DEVAL L.  PATRICK
GOVERNOR

JOHN W. POLANOWICZ
SECRETARY
CHERYL BARTLETT, RN
COMMISSIONER

The Commonwealth of Massachusetts Executive Office of Health and Human Services Department of Public Health
Division of Health Professions Licensure
Board of Registration of Physician Assistants 239 Causeway Street, Suite 500, Boston, MA 02114

Tel: 617-973·0806 Fax: 617·973-0980
www.mass.gov/dph/boards/pa

VIA U.S. FIRST CLASS MAIL AND CERTIFIED MAIL# 7014 0510 0001 0375 3784 RETURN RECEIPT REQUESTED.
November 24, 2014 Nicole  Delmonico
Redacted

Dear Ms. Delmonico:

Re:	Board of Registration of Physician Assistants
Docket No. PA-2010-003 License No. PA1933

This letter acknowledges receipt by the Board of Registration of Physician Assistants (Board) of two signed original copies of the Post-Surrender Consent Agreement for Probation (Probation Agreement) between you and the Board in resolution of the above-referenced complaint.  The Board has now signed both original copies of the Probation Agreement, one of which is enclosc9 for your records.   In addition, your license is now active with a Probationary status.

Please note carefully that the effective date of the Probation Agreement is November 21, 2014, as is stated on the signature page of the agreement.  As of the effective date your license is on probation and you must comply with all of the requirements of the Probation Agreement.   It is your responsibility to ensure that the Board receives all required documentation and information by the due dates specified in the Probation Agreement.  The Probation Agreement will remain in effect until you fulfill all of its conditions and the Board gives you written confirmation that your license probation has ended.

In addition, Scott Sherman with the Division of Health Professions Licensure is responsible for monitoring compliance with your agreement.  All correspondence and documentation in connection with your Probation Agreement should be directed to him at the Board's office listed above.  You may also contact him at (617) 973-0828 with any questions regarding this matter.

Sincerely,

Mary Phillips	'
Executive Director
Board of Registration of Physician Assistants

.,...

,.	·.

COMMONWEALTH OF MASSACHUSETTS

SUFFOLK COUNTY

BOARD OF REGISTRATION 

In the Matter of Nicole A. Delmonico License No. PA1933

PHYSICIAN ASSISTANTS	

)
)
)	Docket No. PA 2010-003
)

POST-SURRENDER CONSENT AGREEMENT FOR PROBATION

The Massachusetts Board of Registration of Physician Assistants ("Board") and Nicole A. Delmonico, a Physician Assistant ("PA") formerly licensed by the Board, hereby stipulate and agree that the following information shall be entered into, and become a permanent part of, the Respondent's records maintained by the Board.  For purposes of this Consent Agreement for Probation, the word "license" shall refer to both a current license and to any right to renew an expired license; the word "Respondent" shall refer to Ms. Delmonico.

1.	The Respondent acknowledges that the Board issued to her a license to practice as a Physician Assistant ("PA") in Massachusetts, License No. PA1933, on or about April 25, 2005.	The Respondent further acknowledges that she is also licensed as a Physician Assistant in the states of Florida, License No. PA91 02975, issued on or about September 24, 2004 (expired 1/31/06); Washington, License No. PA10005334, issued on or about December 7, 2007 (expired 6/8/10); and Rhode Island, License No. PA00566, issued on or about November 3, 2010 (expired 6/30111).

2.	The Respondent acknowledges that effective November 19, 2010; she entered into a Voluntary Surrender Agreement with the Board, thereby surrendering her Massachusetts Physician Assistant license, in resolution of a complaint contained in Docket No. PA-
20 10-003 ("the Complaint").  The Respondent acknowledges all facts recited in the
November 19, 2010 Voluntary Surrender Agreement.

3.	The Board and the Respondent acknowledge that the Respondent currently participates in the Massachusetts Professional Recovery System ("MPRS"), that she is currently in compliance with the requirements of that program and that, provided she remains in full compliance for the duration, she is expected to successfully complete that program on or about May 3, 2016.

