filed state of california medical board of california ...4patientsafety.org/documents/hiser, daniel...

1 XAVIER BECERRA Attorney General of California

2 ALEXANDRA M. ALVAREZ Supervising Deputy Attorney General

3 KAROLYN M. WESTFALL Deputy Attorney General

4 State Bar No. 234540 600 West Broadway, Suite 1800

5 San Diego, CA 921 01 P.O. Box 85266

6 San Diego, CA 92186-5266 Telephone: (619) 738-9465

7 Facsimile: (619) 645-2061

8 Attorneysfor Complainant

FILED STATE OF CALIFORNIA

MEDICAL BOARD OF CALIFORNIA SACRPr._ENTO A;pr,·l (3 20D. BY· · t~?2J-~ANALYST

BEFORE THE

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11 MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

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13 In the Matter of the Accusation Against:

14 DANIEL LEE HISER, M.D. 7051 Alvarado Road

15 La Mesa, CA 91942

16 Physician's and Surgeon's Certificate No. G47397,

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Case No. 800-2014-004464

ACCUSATION

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Respondent.

Complainant alleges:

PARTIES

21 1. Kimberly Kirchmeyer (complainant) brings this Accusation solely in her official

22 capacity as the Executive Director ofthe Medical Board of California, Department of Consumer

23 Affairs (Board).

24 2. On or about May 17, 1982, the Board issued Physician's and Surgeon's Certificate

25 No. G47397 to Daniel Lee Hiser, M.D. (respondent). The Physician's and Surgeon's Certificate

26 was in full force and effect at all times relevant to the charges brought herein and will expire on

27 February 28,2018, unless renewed.

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ACCUSATION NO. 800-2014-004464

JURISDICTION 1

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3. This Accusation is brought before the Board, under the authority of the following

laws. All section references are to the Business and Professions Code (Code) unless otherwise

4 indicated.

5 4. Section 2227 of the Code states:

6 "(a) A licensee whose matter has been heard by an administrative law judge

7 ofthe Medical Quality Hearing Panel as designated in Section 11371 of the

8 Government Code, or whose default has been entered, and who is found guilty, or

9 who has entered into a stipulation for disciplinary action with the board, may, in

10 accordance with the provisions of this chapter:

11 "(1) Have his or her license revoked upon order of the board.

12 "(2) Have his or her right to practice suspended for a period not to exceed one

13 year upon order of the board.

14 "(3) Be placed on probation and be required to pay the costs of probation

15 monitoring upon order of the board.

16 "( 4) Be publicly reprimanded by the board. The public reprimand may

17 include a requirement that the licensee complete relevant educational courses

18 approved by the board.

19 "(5) Have any other action taken in relation to discipline as part of an order of

20 probation, as the board or an administrative law judge may deem proper.

21 "(b) Any matter heard pursuant to subdivision (a), except for warning letters,

22 medical review or advisory conferences, professional competency examinations,

23 continuing education activities, and cost reimbursement associated therewith that

24 are agreed to with the board and successfully completed by the licensee, or other

25 matters made confidential or privileged by existing law, is deemed public, and

26 shall be made available to the public by the board pursuant to Section 803.1."

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5. Section 2234 of the Code, states:

"The board shall take action against any licensee who is charged with

unprofessional conduct. In addition to other provisions of this article,

unprofessional conduct includes, but is not limited to, the following:

"(a) Violating or attempting to violate, directly or indirectly, assisting in or

abetting the violation of, or conspiring to violate any provision of this chapter.

"(b) Gross negligence.

"(c) Repeated negligent acts. To be repeated, there must be two or more

negligent acts or omissions. An initial negligent act or omission followed by a

separate and distinct departure from the applicable standard of care shall constitute

repeated negligent acts.

"(1) An initial negligent diagnosis followed by an act or omission medically

appropriate for that negligent diagnosis of the patient shall constitute a single

negligent act.

"(2) When the standard of care requires a change in the diagnosis, act, or

omission that constitutes the negligent act described in paragraph (1 ), including,

but not limited to, a reevaluation of the diagnosis or a change in treatment, and the

licensee's conduct departs from the applicable standard of care, each departure

constitutes a separate and distinct breach of the standard of care.

"(d) Incompetence.

