STATE OF FLORIDA DEPARTMENT OF HEALTH ... - PsychSearch

STATE OF FLORIDA
DEPARTMENT OF HEALTH
DEPARTMENT OF HEALTH,
Petitioner,
v. CASE NO. 2010-18799
SANDRA J. HARRISON, L.C.S.W.,
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 Clinical
Social Work, Marriage and Family Therapy, and Mental Health Counseling (hereinafter
Board) against Sandra J. Harrison, L.C.S.W., and alleges:
1. Petitioner is the state department charged with regulating the practice of
Clinical Social Work, Marriage and Family Therapy, and Mental Health Counseling
pursuant to section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter
491, Florida Statutes.
2. At all times material to this Complaint, Respondent was a licensed clinical
social worker in the State of Florida, having been issued license number SW 4337 on or
about April 22, 1996.

3. Respondent's address of record is 9290 Via Classico E, Wellington, Florida
33411.
4. Respondent has indicated that her address is actually 9219 Via Classico E,
Wellington, Florida 33411.
5. On or about April 24, 2002, Respondent was licensed by the State of
Nevada Board of Examiners for Social Workers (hereinafter "Nevada Board") as a
licensed clinical social worker and issued license number 4197-C. Respondent was
licensed in Nevada by endorsement based on her Florida licensure as a clinical social
worker.
6. On or about September 23, 2004, the Nevada Board received a complaint
from a representative at NNAMHS, Respondent's employer against Respondent alleging
misconduct as a licensed clinical social worker in Nevada.
7. Based on the allegations received by the Nevada Board on or about
September 34, 2004, the Nevada Board opened case number G04-14 against
Respondent and conducted an investigation.
8. On or about April 24, 2006, the Nevada Board received a complaint from a
former friend or associate of Respondent against Respondent alleging misconduct as a
licensed clinical social worker in Nevada.
9. Based on the allegations received by the Nevada Board on or about April
24, 2006, the Nevada Board opened case number G06-04 against Respondent and
conducted an investigation.

10. On September 30, 2008, Respondent allowed her Nevada license to
practice clinical social work expire.
11. On or about October 9, 2008, Respondent entered into a Consent Decree
with the Nevada Board to resolve case numbers G04-14 and G06-04. The Consent
Decree was effective October 10, 2008.
12. The Consent Decree reflects that the Nevada Board found Respondent's
conduct violated ten (10) provisions of the Nevada Annotated Code (NAC) or rules
governing the practice of clinical social work.
13. The Consent Decree reflects that Respondent was assessed legal and
investigative fees and voluntarily surrendered her license. Respondent was not eligible
to apply for reinstatement of her license for at least one year, and if ever her license is
reinstated in Nevada, it is subject to a host of conditions including up to one year of
probation.
14. The Consent Decree states that at the time it becomes effective, it shall
become a public document "and will be reported to the Disciplinary Action Reporting
System (DARS) of the Association of Social Work Boards (ASWB) or such other national
databases as required by law.
15. Respondent claims she notified the Board that she voluntarily relinquished
her Nevada license to practice clinical social work by letter dated November 9, 2008,
and sent via U.S. mail.
16. The November 9, 2008 letter states in its entirety:
I am writing to notify the Board that I, Sandra Harrison,
LCSW, License #SW4377, had a Social work License in the

State of Florida and Nevada. I now have relocated back to
the State of Florida to take care of a sick family member and
will be staying here. I have let my Nevada SW license expire
and also signed a consent decree voluntarily relinquishing
my license to that state, as I will not be returning threre. I
still have a current license in the State of Florida.
If you have any questions, please call me at [number
omitted].
17. The Board did not receive Respondent's November 9, 2008, letter.
18. Section 491.009(1)(b), Fla. Stat. (2008) provides that "[h]aving a license .
.. to practice a comparable profession revoked, suspended, or otherwise acted against,
including the denial of certification or licensure by another state, territory, or country" is
grounds for discipline by the Board.
19. Section 456.072(1)(f), Fla. Stat. (2008) provides that the Board can
discipline: "Having a license or the authority to practice any regulated profession
revoked, suspended or otherwise acted against, including the denial of licensure, by the
licensing authority of any jurisdiction, including its agencies or subdivisions, for a
violation that would constitute a violation under Florida law. The licensing authority's
acceptance of a relinquishment of licensure, stipulation, consent order, or other
settlement, offered in response to or in anticipation of the filing of charges against the
license, shall be construed as action against the license."
20. Based on the foregoing, Respondent violated sec. 491.009(1)(b) and
456.072(1)(f), Fla. Stat. (2008), when she entered into and the Nevada Board accepted
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
work.
WHEREFORE, the Petitioner respectfully requests that the Board of Clinical Social
Work, Marriage and Family Therapy, and Mental Health Counseling enter an order
imposing one or more of the following penalties: permanent revocation or suspension of
license, restriction of practice, imposition of an administrative fine, issuance of a
reprimand, placement of the Respondent on probation, corrective action, continuing
education and/or any other relief that the Board deems appropriate.
SIGNED this 22-hot day of i—e6aL01,14/ , 2011.
FILED
DEPARTMENT DF HEALTH
DEPUTY CLERK
cuERKAY14,440► nQ
DATE:
a -03 00k1
Laura M. Fullerton Lopez
Assistant General Counsel
Florida Bar Number 093981
Department of Health
Prosecution Services Unit
4052 Bald Cypress Way, Bin C-65
Tallahassee, FL 32399-3265
(850) 245-4640 voice
(850) 245-4682 FAX
PCP: -115971,01/1411 , 2011
PCP Members: ‘-)
Bi,(41-eAr i 04[1/4041 ofivo-

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.
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.