Joanne Almeida

Preliminary Matters

Announcement regarding lack of conflict

1. Prior to the commencement of the hearing, the Registrant Panellist brought the HCPC’s attention to the fact that between 2013 and 2016 he was academic director of a Clinical Psychology course provided by the University of Birmingham, which the Registrant attended, albeit that he had no recollection of her. The Registrant had been alerted to this disclosure and had confirmed in writing that whilst she had attended lectures given by the Registrant Panellist, she had not been taught by him in a 1:1 setting, she had had no contact with him since 2016, and she had no objection to his attendance at the hearing in his capacity as panellist.

2. This was aired at the commencement of the hearing. The Registrant Panellist did not consider himself to be conflicted, nor did the other Panellists the Registrant’s representative confirmed that there remained no objection to his sitting on the Panel.

Application to hear part of the Allegation in private

3. Ms Stevens asked for parts of the hearing and/or written decision to remain in private [Redacted].

4. Ms Collins did not oppose this application.

5. The Panel accepted the advice of the Legal Assessor, which included reference to Rule 10(1)(a) of the Health Professions Council (Conduct and Competence Committee)(Procedure) Rules 2003 as amended ('the Rules') which states that:

“the proceedings shall be held in public unless the Committee is satisfied that, in the interests of justice or for the protection of the private life of the registrant, the complainant, any person giving evidence or of any patient or client, the public should be excluded from all or part of the hearing”.

6. The Panel concluded that any parts of the hearing [Redacted] should remain in private. [Redacted].

Allegation in unamended form

As a registered Practitioner Psychologist (PYL33670), your fitness to practise is impaired by reason of your misconduct in that:

1. You failed to maintain appropriate professional boundaries with Service User A, in that:

a. On more than one occasion between September 2021 and November 2022, during Service User A's therapy you provided information about your personal life; and/or

b. On an unknown date in December 2021, you went to Service User A's house in a personal capacity, with a minor; and/or

c. Between September 2021 and November 2022, you sent messages to Service User A, including those set out in Schedule A which were:

i. Inappropriate; and/or
ii. Of a sexual nature.

d. On or around 17 February 2022, you had sexual intercourse with Service User A at their address; and/or

e. On an unknown date in March 2022, you had sexual intercourse with Service User A [Redacted]; and/or

f. On an unknown date between February and March 2022, you attended the park with Service User A with a minor.

2. You consumed a Class B drug, in that on an unknown date in March 2022, you smoked Cannabis in the presence of the Complainant.

3. Between 01 April 2022 and 16 November 2022, you failed to submit an ADHD assessment completed by Service User A in a timely manner.

4. Your conduct in relation to Particular 1 was sexually motivated.

5. The matters set out in Particulars 1, 2, 3 and 4 above constitute misconduct.

6. By reason of the matters set out above, your fitness to practise is impaired by reason of misconduct.

Schedule A

GS/01 (Pictures sent to Service User A)

1. A picture of the Registrant holding a wine glass

2. A picture of the Registrant's garden

GS/04 (Text messages sent to Service User A)

1. “Can't stop what you feel” 22 September 2022

2. “You haven't replied to my messages for months so I don't bother messaging you anymore" undated

3. “Think I sent you a photo of something I cooked the other week and a photo of something else a few weeks ago." Undated

4. “But I send communication via email or ther wise you don't reply" undated

5. “Hope that answers your questions.” Undated

6. “Morning Service A … Best Wishes, Jo xx" Undated

7. “Service A, if you take this any further then I Will loose everything. My family, my work, my profession, my mental health my ability to earn money. It will leave me at rockbottom and will be the one that suffers. I'm begging you not to do this. If you value me at all and how much I have tried to help you, you won't. If you go forward and provide more information then I will just have to tell the truth, but it will come at the cost of everything I have and worked hard for, and it will be on my and your shoulders” Undated.

8. "I understand that you feel this way and please go ahead and make a complaint about it. I will answer everything honestly but if you say anything about a sexual relationship, then I will be struck off and permanently unable to work as a psychologist. That's 9 years of study and graft down the drain and a family shattered. I will never trust another person again so your trauma legacy will live on. Such lengths you will go to make sure you get what you want? You are no friend of mine" Undated.