6. Section 2242 of the Code, states, in pertinent part:

"(a) Prescribing, dispensing, or furnishing dangerous drugs as defined in Section

4022 without an appropriate prior examination and a medical indication, constitutes

unprofessional conduct.

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7. Section 4022 of the Code states, in pertinent part:

"Dangerous drug' or "dangerous device" means any drug or device unsafe for self

use in humans or animals, and includes the following:

"(a) Any drug that bears the legend: "Caution: federal law prohibits dispensing

without prescription," "RX only," or words of similar import.

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"(c) Any other drug or device that by federal or state law can be lawfully dispensed

on prescription or furnished pursuant to Section 4006."

8. Section 2264 of the Code states:

"The employing, directly or indirectly, the aiding, or the abetting of any

unlicensed person or any suspended, revoked, or unlicensed practitioner to engage

in the practice of medicine or any other mode of treating the sick or afflicted which

requires a license to practice constitutes unprofessional conduct."


"(a) Notwithstanding Section 146, any person who practices or attempts to

practice, or who advertises or holds himself or herself out as practicing, any system

or mode of treating the sick or afflicted in this state, or who diagnoses, treats,

operates for, or prescribes for any ailment, blemish, deformity, disease,

disfigurement, disorder, injury, or other physical or mental condition of any person,

without having at the time of so doing a valid, unrevoked, or unsuspended

certificate as provided in this chapter [Chapter 5, the Medical Practice Act], or

without being authorized to perform the act pursuant to a certificate obtained in

accordance with some other provision of law, is guilty of a public offense,

punishable by a fine not exceeding ten thousand dollars ($1 0,000), by imprisonment

pursuant to subdivision (h) of Section 1170 of the Penal Code, by imprisonment in a

county jail not exceeding one year, or by both the fine and either imprisonment.

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ACCUSATION NO. 800-20 I 4-004464

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"(b) Any person who conspires with or aids or abets another to commit any

act described in subdivision (a) is guilty of a public offense, subject to the

punishment described in that subdivision.

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"(b) The practice of nursing within the meaning of this chapter means those

functions, including basic health care, that help people cope with difficulties in

daily living that are associated with their actual or potential health or illness

problems or the treatment thereof, and that require a substantial amount of

scientific knowledge or technical skill, including all of the following:

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"(2) Direct and indirect patient care services, including, but not limited to,

the administration of medications and therapeutic agents, necessary to implement a

treatment, disease prevention, or rehabilitative regimen ordered by and within the

scope of licensure of a physician, dentist, podiatrist, or clinical psychologist, as

defined by Section 1316.5 of the Health and Safety Code.

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11. Section 2725.1 of the Code states, in pertinent part:

"(a) Notwithstanding any other provision of law, a registered nurse may

dispense drugs or devices upon an order by a licensed physician and surgeon or an

order by a certified nurse-midwife, nurse practitioner, or physician assistant issued

pursuant to Section 2746.51, 2836.1, or 3502.1, respectively, if the registered nurse

is functioning within a licensed primary care clinic as defined in subdivision (a) of

Section 1204 of, or within a clinic as defined in subdivision (b), (c), (h), or (j) of

Section 1206 of, the Health and Safety Code.

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12. Section 2726 of the Code states: "Except as otherwise provided herein, this

2 chapter [The Nursing Practice Act] confers no authority to practice medicine or

3 surgery."

4 FIRST CAUSE FOR DISCIPLINE

5 (Aiding and Abetting Unlicensed Practice of Medicine)

6 13. Respondent has subjected his Physician's and Surgeon's Certificate No. 047397 to

7 disciplinary action under sections 2227, 2264, and 2234, subdivision (a), as defined by section

8 2052, subdivision (b), of the Code, in that he aided and abetted the unlicensed practice of

9 medicine, as more particularly alleged hereinafter:

10 14. On or about September 23,2005, M.N., a California licensed registered nurse, and

11 E.P.O., an unlicensed person, formed a professional corporation named, "Timeless Age-Defying

12 Laser Clinic, Inc.," (TADLC) located in San Diego, CA.

13 15. In or around 2007, respondent had known M.N. for approximately three to four years

14 while working at Scripps Memorial Hospital. At that time, M.N. asked respondent if he would be

15 interested in serving as the Medical Director for T ADLC, which he understood to be a clinic that

16 provided Botox1 treatments, fillers, cellulite-type treatments, chemical peels, laser treatments, and

17 hair removal. Respondent had no training or experience in any of these procedures, and did not

18 inquire of M.N. regarding her training or experience in any of these procedures, but agreed to

19 serve as the Medical Director for TADLC.

