Counseling and Mathematics, which is valid through June 30, 2022. 2, At all times pertinent hereto, the Respondent was employed as a Guidance Counselor at Piper High School in the Broward County School District. MATERIAL ALLEGATIONS 3. During the time period from January 1, 2014, to January 29, 2016, Respondent took part in an elaborate scheme that was created to engage in large scale Medicaid fraud. Respondent, his family members, and other associates created companies that would give the illusion of offering counseling services to disadvantaged students, 4. Respondent and his co-conspirators collected Medicaid billing numbers from students through a faith based organization on the pretext of providing services to students that included but was not limited to help for students who needed a strong male role model in their AC-2 EPCM-4 MICAH HARRELL Administrative Complaint Page 2 of 3 lives, The information collected by Respondent was used by Respondent and by others with his knowledge to fraudulently bill the Medicaid system for services that were never authorized or tendered. A result of Respondent’s conduct was that students were labeled with mental health disorders that they did not have. 5. Respondent used his position as a teacher to further facilitate this fraud. Respondent offered a free after school program addressing tutoring, mentoring, and behavioral problems for the children at Northpark Apartments. Respondent and his associates would have parents complete paper work to participate in the program. Parents were required to provide information including their students’ Medicaid numbers. Respondent would then use the students’ Medicaid numbers to bill Medicaid fraudulently for services that were never provided to the students. 6. On or about April 6, 2017, Respondent was charged with 33 counts of Scheme to Defrand, Medicaid Fraud-False Claims, and Criminal Use of Personal Information Telated to the aforementioned conduct. On or about April 3, 2018, Respondent pled nolo contendere to one count of Scheme to Defraud (more than $20,00, less than $50,000) and adjudication was withheld. The remaining 16 counts of Medicaid Fraud-False Claims and 16 counts of Criminal Use of Personal Information, were nolle prossed. The Petitioner charges: STATUTE VIOLATIONS COUNT 1: The Respondent is in violation of section 1012.795(1)(d), Florida Statutes, in that Respondent has been guilty of gross immorality or an act involving moral turpitude as defined by rule of the State Board of Education. COUNT 2: The Respondent is in violation of section 1012.795(1)(j), Florida Statutes, in that Respondent has violated the Principles of Professional Conduct for the Education Profession prescribed by State Board of Education rules. RULE VIOLATIONS COUNT 3: _ The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(a)1, Florida Administrative Code, in that Respondent has failed to make reasonable effort to protect the student fram conditions harmful to learning and/or to the student’s mental health and/or physical health and/or safety. COUNT 4: _ The allegations of misconduct set forth herein are in violation of Rule GA- 10.081(2}(a)8, Florida Administrative Code, in that Respondent has exploited a relationship with a student for personal gain or advantage. COUNTS: The allegations of misconduct set forth herein are in violation of Rule 6A- 10,081(2)(b)2, Florida Administrative Code, in that Respondent has intentionally distorted or AC-3 EPCM-5 MICAH HARRELL Administrative Complaint Page 3 of 3 misrepresented facts concerning an educational matter in direct or indirect public expression. COUNT 6: The allegations of misconduct set forth herein are in violation of Rule 6A- 10.081(2)(c)1, Florida Administrative Code, in that Respondent has failed to maintain honesty in all professional dealings, COUNT 7: The Respondent is in violation of Rule 6A-10.081(2)(c)8, Florida Adminisirative Code, in that Respondent has submitied fraudulent information on a document in connection with professional activities, WHEREFORE, based on the reasons set forth herein and in accordance with the Explanation of Rights and Election of Rights forms attached to and made a part of this Administrative Complaint, Petitioner respectfully recommends that the Education Practices Commission impose an appropriate sanction against the Respondent’s educator's certificate pursuant to the authority provided in sections 1012.795(1} and 1012.796(7), Florida Statutes. The sanctions imposed by the Education Practices Commission may include, but are not limited to, any one or a combination of the following: issuing the Respondent a written reprimand; placing the Respondent on probation for any period of time; restricting the Respondent's authorized scope of practice; assessing the Respondent an administrative fine; directing the Respondent to enroll in the Recovery Network Program; suspending the Respondent’s educator’s certificate for a period of time not to exceed five years; revoking the Respondent’s educator’s certificate for a period of time up to 10 years or permanently; determining the Respondent to be ineligible for certification; or barring the Respondent from reapplying for an educator’s certificate for a period of time up to 10 years or permanently. EXECUTED on this_31% dayof_July 2019. RICHARD CORCORAN, as Commissioner of Education State of Florida AC-4 EPCM-6

Docket for Case No: 20-000402PL