9. "I'm not playing a guilt trip I am genuinely angry and distraught that I got sucked in by your promises of trust and support and the fact that after everything you would do this to me. Shame on you. Don't contact me again." Undated

SG/01

1. "Exactly, I'm sure next time we will be less anxious x" Undated

2. "[Kissing face emoji]" Undated

3. “That's mean! At least I had a shower before he went there" Undated

4. "What do you mean mean [furrowed eyebrows wearing a monocle emoji]" undated

5. "Never mind. Just getting from nursery now x" Undated

6. "I only fucked him once today for the first time. …" Undated

7. "Oh no, sorry for you guys, is she in a lot of pain?" Undated

8. "Thank you, thank you so much but I'll hang on until I can." Undated

Application to amend the Allegation

7. Ms Collins applied to amend the dates of Particulars 1(a) and (c). She explained that this was in response to written submissions that had been sent in by the Registrant in advance of the hearing. Ms Collins explained that the original date range had been wide to ensure that all relevant dates were covered, but that the suggested amendment did not alter the nature of the relevant Particulars.

8. Ms Stevens supported this application.

9. The Panel accepted the advice of the Legal Assessor.

10. The Panel decided to allow the proposed amendments on the basis that they provided greater clarity, but did not alter the substance of the Allegation or cause prejudice to the Registrant.

Application to discontinue part of the Allegation

11. Ms Collins applied to discontinue part of the Allegation, namely the text messages numbered at 1, 2, 3, 4 and 5, exhibited in GS/04, set out in the Unamended Allegation above. She explained that this application was made in response to representations made by the Registrant that these texts had been sent by Service User A to her and not vice versa. Ms Collins submitted that rather than calling evidence to explore this issue, the decision had been reached to apply for discontinuance as it was not proportionate to call Service User A on this discrete point.

12. Ms Stevens supported this application.

13. The Panel accepted the advice of the Legal Assessor.

14. The Panel decided to allow the application. The Panel agreed that it would be disproportionate for Service User A to be called to give evidence on an area of the case that was of minimal importance given the other far more serious Particulars set out in the Allegation.

15. It was not submitted on behalf of the Registrant that a different panel should be constituted to continue with the hearing, and the Panel was able to put out of its mind, the matters that had been discontinued when moving forward with the hearing.

Background

16. At the relevant time, the Registrant worked in the role of Highly Specialist Clinical Psychologist with Derbyshire Healthcare NHS Foundation Trust ('the Trust'). She had been employed by the Trust since 10 October 2016. In her role she provided psychology for adults as part of the Community Mental Health Team, which is a secondary service, treating people’s needs that cannot be dealt with at a primary level.

17. As part of this role the Registrant was employed to provide psychological assistance to Service User A. The Registrant first assessed Service User A in September 2018. The recommendation from this assessment was a phased therapy approach for trauma, starting with models such as compassion-based therapy and Eye Movement Desensitisation and Reprocessing (EMDR).

18. On 16 November 2022 the Trust received an incident form from the Registrant, stating that Service User A had become aggressive during a therapy session, and that as a result she had ended the session. The Registrant sent a discharge letter on 17 November 2022. Service User A then called the Trust to make a complaint, saying that his therapy had ended due to the cessation of a sexual relationship that had existed between him and the Registrant.

19. In the course of a fact-finding meeting held by the Trust on 22 November 2022, Service User A reported that he had completed an ADHD assessment at the request of the Registrant, but that she had not submitted it. The Trust was of the view that this would have caused a delay of several months, thereby increasing the potential harm to Service User A, in that he may have required medication or management plans, which Service User A did not receive.

20. In a formal statement taken in connection with the Trust investigation, dated 29 November 2022, the Registrant stated that Service User A, over the course of the additional 16 sessions that had been agreed, had demonstrated increasingly inappropriate behaviour.

21. On 29 November 2022, a further fact-finding meeting was held by the Trust, in which the Registrant admitted that the complaint made by Service User A was not malicious.

22. The Trust then commenced a formal investigation. The terms of reference were read to the Registrant on 7 December 2022. On 8 December 2022 the Registrant left on sick leave, [Redacted].

23. There was a review of Service User A’s care on 9 February 2023, where it was recommended that Cognitive Behavioural Therapy be used to target processed trauma, emotional dysregulation and dependency problems. There was also a recommendation to continue EMDR to address past traumas.

