Florida health regulators use the honor code to police assisted living facilities, relying on owners and administrators to report to the state when an employee is accused of a crime such as fraud.

But when Tiffany Gordon was accused last year of bilking Miami's cash-strapped public hospital out of more than $83,000 by creating “ghost employees” and securing them paychecks, she both owned and ran the Intraqual Premier ALF.

She continues to run the Miami Gardens facility from her home — where she is under house arrest.

That may soon change, however. Late last week, after The Miami Herald inquired how someone could run an ALF — attending to the many needs of frail elders and disabled people — while on house arrest, the state Agency for Health Care Administration filed an administrative complaint against Intraqual Premier, seeking to revoke its license. Under new state laws, ALFs must report to the state when owners or administrators are criminally charged, rendering them ineligible to work with vulnerable clients, such as frail elders and people with disabilities.

Gordon, 35, could not be reached for comment. Her attorney, Seth LaVey, declined to discuss Gordon or Intraqual Premier, and said he instructed her not to discuss the case, either.

“She maintains her innocence, and has done so from the day we took the case,” LaVey said, through a staffer in his office.

When Gordon was arrested last September, she held a financial watchdog role, overseeing the work of a private agency that supplied temporary workers to Jackson Memorial Hospital.

She also operated Intraqual, at 19117 NW 33rd Ave., which was licensed by the state in November 2010 as an assisted living facility with an “extended congregate care” classification. That license allows the home to provide a significantly higher level of care than most ALFs — stopping short of the services nursing homes provide. In licensure records, Gordon is listed as director, chief operating officer, president and part-owner. She also is listed as both administrator and chief financial officer.

Last September, Miami-Dade police detectives arrested her, and charged her with fleecing the struggling public hospital out of $83,000.

Police say the scam went like this: Gordon hired two pals and paid them $49,301 and $34,323 mostly to do nothing. One of Gordon’s alleged confederates, Janet Lockwood, collected $17,000 from Jackson for four months while Lockwood was attending U.S. Navy boot camps in Michigan and Illinois. Most of the money was kicked right back to Gordon, police said.

In documents, a detective said the hospital uncovered the scheme in July 2010, when an internal auditor told police she had learned that Gordon had “committed fraud in excess of $300,000 for payments to temporary workers.”

Some of the temps had been paid for some hours they did not work, while others were paid to do absolutely nothing, a detective wrote. At the time, Gordon was the Jackson auditor in charge of overseeing the temporary employee company, including authorizing workers’ time sheets.

Police said Gordon had strongly recommended that Lockwood and another friend be hired at Jackson, though “they did not meet the minimum qualification criteria,” for their jobs.

In a charging document dated Sept. 8, Gordon faces three counts of unlawful compensation by a public employee, operating an organized scheme to defraud, and official misconduct by a public employee. She is being tried by State Attorney Katherine Fernández Rundle’s public corruption unit.