STATE OF FLORIDA DEPARTMENT OF HEALTH ... - PsychSearch
STATE OF FLORIDA DEPARTMENT OF HEALTH ... - PsychSearch
STATE OF FLORIDA DEPARTMENT OF HEALTH ... - PsychSearch
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<strong>STATE</strong> <strong>OF</strong> <strong>FLORIDA</strong><br />
<strong>DEPARTMENT</strong> <strong>OF</strong> <strong>HEALTH</strong><br />
<strong>DEPARTMENT</strong> <strong>OF</strong> <strong>HEALTH</strong>,<br />
Petitioner,<br />
v. CASE NO. 2010-18799<br />
SANDRA J. HARRISON, L.C.S.W.,<br />
Respondent.<br />
ADMINISTRATIVE COMPLAINT<br />
COMES NOW the Petitioner, Department of Health, by and through its<br />
undersigned counsel, and files this Administrative Complaint before the Board of Clinical<br />
Social Work, Marriage and Family Therapy, and Mental Health Counseling (hereinafter<br />
Board) against Sandra J. Harrison, L.C.S.W., and alleges:<br />
1. Petitioner is the state department charged with regulating the practice of<br />
Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling<br />
pursuant to section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter<br />
491, Florida Statutes.<br />
2. At all times material to this Complaint, Respondent was a licensed clinical<br />
social worker in the State of Florida, having been issued license number SW 4337 on or<br />
about April 22, 1996.
3. Respondent's address of record is 9290 Via Classico E, Wellington, Florida<br />
33411.<br />
4. Respondent has indicated that her address is actually 9219 Via Classico E,<br />
Wellington, Florida 33411.<br />
5. On or about April 24, 2002, Respondent was licensed by the State of<br />
Nevada Board of Examiners for Social Workers (hereinafter "Nevada Board") as a<br />
licensed clinical social worker and issued license number 4197-C. Respondent was<br />
licensed in Nevada by endorsement based on her Florida licensure as a clinical social<br />
worker.<br />
6. On or about September 23, 2004, the Nevada Board received a complaint<br />
from a representative at NNAMHS, Respondent's employer against Respondent alleging<br />
misconduct as a licensed clinical social worker in Nevada.<br />
7. Based on the allegations received by the Nevada Board on or about<br />
September 34, 2004, the Nevada Board opened case number G04-14 against<br />
Respondent and conducted an investigation.<br />
8. On or about April 24, 2006, the Nevada Board received a complaint from a<br />
former friend or associate of Respondent against Respondent alleging misconduct as a<br />
licensed clinical social worker in Nevada.<br />
9. Based on the allegations received by the Nevada Board on or about April<br />
24, 2006, the Nevada Board opened case number G06-04 against Respondent and<br />
conducted an investigation.
10. On September 30, 2008, Respondent allowed her Nevada license to<br />
practice clinical social work expire.<br />
11. On or about October 9, 2008, Respondent entered into a Consent Decree<br />
with the Nevada Board to resolve case numbers G04-14 and G06-04. The Consent<br />
Decree was effective October 10, 2008.<br />
12. The Consent Decree reflects that the Nevada Board found Respondent's<br />
conduct violated ten (10) provisions of the Nevada Annotated Code (NAC) or rules<br />
governing the practice of clinical social work.<br />
13. The Consent Decree reflects that Respondent was assessed legal and<br />
investigative fees and voluntarily surrendered her license. Respondent was not eligible<br />
to apply for reinstatement of her license for at least one year, and if ever her license is<br />
reinstated in Nevada, it is subject to a host of conditions including up to one year of<br />
probation.<br />
14. The Consent Decree states that at the time it becomes effective, it shall<br />
become a public document "and will be reported to the Disciplinary Action Reporting<br />
System (DARS) of the Association of Social Work Boards (ASWB) or such other national<br />
databases as required by law.<br />
15. Respondent claims she notified the Board that she voluntarily relinquished<br />
her Nevada license to practice clinical social work by letter dated November 9, 2008,<br />