24. The HCPC Allegation is that the Registrant:

- failed to maintain appropriate professional boundaries by:

(a) providing information about her personal life to Service User A on more than one occasion whilst providing therapy for him, [Redacted];

(b) visiting Service User A’s house in a personal capacity [Redacted];

(c) sending messages to Service User A that were of a sexual nature and/or inappropriate in that they attempted to put pressure on Service User A not to report her for her actions;

(d) having sexual intercourse with Service User A at his address;

(e) having sexual intercourse with Service User A at [Redacted];

(f) attending a park with Service User A [Redacted].

- Consumed Cannabis in the presence of Service User A.

- Failed to submit an ADHD assessment completed by Service User A.

Admissions

25. In the presence of her legal representatives, the Registrant admitted the entirety of the factual allegations in their amended form.

26. Following advice from the Legal Assessor, the Chair announced that Particulars 1, 2, 3 and 4 were proved on the basis of those Admissions

Decision on Ground

27. Ms Collins submitted that the matters found proved amounted to breaches of the ‘HCPC Standards of Conduct, Performance and Ethics’ (January 2016) and the ‘Standards of Proficiency for Practitioner Psychologists’, effective from 1 July 2015 until September 2023.

28. Ms Collins submitted that the matters found proved were serious and amounted to misconduct.

29. Ms Stevens accepted, on behalf of the Registrant, that the matters found proved amounted to misconduct.

30. The Panel accepted the advice of the Legal Assessor.

31. The Panel concluded that the Registrant’s behaviour, as admitted by her, amounted to a serious departure from the standards to be expected of a Clinical Psychologist. Whilst providing therapy for Service User A, she had failed to maintain appropriate professional boundaries, by providing information about her personal life to Service User A on more than one occasion, by visiting his house in a personal capacity [Redacted], by sending messages to Service User A that were of a sexual nature and/or inappropriate in that they attempted to put pressure on Service User A not to report her for her actions, by having sexual intercourse with Service User A on two occasions, and by attending a park with Service User A [Redacted]. Further, she had consumed Cannabis in the presence of Service User A, and she had failed to submit an ADHD assessment completed by Service User A. It was the judgement of the Panel that the behaviour was extremely serious and clearly amounted to misconduct.

Decision on Impairment

32. Ms Collins submitted that the Registrant’s fitness to practice is currently impaired, both on the personal and public component, by reason of her misconduct, in light of the seriousness of the matters admitted, together with the lack of appropriate remediation and insight demonstrated by the Registrant.

33. Ms Stevens submitted that the Registrant accepts that if permitted to return to practice at the current time she would require intensive supervision, robust support networks and therapy, and would need to undertake professional development. Ms Stevens submitted that the Registrant accepts that there is an aspect of public confidence. Ms Stephens submitted that the Registrant accepts that her fitness to practise is currently impaired in the circumstances.

34. The Panel accepted the advice of the Legal Assessor.

35. In considering the issue of current impairment of fitness practice, the Panel took account of the Registrant’s previous good character and the four references submitted by her attesting to her character, provided by two friends who are clinical psychologists, [Redacted].

36. The Panel also took account of a detailed document written by the Registrant regarding her misconduct.

37. The Panel concluded that the Registrant’s misconduct was difficult to remediate in that it relates to behavioural misconduct of a very serious nature. The Registrant’s behaviour included indulging in sexual intercourse with a vulnerable service user who was suffering mental health issues, smoking illicit drugs in his presence, attempting to prevent that service user from reporting her, and failing to submit his ADHD assessment.

38. Whilst the Panel accepted that the Registrant had a previously unblemished career, the Panel concluded that the Registrant’s behaviour in relation to Service User A could not be regarded as an isolated event in that it had spanned a considerable period of time.

39. The Panel considered with care the document that the Registrant had compiled dealing with her misconduct and concluded that this had the flavour of an academic thesis rather than a genuine expression of remorse. The content of the essay suggested that the Registrant had personally distanced herself from her actions. The Registrant had written an essay containing the theoretical aspects of what she had done but appeared at times to be on the verge of blaming Service User A for what had taken place. Whilst saying that she does not seek to make excuses for her actions, she had not taken ownership of the problem. It was the judgement of the Panel that this document demonstrated very little insight into the potential harm that she had caused to Service User A by reason of her actions, for example the potential harm resulting from the breakdown of their relationship and the cessation of therapy provided by her, and the possibility that Service User A would be reluctant to seek psychological help in the future.