20 16. Respondent served as the Medical Director for TADLC from in or around 2007,

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through in or around 2015. During that time, respondent never performed any procedures, never

evaluated any patients, and never created any medical procedure protocols. Respondent

understood that TADLC never employed a physician assistant during that time period.

Respondent further understood that either M.N., or other persons she hired, were performing all

procedures at the clinic. Respondent was unaware of who the other persons were, or what

1 Botox (Botulinum Toxin Type-A) is a purified protein produced by Clostridium botulinum bacterium, which reduces the activity of the muscles that cause frown lines and wrinkles to form over time when injected under the skin. Botox is a dangerous drug pursuant to Business and Professions Code section 4022, and can only be dispensed upon a prescription.

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1 licenses they held, if any. Respondent understood he was the only person affiliated with the

2 clinic who had a DEA license. At all times, respondent understood his role as Medical Director

3 for TADLC was to be available for patient complaints and to review patient charts.

4 17. On or about August 23, 2011, E.P.O. filed a Statement oflnformation with the

5 California Secretary of State listing the TADLC's officers and directors. E.P.O. was listed as the

6 Chief Executive Officer and Chief Financial Officer, and M.N. was listed as the Secretary.

7 Respondent was not listed on this document.

8 18. On or about September 26, 2012, E.P.O. filed a Statement oflnformation with the

9 California Secretary of State listing TADLC's officers and directors. E.P.O. was listed as an

10 Agent, and M.N. was listed as the Chief Executive Officer, Secretary, and Chief Financial

11 Officer. Respondent was now listed as a Director on this document.

12 19. On or about October 7, 2012, respondent signed off as an Officer on TADLC's

13 minutes of a special meeting of the Board of Directors, during which respondent was identified as

14 the Vice President of the Corporation, as well as the 51% owner of TADLC.

15 20. On or about June 1, 2013, the Board of Registered Nursing filed an Accusation

16 against M.N. alleging, among other things, the Unlicensed Practice ofMedicine at TADLC, by

17 treating patients without proper direction by a physician, and without prescriptions for the

18 dangerous drugs injected.

19 21. On or about July 1, 2013, respondent signed off as the Medical Director to TADLC's

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Standardized Procedure and Protocol for Sublativez treatment by a Registered Nurse, Nurse

Practitioner, Physician Assistant and Physician. Within this document, all sublative treatments

were to be conducted under the general supervision of the physician. The physician and mid-

level practitioners were to have specialized training/certification in the treatment of sublative, and

the initial evaluation and final determination of satisfactory training and competence of the mid-

level practitioners was to be by the physician. At that time, respondent had no training or

experience in sublative treatments.

2 Sublative Rejuvenation is a procedure which uses radio frequency to deliver controlled ablative and non-ablative fractional treatment for wrinkles, scars, large pores and better texture of the skin.

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2 Standardized Procedure and Protocol for Sublime/ReFirme3 treatment by a Registered Nurse,

3 Nurse Practitioner, Physician Assistant and Physician. Within this document, all

4 Sublime/ReFirme treatments were to be conducted under the general supervision of the physician.

5 The physician and mid-level practitioners were to have specialized training/certification in the

6 treatment of Sublime/ReFirme, and the initial evaluation and final determination of satisfactory

7 training and competence of the mid-level practitioners was to be by the physician. At that time,

8 respondent had no training or experience in Sublime/ReFirme treatments.


10 Standardized Procedure and Protocol for Intense Pulsed Light (IPL)4 treatment by a Registered

11 Nurse, Nurse Practitioner, Physician Assistant and Physician. Within this document, all Intense

12 Pulsed Light treatments were to be conducted under the general supervision of the physician. The

13 physician and mid-level practitioners were to have specialized training/certification in the

14 treatment of IPL, and the initial evaluation and final determination of satisfactory training and

15 competence of the mid-level practitioners was to be by the physician. At that time, respondent

16 had no training or experience in IPL treatments.


