STATE OF FLORIDA BOARD OF PHYSICAL THERAPY PRACTICE DEPARTMENT OF HEALTH, Petitioner, Vv. CASE NO. 2018-07401 PATRICIA A. BROOKS, P.T., Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Physical Therapy Practice (hereinafter Board) against Patricia A. Brooks, P.T., and alleges: 1. Petitioner is the state department charged with regulating the practice of physical therapy pursuant to section 20.43, Florida Statutes; chapter 456, Florida Statutes; and chapter 486, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed physical therapist in the State of Florida, having been issued license number PT 9425. 3. Respondent’s mailing address of record is 605 Chinquapin Road, Monticello, Florida 32344. 4. On or about February 23, 2015, Respondent entered a plea of guilty to driving under the influence in Madison County, Florida, Case No. 2015-CT-5. 5. | Respondent failed to report this plea to the Board in writing within 30 days. 6. Onor about April 6, 2015, Respondent entered into a Five-Year Monitoring Contract (Contract) with Professionals Resource Network (PRN), requiring Respondent to be regularly PEth tested. 7. During the term of the Contract, Respondent expressed to PRN that she was financially unable to continue the required testing. 8. Respondent requested an early termination of the Contract from PRN. 9. PRN required Respondent to undergo an Appropriateness to Exit Evaluation (Evaluation) if she desired to terminate the Contract. 10. Respondent ceased performing the required testing and did not submit to an Evaluation. DOH v. Patricia A. Brooks, P.T. Case No. 2018-07401 Page 2 of 5 11. On or about March 20, 2018, PRN terminated the Contract with Respondent for failure to comply with the terms of the Contract without good cause. COUNT I 12. Petitioner realleges and incorporates paragraphs one through 11 as if fully set forth herein. 13. Section 456.072(1)(x), Florida Statutes (2014), subjects a licensee to discipline for failing to report to the board, or the department if there is no board, in writing within 30 days after the licensee has been convicted or found guilty of, or entered a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction. 14. Respondent failed to report her February 23, 2015, guilty plea to driving under the influence to the Board in writing within 30 days. 15. Based on the foregoing, Respondent violated section 456.072(1)(x). COUNT It 16. Petitioner realleges and incorporates paragraphs one through 11 as if fully set forth herein. DOH v. Patricia A. Brooks, P.T. Case No. 2018-07401 Page 3 of 5 17. Section 456.072(1)(hh), Florida Statutes (2017), subjects a licensee to discipline for being terminated from an impaired practitioner program that is overseen by a consultant as described in s. 456.076, for failure to comply, without good cause, with the terms of the monitoring or participant contract entered into by the licensee, or for not successfully completing any drug treatment or alcohol treatment program. 18. Respondent was terminated from PRN for failing to comply with the terms of the Contract without good cause. 19. Based on the foregoing, Respondent violated section 456.072(1)(hh). WHEREFORE, Petitioner respectfully requests that the Board enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. [SIGNATURE PAGE TO FOLLOW] DOH v. Patricia A. Brooks, P.T, Case No. 2018-07401 Page 4 of 5 SIGNED this 16th day of June, 2020. Scott A. Rivkees, MD i { Wen General Christina Arzillo Shideler iF { '' E D> Assistant General Counsel DEPARTMENT oe HEALTH DOH Prosecution Services Unit DE 4052 Bald Cypress Way, Bin C-65 CLERK: rene Word Tallahassee, FL 32399-3265 DATE: JUN 1.7 2029 Florida Bar # 90869 (850) 558-9844 (850) 245-4684 FAX Christina.Shideler@flhealth.gov PCP: 6.16.20 PCP Members: Pabian, Watson & Bumgarner DOH v. Patricia A. Brooks, P.T. Case No. 2018-07401 Page 5 of 5 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106,.2015(5), Florida Administrative Code. Please be advised that mediation under Section 120.573, Florida Statutes, is not available for administrative disputes involving this agency action. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. DOH v. Patricia A. Brooks, P.T. Case No. 2018-07401 Page 6 of 5

Docket for Case No: 20-005348PL