40. In the circumstances, the Panel concluded that it could not be said that if permitted to practise unrestricted, the risk that the Registrant would repeat her misconduct, and thereby pose a risk of causing similar harm to service users in future, was low.

41. Accordingly, it was the judgement of the Panel that the Registrant’s fitness to practise is currently impaired on the personal component.

42. The Panel concluded that the Registrant had breached a fundamental tenet of the profession and had brought the profession into disrepute by reason of her misconduct. She had indulged in sexual behaviour on more than one occasion with a service user, had smoked illicit drugs with him and had then sought to put pressure on him not to report her for her actions.

43. The Panel concluded that a fellow member of the profession would regard the Registrant’s misconduct as deplorable. The Panel took the view that a member of the public would be horrified about what she had done.

44. The Panel had no doubt that confidence in the profession and its regulator, and maintenance of standards within the profession, would be adversely affected if a finding of impairment were not made in those circumstances.

45. Accordingly, the Panel concluded that the Registrant’s fitness to practise is also currently impaired on the public component.

Decision on Sanction

46. Ms Collins submitted that the following aggravating factors were present:

• There was a pattern of inappropriate behaviour, in that: sexual intercourse with Service User A took place on two occasions; inappropriate and unprofessional messages were sent over a period of months; meeting for personal social events [Redacted] took place twice; consuming Cannabis in Service User A’s presence and failing to submit an ADHD assessment on the service user’s behalf took place once.

• The misconduct only came to light as a result of Service User A’s complaint.

• The Registrant tried to discourage Service User A from making full disclosure of the extent of her misconduct.

• The misconduct took place both inside and outside of her employment as a psychologist.

• Service User A was extremely vulnerable at the material time given his traumatic background of abuse and mental health.

• The harm/risk of harm was serious.

• There was a power imbalance between the Registrant and Service User A due to their relationship of Psychologist and patient.

• The Registrant had failed to recognise warning signs and seek support.

• There was an overlap between the personal relationship and provision of treatment.

47. Ms Collins submitted that the Registrant’s previous good character is a mitigating factor.

48. Ms Collins submitted that sanction was a matter for the judgement of the Panel. She urged the Panel to consult the ‘HCPC’s Sanctions Policy’, including the sections entitled ‘Abuse of Professional Position’ and ‘Sexual Misconduct’.

49. Ms Collins reminded the Panel of the passage in the Sanctions Policy which states:

“There are some concerns which are so serious, that activities intended to remediate the concern cannot sufficiently reduce the risk to the public or public confidence. Despite the steps the Registrant has taken to attempt to remediate the concern, the panel is still likely to impose a serious sanction. These might include cases involving:

...abuse of professional position, including vulnerability (paragraphs 67-75 of policy) or sexual misconduct (Paragraphs 76-77 of policy)”.

50. Ms Collins submitted that the Panel may think the concerns are so serious they cannot be remediated.

51. Ms Collins submitted that the Panel had been made aware of some remediation by the Registrant since her conduct in May 2021/2022, namely personal reflection, reading and counselling. Ms Collins submitted that the Panel may feel this has gone some way to remediate the misconduct but there is more to be done in terms of education on behavioural issues, supervision or personal reflection.

52. Ms Stevens submitted that the Registrant accepts her practice is currently impaired, and does not intend to work in the psychological profession, as a practising psychologist or otherwise, for some time. However, the Registrant does hope to be able to review this at some point.

53. Ms Stevens did not advocate any particular sanction on behalf of the Registrant, but submitted that the Registrant wished the Panel to take note and give due consideration to the following mitigating factors:

a. Admissions: the Registrant, within the Notice to Admit and this hearing, had admitted both misconduct and impairment.

b. Health concerns/difficulties: [Redacted]

c. It also occurred at a time of significant pressure in the Registrant’s personal life, [Redacted].

d. [Redacted].

e. Inadequate supervision, intensive work pressures: Ms Stevens submitted that for a large proportion of the Registrant’s work with Service User A, she was without regular or adequate supervision within a service which was under pressure from external and internal factors. She was in turn subjected to pressure in her work, by the service.

f. Unblemished previous professional history: Prior to her misconduct, the Registrant had worked as a practising psychologist for 5 years with an unblemished professional record.

g. Testimonials: Ms Stevens asked the Panel to consider in particular the following testimonials within the bundle:

i. [Redacted]
ii. The character reference from a fellow Clinical Psychologist, who is a friend of the Registrant, Dr C M
iii. The character reference from a fellow Clinical Psychologist, who is a friend of the Registrant, Dr E W.