4.	The Respondent agrees that her PA license shall be placed on PROBATION, for an indefinite period, commencing with the Effective Date of this Agreement and ending when the Respondent can demonstrate that she has successfully completed the MPRS program.

Nicole A. Delmonico, Docket No. AP-2010-00J
Post-Surrender Consent Agreement for Probation	Page 1of4

5.	The Respondent agrees to comply with the following requirements during the probationary period:
a.	Comply with all laws and regulations governing practice as a Physician Assistant in the Commonwealth of Massachusetts
b.	Timely renew her Massachusetts  PA license;
c.	Notify the Board in writing of any change in her mailing address, within ten (10) days of such change;
d.	Comply with all continuing education requirements;
e.	Comply with MPRS program requirements and recommendations of the MPRS monitor;
f.	Refrain from prescribing or dispensing all Massachusetts controlled substances
until such time as the Board modifies this restriction.
1)	The Respondent agrees that this restriction shall remain in place during the first six months of the probationary period and that she may petition the Board for modification of this restriction any time after the first six months have passed.
2.)   The Respondent agrees that the Board may further extend the period of this
Restriction or eliminate this restriction based on its evaluation of her practice and circumstances at the time of any such petition.
g.	Notify the Board of her employment status with respect to any position that requires a PA license. The Respondent agrees to submit a written statement describing
1)	her existing employment status to be submitted within ten (10) days of the
Effective Date of this Agreement;
2)	new employment obtained to be submitted within ten (10) days of obtaining
such employment and the statement shall include the date of hire, the name and address of the employer and the name and license number of all supervising physicians;
3)	termination of employment to be submitted within ten (I 0) days of such
termination and the statement shall include the date of termination, the name and address of the employer, the name and license number of all supervising
physicians and the reason for the termination.
h.	Arrange for all employers and supervising physicians identified in statements as required by paragraph 5(t) to submit, directly to the Board, a letter stating that they have reviewed this Agreement and that they arc aware of the conditions on
her license.
1.	Submit a report to the Board every six months that documents her current place(s) of employment, a copy of her current prescription guidelines, and a log of all prescriptions  issued during the preceding months that   includes (I) the patient's name, (2) the date of the prescription, (3) the name of the drug, (4) the dose, (5)
the quantity, (6) the corresponding diagnosis, (7) the name of the supervising physician, (8) the state where she expects the prescription to be filled.

6.	The Respondent agrees that if she does not comply with the requirements in Paragraph 5, or if the Board opens a Subsequent Complaint whose allegations if true would constitute a violation of Paragraph 5(a), the Board may, upon written notice to the Respondent:
Nicole A. Delmonico, Docket No. AP-2010-003
Post-Surrender Consent Agreement for Probation	Page 2 of4

-	-       --------------------.
,.

a.	EXTEND the probationary period; or
b.	MODIFY the requirements of this Agreement; or
c.	EXTEND the probationary period AND MODIFY the requirements of this Agreement; or
d.	IMMEDIATELY SUSPEND the Respondent's license, or right to renew such license, before adjudication of any of the allegations of noncompliance
that are contested by the Respondent, and such suspension shall remain in effect until final disposition of the matter in accordance with Paragraph
7 below.

7.	If the Board suspends the Respondent's license, or right to renew such license, pursuant to Paragraph 6(d), above, the suspension shall remain in effect until:
a.	the Board and the Respondent sign a subsequent consent agreement in resolution of the Respondent's noncompliance, and any such agreement shall supersede this Agreement; or
b.	the Board issues a final decision and order following adjudication of the
allegations of noncompliance and such final decision and order shall supersede this Agreement.

8.	The Respondent understands and agrees that if her license is suspended by the Board in accordance with Paragraph 8, above, she shall immediately return her license to the Board, by hand or certified mail, whether such license is current or expired.  Upon said suspension, the Respondent agrees that she shall not in any way represent herself as a licensed Physician Assistant in Massachusetts until such time as the Board terminates the suspension of her license or right to renew such license.  Any evidence that the Respondent has represented herself as a Physician Assistant in Massachusetts after the Board has notified the Respondent of her license suspension shall be grounds for further disciplinary action by the Board and the Board's referral of the matter to the appropriate law enforcement authorities for prosecution, as set forth in M.G.L. c. 112, § 65.