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Standardized Procedure and Protocol for administration of Dermal Filler (Juvederms and/or

Restylane6) by a Registered Nurse, Nurse Practitioner, Physician Assistant and Physician. Within

3 Sublime/ReFirme is a skin tightening procedure that uses bipolar radiofrequency and infrared light.

4 IPL is a technology used by cosmetic and medical practitioners to perform various skin treatments for aesthetic and therapeutic purposes, including hair removal, photorejuvenation (e.g. the treatment of skin pigmentation, sun damage, and thread veins) as well as to alleviate dermatologic diseases such as acne.

s Juvederm is an injectable filler composed of largely hyaluronic acid. It is used to soften deep folds and reduce wrinkles in the faces of patients. Juvederm is a dangerous drug pursuant to Business and Professions Code section 4022, and can only be dispensed upon a prescription.

6 Restylane is an injectable filler composed of a specific formulation of non-animal sourced hyaluronic acid. It is mainly used for lip enhancement and smoothing lines around the lips and in the faces of patients. Restylane is a dangerous drug pursuant to Business and Professions Code section 4022, and can only be dispensed upon a prescription.

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1 this document, all administration of Dermal Filler was to be conducted under the general

2 supervision of the physician. The physician and mid-level practitioners were to have specialized

3 training/certification in the administration of Dermal Filler, and the initial evaluation and final

4 determination of satisfactory training and competence of the mid-level practitioners was to be by

5 the physician. At that time, respondent had no training or experience in the administration of

6 Dermal Filler products.


8 Standardized Procedure and Protocol for Laser Hair Removal by a Registered Nurse, Nurse

9 Practitioner, Physician Assistant and Physician. Within this document, all laser hair removal was

10 to be conducted under the general supervision of the physician. The physician and mid-level

11 practitioners were to have specialized training/certification in the treatment of laser hair removal,

12 and the initial evaluation and final determination of satisfactory training and competence of the

13 mid-level practitioners was to be by the physician. At that time, respondent had no training or

14 experience in the Laser Hair Removal.


16 Standardized Procedure and Protocol for Laser Genesis Skin Rejuvenation treatment by a

17 Registered Nurse, Nurse Practitioner, Physician Assistant and Physician. Within this document,

18 all Laser Genesis Skin Rejuvenation treatments were to be conducted under the general

19 supervision of the physician. The physician and mid-level practitioners were to have specialized

20 training/certification in the treatment of Laser Genesis Skin Rejuvenation, and the initial

21 evaluation and final determination of satisfactory training and competence of the mid-level

22 practitioners was to be by the physician. At that time, respondent had no training or experience in

23 Laser Genesis Skin Rejuvenation treatments.


25 Standardized Procedure and Protocol for the administration of Botox Cosmetic by a Registered

26 Nurse, Nurse Practitioner, Physician Assistant and Physician. Within this document, all

2 7 administration of Botox Cosmetic was to be conducted under the general supervision of the

28 physician. The physician and mid-level practitioners were to have specialized

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training/certification in the administration of Botox Cosmetic, and the initial evaluation and final

2 determination of satisfactory training and competence of the mid-level practitioners was to be by

3 the physician. At that time, respondent had no training or experience in administration of Botox

4 Cosmetic.


6 Standardized Procedure and Protocol for Laser Vein Removal? treatment by a Registered Nurse,

7 Nurse Practitioner, Physician Assistant and Physician. Within this document, all administration of

8 Laser Vein Removal was to be conducted under the general supervision of the physician. The

9 physician and mid-level practitioners were to have specialized training/certification in the

10 treatment of Laser Vein Removal, and the initial evaluation and final determination of

11 satisfactory training and competence of the mid-level practitioners was to be by the physician. At

12 that time, respondent had no training or experience in Laser Vein Removal treatment.

13 29. On or about November 15, 2013, the Board of Registered Nursing issued a Decision

14 and Order, placing M.N. on probation for a period of three (3) years for, among other things,

15 engaging in the unlicensed practice of medicine, related to her ownership ofT ADLC.

16 30. In or around 2013, respondent became aware that M.N. was disciplined by the Board

17 of Registered Nursing, but never sought out the record of discipline and never inquired ofM.N.