54. Ms Stevens submitted that it would be proper for the Panel to take into account the 2 year interim suspension period that had been imposed. She submitted that this suspension had had a significant financial and emotional impact on the Registrant, [Redacted].

55. The Panel accepted the advice of the Legal Assessor.

56. The Panel understood that the purpose of sanction is not to be punitive but is to protect the public and the wider public interest, which includes the maintenance of public confidence in the profession and declaring and upholding proper standards of conduct and behaviour.

57. The Panel took account of the ‘HCPC’s Sanctions Policy’. It applied the principle of proportionality, weighing the Registrant’s interests against the need to protect the public and the wider public interest. It considered the least restrictive sanction first.

58. The Panel regarded the following as mitigating factors:

• the Registrant’s hitherto unblemished career, and her previous good character, as supported by her testimonials.

• the Registrant’s early indication that she would be admitting the Allegation, followed by her Admissions at the commencement of this hearing.

59. The Panel regarded the following as aggravating factors:

• The conduct spanned some 4 months, from December 2021 to April 2022, and continued until November 2022 in relation to the failure to submit the ADHD assessment.

• The conduct only came to light after Service User A raised it, and the Registrant had by then attempted to persuade him not to do so.

• There was an imbalance of power in that the Registrant’s role with the Trust involved providing professional treatment for Service User A, who was a vulnerable service user with mental health issues.

• The misconduct took place whilst Service User A was on the Registrant’s case load.

60. The Panel considered with care the 4 testimonials provided in support of the Registrant’s case, namely:

a. [Redacted]

b. The letter from Dr C M, Principal Clinical Psychologist and friend of the Registrant, who spoke of the workplace stress the Registrant had complained about to her, stemming from the chronic recruitment difficulties, inadequate staffing levels and the inadequate supervision she received.

c. The letter from Dr EW, a Clinical Psychologist and friend of the Registrant, who spoke of the regret and remorse expressed to her by the Registrant about her behaviour.

d. [Redacted]

61. When reaching its decision, the Panel took account of the Registrant’s [Redacted] and stressful workplace conditions that she was undergoing at the time of the misconduct. However the Panel concluded that these factors did not mitigate her misconduct in having sexual intercourse with a vulnerable service user, taking Cannabis in his presence and attempting to persuade him not to report her for her behaviour after the event.

62. The Panel took into account the essay provided by the Registrant, expressing her thoughts about her misconduct, together with the reading that she had completed by way of attempted remediation [Redacted].

63. However the Panel concluded that the Registrant had not remediated her misconduct. As set out in its decision on Impairment, the Panel concluded that the Registrant had demonstrated very little insight into the potential harm that she had caused to Service User A by reason of her actions. Whilst she had admitted the Allegation in full, and had not sought to excuse her actions, the essay that she had written for the benefit of the Panel seemed at times to place blame at the door of Service User A, and to personally distance her from her actions.

64. In view of the nature of the misconduct, namely sexual behaviour and abuse of trust, the Panel concluded that to take no further action or to impose a Caution Order would be insufficient to protect the public, or to maintain standards and uphold confidence in the profession and the regulatory process. In considering the criteria set out in the ‘HCPC’s Sanctions Policy’, the Panel concluded that it could not be said that the misconduct was isolated, limited or minor in nature, that the risk of recurrence was low, that the Registrant had shown good insight, or that she had undertaken appropriate remediation.

65. The Panel considered a Conditions of Practice Order but concluded that conditions would not be sufficient in light of the nature and seriousness of the misconduct. Further they would not be workable in light of the behavioural nature of the misconduct [Redacted].

66. The Panel considered a Suspension Order but concluded that this would be insufficient to protect the public from the risk of future harm in light of the very limited remediation and insight demonstrated by the Registrant into the effect of her behaviour on Service User A. In those circumstances the Panel concluded that it could not be said that the Registrant was unlikely to repeat her misconduct if permitted to practice unrestricted following a period of suspension. There was no evidence before the Panel to show that the Registrant was likely to be able to resolve or remedy her failings. The Panel also concluded that such a sanction would be insufficient to uphold public confidence in the profession, and in the regulatory process.