9.	The Respondent agrees to submit a written request to the Board for restoration to unrestricted license status within thirty (30) days of her successful completion of the MPRS program.  This request shall be accompanied by documentation from the MPRS monitor corroborating her successful completion and recommending restoration of her license to unrestricted status.  This request shall also be accompanied by documentation from all jurisdictions where the Respondent is licensed or has been licensed to practice as a Physician Assistant that she is in good standing or that her right to renew her license is unrestricted.  The Board shall restore the Respondent's license to unrestricted status if it determines that the Respondent has been compliant with each requirement of this Agreement and that restoration is the best interests of the public health, safety, or welfare.

10.	The effective date of this Consent Agreement ("Effective Date") is the date on which the Board signs this Agreement after receiving two copies of the Agreement signed and dated by the Licensee.

Nicole A. Delmonico, Docket No. AP-2010-00J
Post-Surrender Consent Agreement for Probation	Page J of4

. ·

11.	The Licensee understands that she has the right to consult with legal counsel in connection with her decision to enter into this Agreement and acknowledges that; if she has not used legal counsel, that the decision not to do so has been one taken of her own free will.

12.		The Licensee understands that the probation of her Physician Assistant license as agreed under the terms of this Agreement is a final act and is not subject to reconsideration or judicial review.

1 3.	The Licensee understands that, after its Effective Date, this Agreement constitutes a "public record" within the meaning of M.G.L c. 4, § 7 subject to public disclosure and  that the Board may forward a copy of this Agreement to other licensing boards and/or law enforcement entities, and to any other individual or entity as required by law.

14.	The Licensee certifies that she has read this document entitled "Post-Surrender Probation Agreement."   The Licensee understands that, by executing this Agreement, she is agreeing to the terms and conditions pursuant to which the Board shall reinstate her physician assistant license and place her license on probationary status on the terms and conditions set forth herein.

BY THE LICENSEE:	BY THE BOARD:

Nicole A. Delmonico

Date

Witness (Signature)

Witness (Print Name and Date)

FOR BOARD USE:

Mary Phillips, Executive Director

 	
Effective Date

An original copy of this fully executed Consent Agreement for Probation was sent to
Licensee/Licensee's attorney on by November 24,2014Mail No. 70140510000103753784

Nicole A.   Delmonico,   Docket   No. AP-2010-003
Post-Surrender Consent Agreement for Probation	Page 4 of4

-----------------------

- ------------,

COMMONWEATLH OF MASSACHUSETTS

PHYSCIAN ASSISTANTS

---------

In the :\·[atl\.'r ol
NICOLE ANN DEL lON!CO
Lic nJ-c No . PA 193
(Licen.;c 1-xplr.ttion D.nc 311/11)

Docke t   No. PA-2010-003

VOLUNTARY SURRENDER AGREEMENT

I>-	..	._.	...

The Board of Registration of Physician Assistants (“Board”) and Nicole Ann Delmonico ("the Licensee"). a Physcian Assistant licensed by  the Board (License  No. PA 1933). do hereby stipulate and agree that the  information contained in this Voluntary Surrender Agreement ('Agreement”) ,JJ.tll he cn!l..'l cd into .tnd hccomc .1 perm.1ncnt p.lrt of the ftlc of the Liccn..,cc th.tt "' m.tintaiJh.:d b the Boan.l  h1r the purpose). of thi'i :\g.n:cmcnt. the \HlJU "lkcmc '' shall ref er both to the L1cen'>ce\
.·uncu t  IJ1.·en'e to ptactict: a' .1 Ph ·.JI.'tan ""'' tant in t-.la-;,.ldlll. ctts ami to .lily nJ:.•htto ll.'lll'\\ :-.ulh
IH:Cll \1:,