18 about the facts surrounding the case. The nature of respondent's involvement in TADLC did not

19 change in any way after M.N.'s license was placed on probation.

20 31. On or about July 15, 2014, an employee ofthe Division oflnvestigations, A.B.

21 (A.B.), entered TADLC and purchased a box ofLatisses over the counter, for $185.00. A.B. was

22 never seen by a health care provider at TADLC, and did not produce a prescription prior to the

23 purchase.

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7 Laser Vein Removal involves a focused beam of light to target the vein that is selected for treatment. The heat of the laser destroys the vein, and over a period of time, the vein is reabsorbed by the body and disappears.

8 Latisse (Bimatoprost) is used on the upper eyelashes to increase their growth, making eyelashes longer, thicker, and darker. Latisse is a dangerous drug pursuant to Business and Professions Code section 4022, and can only be dispensed upon a prescription.

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1 32. On or about November 15,2014, M.N. wrote a letter to the Board of Registered

2 Nursing, indicating that respondent owned 51% ofT AD LC, and that she owned 49%. M.N.

3 further indicated that respondent oversees the clinic and signs off on all prescriptions.

4 33. On or about November 18, 2014, respondent wrote a letter to the Board of Registered

5 Nursing, indicating that he supervises, oversees, and manages TADLC, and all medical staff. He

6 further indicated that he works at the clinic one day per week, and is available by phone and video

7 conference seven days per week. He further indicated that he authorizes and signs all

8 prescriptions. Respondent signed this letter as the Medical Director and Owner ofT ADLC.

9 34. PATIENT S.K.: On or about May 21, 2013, through on or about June 13, 2016,

10 patient S.K., a patient with a history of melanoma, received multiple treatments at TADLC,

11 including but not limited to, Botox injections, Juvederm, IPL, and Chemical Peels. Throughout

12 that time, patient S.K. never met with or received any treatments from respondent. On or about

13 July 11, 2014, patient S.K. purchased a compound cream product from TADLC, the prescription

14 for which was signed by respondent.

15 35. PATIENT B.B.: On or about August 29, 2014, and on or about December 11, 2014,

16 patient B.B. purchased compound cream products from TADLC, the prescription for which was

17 signed by respondent. Patient B.B. never met with or received any treatments from respondent.

18 36. PATIENT M.H.: Between on or about June 19, 2010, through on or about

19 November 25, 2013, patient M.H. received multiple treatments at TADLC, including but not

20 limited to, Botox injections. Throughout that time, patient M.H. never met with or received any

21 treatments from respondent. On or about May 20, 2014, patient M.H. ordered a compound cream

22 product from TADLC over the phone, the prescription for which was signed by respondent.

23 37. PATIENT A.M.: Between on or about February 19,2010, through on or about June

24 27, 2016, patient A.M. received multiple treatments at TADLC, including but not limited to,

25 Botox injections, ReFirme, and IPL. Throughout that time, patient A.M. never met with or

26 received any treatments from respondent. On or about April 29, 2014, patient A.M. purchased a

27 compound cream product from TADLC, the prescription for which was signed by respondent.

28 On or about May 22, 2014, patient A.M. had an IPL procedure performed on her chest. Nine (9)

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1 days later, the nurse noted that "striping and scabbing" was seen over the entire chest as well as

2 an "opened area towards the left clavicle." Respondent was not consulted or informed of this side

3 effect.

4 38. PATIENT C.M.: Between on or about May 6, 2011, through on or about March 17,

5 2015, patient C.M. received multiple treatments at TADLC, including but not limited to Botox

6 injections, ReFirme, and Genesis. Throughout that time, patient C.M. never met with or received

7 any treatments from respondent. On or about August 15,2014, patient C.M. purchased a

8 compound cream product from TADLC, the prescription for which was signed by respondent.