and sent via U.S. mail.<br />
16. The November 9, 2008 letter states in its entirety:<br />
I am writing to notify the Board that I, Sandra Harrison,<br />
LCSW, License #SW4377, had a Social work License in the
State of Florida and Nevada. I now have relocated back to<br />
the State of Florida to take care of a sick family member and<br />
will be staying here. I have let my Nevada SW license expire<br />
and also signed a consent decree voluntarily relinquishing<br />
my license to that state, as I will not be returning threre. I<br />
still have a current license in the State of Florida.<br />
If you have any questions, please call me at [number<br />
omitted].<br />
17. The Board did not receive Respondent's November 9, 2008, letter.<br />
18. Section 491.009(1)(b), Fla. Stat. (2008) provides that "[h]aving a license .<br />
.. to practice a comparable profession revoked, suspended, or otherwise acted against,<br />
including the denial of certification or licensure by another state, territory, or country" is<br />
grounds for discipline by the Board.<br />
19. Section 456.072(1)(f), Fla. Stat. (2008) provides that the Board can<br />
discipline: "Having a license or the authority to practice any regulated profession<br />
revoked, suspended or otherwise acted against, including the denial of licensure, by the<br />
licensing authority of any jurisdiction, including its agencies or subdivisions, for a<br />
violation that would constitute a violation under Florida law. The licensing authority's<br />
acceptance of a relinquishment of licensure, stipulation, consent order, or other<br />
settlement, offered in response to or in anticipation of the filing of charges against the<br />
license, shall be construed as action against the license."<br />
20. Based on the foregoing, Respondent violated sec. 491.009(1)(b) and<br />
456.072(1)(f), Fla. Stat. (2008), when she entered into and the Nevada Board accepted<br />
the Consent Decree in resolution of case numbers G04-14 and G06-04, and the Nevada
Board thereby took action against Respondent's Nevada license to practice clinical social<br />
work.<br />
WHEREFORE, the Petitioner respectfully requests that the Board of Clinical Social<br />
Work, Marriage and Family Therapy, and Mental Health Counseling enter an order<br />
imposing one or more of the following penalties: permanent revocation or suspension of<br />
license, restriction of practice, imposition of an administrative fine, issuance of a<br />
reprimand, placement of the Respondent on probation, corrective action, continuing<br />
education and/or any other relief that the Board deems appropriate.<br />
SIGNED this 22-hot day of i—e6aL01,14/ , 2011.<br />
FILED<br />
<strong>DEPARTMENT</strong> DF <strong>HEALTH</strong><br />
DEPUTY CLERK<br />
cuERKAY14,440► nQ<br />
DATE:<br />
a -03 00k1<br />
Laura M. Fullerton Lopez<br />
Assistant General Counsel<br />
Florida Bar Number 093981<br />
Department of Health<br />
Prosecution Services Unit<br />
4052 Bald Cypress Way, Bin C-65<br />
Tallahassee, FL 32399-3265<br />
(850) 245-4640 voice<br />
(850) 245-4682 FAX<br />
PCP: -115971,01/1411 , 2011<br />
PCP Members: ‘-)<br />
Bi,(41-eAr i 04[1/4041 ofivo-
NOTICE <strong>OF</strong> RIGHTS<br />
Respondent has the right to request a hearing to be conducted<br />
in accordance with Section 120.569 and 120.57, Florida Statutes, to<br />
be represented by counsel or other qualified representative, to<br />
present evidence and argument, to call and cross-examine<br />
witnesses and to have subpoena and subpoena duces tecum issued<br />
on his or her behalf if a hearing is requested.<br />
NOTICE REGARDING ASSESSMENT <strong>OF</strong> COSTS<br />
Respondent is placed on notice that Petitioner has incurred<br />
costs related to the investigation and prosecution of this matter.<br />
Pursuant to Section 456.072(4), Florida Statutes, the Board shall<br />
assess costs related to the investigation and prosecution of a<br />
disciplinary matter, which may include attorney hours and costs,<br />
on the Respondent in addition to any other discipline imposed.