The I  l<.:cn...ee .llkllO\\ kd g1..':0. that th · Bo.ml "''ued to hc:r a ill'l'll-;t: to pt.ll'tll'l' a' a l'hy'iil'i.m
r  ...,.,t.tllt ( "P:\.) in t-,Ja,,adJ\I<,I.:IlS.  l.!l'\.'Jl<,C Nl) P:\ llJ33. Oil 01 ;thout April 25. :!tlO"i	I h· Li<.:cns1.'1.' f'urlhcr ;H:knowledges that !->he is also hL'cnsed as a Ph si<:ian t\-;..,j..,t,mt 111 th..: ..,t,ttc, ol Florida. l.in:n'ic No. PNJIO:!<J75. i'>sucd on 01 about Sqllcmber 2-l.lllO-t (l'\punl 1/31/0(i); Washington. Lin·ns o.· No. Pt\ 1000533-1. bsucd on or ; huut Dl.'cemhel 7. 2007 (c\pircd 6/l-i/101: .md Rhode lslnnd, License No. Pi\0056(), issuC'd on or about Novemh<:l 1. 20 10 (I.! :X pi rat inn datl' 6/30/1 I l.

l'ltL'  l.il'I..' IISI.'t: hctd))  -;tate.., that  she\ oluutanly cntl.'rs  iuloth :-. At!ll'l'llll'llt  "tth the  Bo;ud  to
,·n f lllll aril y ....IIITL'Illkl h ·r  :vta:-sadntst·tb l'llyski:m t\ssistant  IKt'll"L' Ill the Bo.ud  lllll.''>uht t loll
,,fa l'lllllpl:lillt U llllatn1.·d in Dockl'l No  1\\-2010-003 ("thc( 'ompl alllt")	lh ,·('umpl .unt
·tl k =· .:s. and tit .· I  H..'Cih o'l' :t\.'klll)\\'kdgv•. thl.' follo\\'ing:

(a)	The Lill'll "l.'C was l'mploycd .1'.. a Physician Assist ant in  1.'''-·ldlll,l.'tts at the C.1pc  Cod and lsl;tmls Community l\lenl:ll llealth C .·nter (''Cap1.· Cod and  \land-,   IIIC') 111 Pm:assel. i\·t a-,,a<:husdh, a IJI.'p.utmelll of Mental! kalth  facility.

1h1	Bcginn111g nn nr ahout. :md po -;thly pnor 1<>, Janu:uy 2009, the LH:l'll l·c. u -;mg prl.'scnpt ion p.tds taken  without  authonnnion  from her cmplo er, '"otc presnipt inn -;
!"or CtliH rolkd -;ub:-.t .utn·s. indud 111g Cl.t s llc:ontrolled  uhstam:l· 'uch  " ox ycodt•nc.
nul..; ide her p1 u t' .":ssinnal  pracllll'

1\:j	On 01 ;thout O.:t1>ber 5. 2010. the I    .:cn-;ce left her  .·mpl o nwnt .tt ( .tpe l'ud ami
Islands 1\IIIC  The Lil'l'IIStc cnnliiHii.'d lo writl' prc ;nipltOII'> l'\lr nmtrolkd
!".:11. "h: 1\1111 Iklmnn i1.11
\'nlunt:u   Sullrlllkr t\gt l'l'llll'lll DtJd,l'l N " I'\ 0 I o 11111
l'.l!'l' Ioi I

'>llh-;t.llll'L''>.  lllllllding Cla-;s  II controlkd  substances sud1 a-.; oX)L"tldotlL', w.ing her lortllCI emplo ct .. p1L'Sl'liption  pads until .It least October 21.2010	rhc Buard Ita-; no record  ot' the  LICL'llscc's obtaining a IlL'\\' Supcn ising Physician  follo\\'ing  her
ka vu1g employment at Cape Cod ami lsl.mds f\'IIIC.