9 39. On or about February 22, 2017, respondent was interviewed by Investigator S.B. from

10 the Division of Investigations at the district office in San Diego, California. During that

11 interview, respondent denied having any ownership interest in T ADLC at any time, but admitted

12 serving as the Medical Director ofTADLC from approximately 2007 through 2015. Throughout

13 that time, respondent believed M.N. to be the only registered nurse who worked at TADLC, but

14 admitted there may have been others whom he did not know. Respondent initially visited

15 TADLC weekly, but over the years admitted he visited less frequently, approximately only once

16 per month to review and sign off on patient charts. Respondent did not know how the clinic

17 ordered Botox, or from where. Respondent claimed to be unaware of the requirement of

18 prescriptions for various products offered at the clinic, but admitted signing prescriptions for

19 "supplies" for the clinic.

20 SECOND CAUSE FOR DISCIPLINE

21 (Gross Negligence)

22 40. Respondent has further subjected his Physician's and Surgeon's Certificate No.

23 G4 7397 to disciplinary action under sections 2227 and 2234, as defined by section 2234,

24 subdivision (b), of the Code, in that respondent committed gross negligence in his care and

25 treatment of patients S.K., B.B., M.H., A.M., and C.M., as more particularly alleged hereinafter:

26 (a) Paragraphs 13 through 39, above, are incorporated by reference and realleged

27 as if fully set forth herein.

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1 (b) Respondent committed gross negligence in his care and treatment of patient

2 S.K. by allowing a registered nurse to care and treat the patient without a prior consultation

3 with the supervising physician;

4 (c) Respondent committed gross negligence in his care and treatment of patient

5 B.B. by allowing a registered nurse to care and treat the patient without a prior consultation


7 (d) Respondent committed gross negligence in his care and treatment of patient

8 M.H. by allowing a registered nurse to care and treat the patient without a prior consultation


10 (e) Respondent committed gross negligence in his care and treatment of patient

11 A.M. by allowing a registered nurse to care and treat the patient without a prior consultation

12 with the supervising physician; and

13 (f) Respondent committed gross negligence in his care and treatment of patient

14 C.M. by allowing a registered nurse to care and treat the patient without a prior consultation

15 with the supervising physician.

16 THIRD CAUSE FOR DISCIPLINE

1 7 (Repeated Negligent Acts)


19 G47397 to disciplinary action under sections 2227 and 2234, as defined by section 2234,

20 subdivision (c), of the Code, in that he committed repeated negligent acts in his care and

21 treatment of patients S.K., B.B., M.H., A.M., and C.M., as more particularly alleged in

22 paragraphs 13 through 40, above, which are hereby incorporated by reference and re-alleged as if

23 fully set forth herein.

24 FOURTH CAUSE FOR DISCIPLINE

25 (Furnishing Dangerous Drugs Without Exam)


27 G47397 to disciplinary action under sections 2227 and 2234, as defined by section 2242, of the

28 Code, in that he prescribed, dispensed, or furnished dangerous drugs without an appropriate prior

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1 examination and medical indication relating to his care and treatment of patients S.K., B.B.,

2 M.H., A.M., and C.M., as more particularly alleged in paragraphs 13 through 41 above, which are

3 hereby incorporated by reference and re-alleged as if fully set forth herein.

4 FIFTH CAUSE FOR DISCIPLINE

5 (Incompetence)


7 047397 to disciplinary action under sections 2227 and 2234, as defined by section 2234,

8 subdivision (d), of the Code, in that he has demonstrated incompetence in his care and treatment

9 of patients S.K., B.B., M.H., A.M., and C.M., as more particularly alleged in paragraphs 13

10 through 42 above, which are hereby incorporated by reference and re-alleged as if fully set forth

11 herein.

12 PRAYER

13 WHEREFORE, complainant requests that a hearing be held on the matters herein alleged,

14 and that following the hearing, the Medical Board of California issue a decision:

15 1. Revoking or suspending Physician's and Surgeon's Certificate No. 047397, issued to

16 respondent Daniel Lee Hiser, M.D.;

17 2. Revoking, suspending or denying approval of respondent Daniel Lee Hiser, M.D.'s

18 authority to supervise physician assistants and nurse practitioners;

19 3. Ordering respondent Daniel Lee Hiser, M.D., if placed on probation, to pay the Board

20 the costs of probation monitoring; and

21 4. Taking such other and further action as deemed necessary and proper.

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23 DATED: Apr i 1 1 3 , 2 0 1 7

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27 SD20 17704600

28 81645923.doc

Executive Director Medical Board of California Department of Consumer Affairs State of California Complainant

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