67. The Panel considered a Striking Off Order.

68. The Panel took account of the ‘HCPC’s Sanctions Policy’, which suggests that such an order is a sanction of last resort for serious, persistent, deliberate or reckless acts involving a number of specified types of misconduct. The types of misconduct specified include sexual misconduct and abuse of a professional position, including vulnerability, both of which apply to this case. The Panel concluded that the misconduct in this case was serious, persistent and deliberate. The Sanctions Policy also suggests that a Striking Off Order is likely to be applicable where the Registrant lacks insight, continues to repeat the misconduct, and is unwilling to resolve matters. The Panel concluded that the Registrant lacks genuine insight, and continued with her misconduct over a period of months. She has expressed a willingness to resolve matters in the sense that she admitted the Allegation at an early stage of the regulatory process after she had been reported by Service User A and has engaged with the regulatory process ever since. However, she currently appears to be unable to demonstrate a genuine willingness to resolve issues in question, in that she has not provided evidence of relevant remediation, including evidence of genuine insight into the effect of her actions on Service User A. Further, the Panel concluded that the Registrant’s misconduct fell within Paragraph 40 of the Sanctions Policy, which states that there are some concerns that are so serious that activities intended to remediate the concern cannot sufficiently reduce the risk to the public or public confidence in the profession.

69. The ‘HCPC’s Sanctions Policy’ suggests that a Striking Off Order is likely to be appropriate where the nature and gravity of the concerns are such that any lesser sanction would be insufficient to protect the public, public confidence in the profession, and public confidence in the regulatory process. The Panel concluded that this applied to the current case.

70. In reaching its conclusion the Panel took account of the significant, adverse, financial and reputational consequences that such an order would be likely to have for the Registrant. The Panel also took account of the fact that the Registrant had already been subject to a 2 year HCPC Interim Suspension Order. However, the Panel concluded that the Registrant had brought these matters on herself. The Panel appreciated that the Registrant had reported experiencing issues with her health at the relevant time, [Redacted]. However this in no way excused her decision to attend a vulnerable service user’s home in a personal capacity, send him messages of a sexual nature, have sexual intercourse with him at his address, have sexual intercourse with him [Redacted] address, meet with him in a public place [Redacted], smoke a Class B drug in his presence, fail to submit an ADHD assessment completed by him, and finally, try to persuade him not to bring these matters to the attention of the relevant authorities when it appeared that he might do so.

71. For those reasons, it was the judgment of the Panel that the appropriate and proportionate Order in the circumstances of this case is a Striking Off Order.

ORDER: The Registrar is directed to strike the name of Ms Joanne Almeida from the Register on the date this Order comes into effect.

Interim Order

1. Ms Collins applied for an Interim Suspension Order for a period of 18 months to protect the public and the wider public interest in light of the Panel’s findings.

2. Ms Stevens did not oppose the application.

3. For the reasons set out in its substantive decision, the Panel concluded there would be a real risk that the Registrant would repeat her misconduct if permitted to practise unrestricted. Accordingly, an Interim Order is necessary to protect the public pending any potential appeal.

4. The Panel also concluded that it was otherwise in the public interest for an Interim Order to be in place pending any potential appeal. The Panel was satisfied that the misconduct was so serious that public confidence in the profession would be seriously harmed if the Registrant were to be allowed to remain in unrestricted practice pending any appeal, and that an Interim Order is needed to maintain proper standards within the profession, and to uphold the reputation of the profession and its regulator.

5. The Panel concluded that an Interim Conditions of Practice Order would not be sufficient or workable, for the same reasons as those set out in its determination on Sanction dealing with the suitability of a substantive Conditions of Practice Order.

6. Accordingly, the Panel concluded that the appropriate order in the circumstances is an Interim Suspension Order.

7. The Panel determined that the appropriate length for such an Interim Order is 18 months to cover the appeal period.

8. The Panel therefore makes an Interim Suspension Order for 18 months. If no appeal is brought, the Interim Order will expire at the end of the appeal period. If an appeal is brought, the Interim Order will expire at the time of the final determination of the appeal, subject to a maximum period of 18 months.

History of Hearings for Joanne Almeida