(d)	By ll!llcr datcJ November I, 2010. the Licensee informed the Dntg Conuol Program
of the MassadlliSC!IS Department or Public Health that she was 110 longer practicing
in Massachuscns  and requcsw<.l  that  her "medical I iccnse, API   33. and tvlassadmseus Controlled Suh-;tanL·c-; License he updated to rc!kct this changL' in  order to he in cumpltilllL'L'  with all  ntlcs and regulations governing  physician  asshtants.''   On or ahout  November  3, 2010.  the Lin:nsec  was  issued  a license  to pnu.:tiL·e  as a Physicwn Asstst:mt  intlw -.t;llc ul  Rhode Island. l.il.'etl'ie No. P.-\00566.   In L'OilllL'L'tiun \\'tth lu:r kderal controlled  sub:-.tan<.:c  n:gistration  i-;-;ued hy the Drug En!orL'I.'Iltcnt Administration.  the  I  iccnsc ha-.  identified  her current  "rcgistralll  .tddt : s" a-; Wan :n Family Practice  t\1\'iociatcs.Jnc .. S51 t\·lain	Street. Warren. Rl O::?XS5

(C)	In the course of het pwctil:e as a Physki.ttl :\ssistalll at the Cape Cod and Island
!vliiC. the Ltccn ....cc engaged in behaviors that n:suhcJ  in h .·r being dtscJplinL·d  hy
lh:r  .·mployn. ''lud1 JisL·ipline indtHkd hL·r -;uspension from employment.

1	'I IlL· I  IL'l'll'>l'l' adno\\ kdg · that llL'r nlJlduct. a dm:tllllellted in till' Compl.unt and Paragraph
2. ahP\L'. ".tn.Jnt   dJ-,dplmary act ion hy the Board under:

(<t}		26J CoJt: oi ivl.t-.;sadHtSdts Regulations ("CiVIR") 6.02(b) for\ lol.ttll\g any provis1o11 of the laws of the Commonwealth  rd.lling to the authorized  practice: ut  Physkt.m Assistants or any rule or rcgulatiDn adopted thereunder (to wit. !VIassadlllsctts General Laws ("M.G.L."J Chapter LJ4C',the MassadHisetts C'ontrolkd Suh ;tam'l's 1.:1\\, .md regulation-;  promulgJtcd   thereunder) .
(h)	2(1.1 CM R (,02< <.:) and f\1 (I.L. L'.  112. * 61. for eng;tgmg in deLL'it and gross
misnmdtll'l in thl· pract ic .: of her profession  as a Physician Assistant.

(c)		26:1 Civ!R 6.02!dl lor cng.tgi11g in pr.tcticc which is fr.muukntor he)UIId tht: authorized scope of pr,tcticc for a Physiciant\ssistant.
(d)	263 Ctv!R 6.06(j) for violating any provision of M.Ci.l. t'. 112. ** 9C through 91\.  (to
\\'II, M.G.L.c. 112. § 911) 01 any ntk or rcgulallon of the Board (to wit. Board
regulation' l'itcd in Paragr.tphs ·l(a}through (t·). ahmc).

n.c Lh.l.'lbl.'(' lltHkr-.t.llld'> Ihat this .\greemcnt shall be illcorporatcd into the r ·t·ords ror Ihl' I lll'ml'\.' maintained by thl· Bn.ml. The Licensee further tJllderst<HHh that thi-; t\gll'L'IIll'llt lPllst i t Ill'S a "puhliL. ll.'ulld wrthm the 111 \llllllg of M.G.L. c. t. § 7 suhJL'l'l 1<.> publil'
dr-.<.· tos 11 · and that thc Bo.1rd 111ay fol\vard .tcopy oi this Com.en t t\ rl'L'IIlL'III  to other IKt.'ll.'olllg  huards or'·"" cnfotLcmcnt .·ntitiL':-..  or both. as \\ell  as to an) lllhl'J  rndi\'idu.tl  01 entity as n.:quirctl by law.

Nin1lc ,\unl kllll"illlU
Vu unl.lf} Sum:ndl'r  \).!r\.l'IIICIII
Dolkl'l i\••. l't\ :-oto 001
I'.t),!l'      \•I .1

5	Til<.· L1n·usec  un<krstaud-;  that thi-; Voluntary  Su 1n:mkr Agn:emcnt  con'>\ itutcs disciplm:u y
action by the BnarJ .

(l.	The l.lccnscc ngrccs to return to the Bo:utl at 1h office	239 Causeway Stn:ct. Boston.
tvta ......admscl\-; 0211-l. c1thcr by hand or by overnight  mail. two (2) du plicat .' original'> ol this Voluntary  Sun cmkr Agreement  signed  hy the  LK·cn'iec,  \\"itnc..;scd,  and dated  no later til au fiH: { 5) dayo; following I'CI.'cipt  or thi Agreement.

In  ullllll'l1ion  "11h  the  Complaint ,  the  License .·agn:l'S  to  immediate Iy  suncndc1  her cun\l!ll ll·d o.,ub..;tanLC' rcgtstrat ion i'i'iUcd hy the United State..; Drug Enforcement
i\dmll\l'>lrattun  ( "DFA··) to th .· D E .-\ .md  her   ·om rolled   ubo.;t an .:cs  n:gistration   i'i'ilu:d  by th .·
!\lao.,o.,achusc\1"  Department  of  Publtc  I kalth, Drug Control  Program  (''DCP" ), to the  DCP.

!-\ .	Tht· Uoard agree'> that in rcttun for the 1 iccno.,ce·., -.uncnder ul her Physkwn ,\so.;istant lie ·n-.e in conned ion \\'ith the f'at:t<; set fmth in Par.1graph 2 . ahon . a  tii!L·r nee ution ol this
.-\ !,'n ( '/1/ ('Hf and iH retum to the Uoord  11 illlill f n e ( 5) do).\ o(ih IW 'c•ipt, the Board o;hallnot
p n:-.cnll hdi.m: it...df the allegation..; cunt.1ined in the Clllllplaint.

ll	ThL· Ltl'L·ns c :•gtcc.'> to return her litcn-.c tu pra .:tkc as a Physician  Assistant  111
ivl .,.., ad m sc\1-; t n the Board at the lllll l' -.\h.' rc\lllll'i to the Hoard two (2) '>lgncd and d.lled
or 1g.i n.1! l'Opi -. of thh  Voluntary  Sun endcr i\gn.·cmcnt.

10.	The J.kcnscc undcrst.mds and agrees that  the condition'>  for any futun: remstatcmcnt  ol h ·r Physician  1\ssist :tnt  lkensc :-.hallmdudc, hut not he limited to. the Lken-.cc's 1..'\aluatton b) the M:tss.tchu:-.ctt:-.  Professional  Recovery System !"MPRS"), full participation  in the tvli'RS .
.'>liCucssfull'ompletion of tlw MJ>RS. ; swell :t'> meeting any and all Board requirements  lor hu:ml.' tt·mqatL'tllCIII  in dTcct :llth ·timl.' of .my \\Tittcn rcque"t flom the Lil:enscc to the Hn.ud     ftHlicens·ll'ltl.;(.ltl'llll'lll.

I  I		1'1tL'  I Xl'IISl'l' llltdL·rst.md-, and agrc.: .·-;  that thl· L'Ulllll\tnn-; 101 .til)' lut 11lc leinstall'lllcllt ol ltn Physil:ian  A :. istant  lken'>t' may  include, hut  not  he limitl...'d  to, a cornprl'ltcnsi\ e nwntal  hc,tlth e\ a luat ion of the  l.it.:ellsl'l.'  conducted  hy a !\l.t-;-.nchusetts  ltccn!-.ed cli n kal psyrhnlngist  (I'll() or  PsyD  or  EdD) or a  Mass :Khu-.etts  lil"cnscd.  board  certified  p:-. dti,llrist.  which  dinic.tll
ha ed as...c-. mcnt shall alltln.:..;o.,  ar c:1s to he  iJent ifll'd  by the Board .

l	The I .icen-.ee understand!-. and agn.·cs that tht• L'ontlition<; for any fut u re n:instatl.'lllL'Ill of her Phy :-.ieian i\s<>i:::tant  license  hall include, hut not he limited to. tht: Lkcnsc ·s prm·iding don1mentation satisf:ll·tory to the Uoard that any and all niminal ca-.cs brought  against  her h.l\ e b-een cJoq·d before the Board will consider any wrillcn request fwm the Licensee for
l il ense r .·in t atcmcnt.

l .l	The Li<..'Cil'>Cl.! fu11her under-;tands and agree'> that any lutu1c !Jcc!l'>C t l.'lllst:ttcment by the Bo;IJ d may he nmd it inned on hc1 entering into a comcnt agrL·<..·mcnt  with tht..' Board hu  a
pniod ol' I icellSl' probation. the dural ion and term..; or which to be dctetlllincd h) tht' Bll:ll d at
the tune of any lil'cnsc rcinst,ttcmcnt.

Ntu•k Ann Uclmllllt• n
\'.,ltmt:u·) "iun n·kr ,\t•t 'l'lll nt
[)ockl't ;-.!n I'A 20 [I) 00 l
l'ar · \ nl .(

I:L  Th Licensee undcrs!ilnds  and agre s that the  urrcndcr of her Physi<.'J,ll\ A.-;:-.Jstanl  lir cn-;c a -; agn:cd  under the  terms  of  this  Voluntary Surrender Agr em nt  '"a final  act  dcprl\ ing h(.•r of all pri\'ilcg<.·s  of liccnslll'L' as a Physician  t\s-;i'\lant  and is not  suh.Ject  to rccon'\ideration  or
j uJ il..·ial review.

15.	The Lil:cnscc understands and  tgrees that after the Effective Date of tlus Voluntary
Surrender i\greem lll she will not longer he .mthorized to practke as a Physician Assist.mt in
rvtassadlllscl!s. The LicL·n-;cc further umk1 st<mds th:n any pr: .:ticc as a Physician A -.i..,tant afh:r the EffcctJ\'C Date of this Agreement  may he referred hl law cnl or(emcnt  fur applllpll.tlc action. shall constitute adJitional ground-; for complaint again-..t h 1 Ph)siL'tan .'\s..,t-;t,mt
I kcnsc.:. and shall he.: considered hy the Board iu connect ion with any future requc t  lot lkcnsc  reinstatement   by the  Licensee.

1<;.	The Lkenscc states that shl·lwo,; used legal <.'liUnscl in connection \\'ith her dcl'i.,ionto entc1 intP this Voluntary Suncnlkr :\grcemcntur. 1f she did not. th.tt ..;he had an opJH1Jlllllll)' 10 do so and that h..:r dct·i-.tnn Ill enter IIllO till.., .\grecn1en! "'"" tuadc t•f h ·t own fll'l' will.

17	Til · Li · ·	· .· c..:ttJfi .·.; that :-h..: h,,., IL',td thi'> dn .·umcnt cutttkd "Volutll.ll )  uttL'lltkt Agreement."  The LJL'\:IISL!I.' undcr t:uHb th.ll. hy executing tht-.. i\gt..:crncnt. she ts \\.11\ mg hc1 right to a fornwl heating at '' luch she would (1llssess the rights to confront and crus-; l'\,11\\IJ\C witncssl'S. to call witnesses. to pn:scnt cvitknc .·. to testify on hct  ll\\ n behalf. to conte'\1 th : allegations. to present  oral argument. to app :.lltu court  in the 1.'\ eut ot  .111  ad\'crse ruling. and all Qthcr rights set forth in M.G.L. c. 30/\, the Mas achuscl!s Adtllmi lr<lii\ 'C Proc":du1e i\t:t. and SOl  Cl'vlR  l.<ll  et St'tf., th . Standard Ad.tudicatury Rules of Pra .:til:c ami Pron·dure .  the Liccns .:e states th.tt sill! further understands  that  in c\ccuting tlu-.. ducumcnt  cutl!kd "Voluutary Surrender Agreement" she is knowingly  and  voluntartl)  \\,li v ing hL·r  nglll to .1 formal hearing and to alll.>f the ahoH listed right-..

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