medvance institute lawsuit for false advertising

IN THE FIFTEENTH JUDICIAL CIRCUIT COURT IN AND FOR PALM BEACH COUNTY, FLORIDA

DONESIA BEST, GUERLANDE EXANTUS, DIANA MEDINA, TERI DOLECKI, DIANA MEYER, & LINDA O'NEILL,

Plaintiffs, v.

Case No.: __________ _

EDUCATION AFFILIATES INC., a Maryland corporation d/b/a MedVance Institute, & KIMC INVESTMENTS, INC., a Maryland corporation d/b/a MedVance Institute,

Defendants.

--------------------------~/

COMPLAINT

Plaintiffs Donesia Best, Guerlande Exantus, Diana Medina, Teri Dolecki, Diana Meyer,

and Linda O'Neill, sue Defendants, Education Affiliates Inc., and KIMC Investments, Inc., both

doing business as MedVance Institute ("MedVance"), for breach of contract, breach of the

covenant of good faith and fair dealing, fraud in the inducement, fraudulent misrepresentation,

and for violating laws prohibiting misleading advertising, Fla. Stat. § 817.41, and unfair and

deceptive trade practices, Fla. Stat. § 501.204.

Introduction

1. This lawsuit concerns a private, for-profit educational facility, MedVance, which

diligently and fraudulently recruits students to attend its campuses in Florida and elsewhere.

MedVance's goal is matriculation of students, not education. The more students who emoll and

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matriculate, the higher the profits for MedVance. In order to convince students to enroll,

MedVance recruiters make false statements regarding the quality of education, graduates'

preparedness to pass certification exams, the costs of education, the ease of repaying federal

loans, and most important to Plaintiffs, job prospects upon graduation.

2. As a recipient and beneficiary of state and federal funds and loan guarantees,

MedVance has a vested interest in enrolling as many students as possible, no matter their

qualifications or interests. MedVance was and still is under scrutiny by the Governrnent

Accountability Office and Congress because of its business practices. The GAO cited

MedVance on August 4,2010 for "encouraging fraudulent practices" and for making "deceptive

or otherwise questionable statements." See Exhibit A. MedVance is part of the burgeoning

phenomenon of for-profit private career colleges, which "have grown in enrollment from

365,000 students to nearly two million over the past several years ... [and whose 1 students

borrowed more than $20 billion in federal loans last year." See id Although only about 12% of

American post-secondary students attend these colleges, those students represent 43% of 2008

student loans in default. See id

3. MedVance victimizes its students. Plaintiffs, who were enticed by promises of a

better life, left MedVance with little more than an insurmountable debt burden. Instead of

learning the skills required to succeed in the fields of Medical Office Administration and

Medical Coding and Billing, Plaintiffs were subjected to out-of-control classes taught by

disinterested and unqualified instructors. Instead of educational extemships capable of

enhancing professional development, Plaintiffs were placed with employers who assigned menial

tasks. Instead of sound financial advice, MedVance's financial department rushed Plaintiffs

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through the loan application process, simply assuring them not to worry about a major life

decision. MedVance is solely focused on the bottom line, to the detriment of its students.

Parties, Jurisdiction, Venue Etc.

4. Plaintiff Donesia Best, a current resident of Palm Beach County, Florida, attended

MedVance Institute's West Palm Beach campus from 2009 to 2010.

5. Plaintiff Guerlande Exantus, a current resident of Palm Beach County, Florida,

attended MedVance Institute's West Palm Beach campus from 2009 to 2010.

6. Plaintiff Diana Medina, a current resident of Palm Beach County, Florida,

attended MedVance Institute's West Palm Beach campus from 2009 to 2010.

7. Plaintiff Teri Dolecki, a current resident of Martin County, Florida, attended

MedVance Institute's Stuart campus from 2008 to 2009.

8. Plaintiff Diana Meyer, a current resident of St. Lucie County, Florida, attended

MedVance Institute's Staurt campus from 2008 to 2009.

9. Plaintiff Linda O'Neill, a current resident of Palm Beach County, Florida,

attended MedVance Institute's Stuart campus from 2008 to 2009.

10. Defendant Education Affiliates Inc. is a Maryland corporation that owns several

private career colleges in Florida doing business under the name, "MedVance Institute."

Education Affiliates purchased MedVance Institute from KlMC Investments, Inc. in December

2009. All Plaintiffs attended Defendants' Stuart or West Palm Beach campuses.

11. Defendant KIMC Investments, Inc. is a Maryland corporation that owned several

private career colleges in Florida doing business under the name, "MedVance Institute." KIMC

Investments, Inc. sold MedVance Institute to Education Affiliates Inc. in December 2009. All

Plaintiffs attended Defendants' Stuart or West Palm Beach campuses.

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12. Jurisdiction is proper pursuant to Fla. Stat. § 26.012 because this is an action at

law in excess of$15,000.

13. Venue is proper pursuant to Fla. Stat. § 47.041 because actions on several causes

of action may be brought in any county where any of the causes of action arose. Most causes of

action accrued in Palm Beach County, Florida.

Facts Common to All Counts

14. Plaintiffs were convinced to enroll because of promises that they could start a

successful career in an in-demand occupational field. Oral representations aside, even

MedVance's informational literature makes unrealistic forecasts and assurances. MedVance tells

recruits that it is "dedicated to preparing qualified candidates for careers in the medical field and

has been doing so for decades." See Exhibit B. It also claims that classes are taught by "highly

trained professionals." See id. It boasts that students learn on-the-job training at "a variety of

medical settings." See id The Medical Office Administration program information guide states:

"Upon completion of this program, graduates will be able to seek entry-level positions in

healthcare facilities ... With strong skills sets in office technology, office management and

customer service, the graduate will possess the knowledge and be positioned to work within the

team dynamic required in healthcare administration today." See id. The Medical Billing and

Coding program information guide similarly states: "The Medical Billing & Coding Specialist

program prepares students to analyze medical records and assign codes to medical conditions,

diagnoses and procedures . . . Graduates find entry-level employment opportunities in

physician's offices, billing offices, hospitals .... " See id Plaintiffs were also orally guaranteed

jobs upon completion of their respective programs by recruiters.

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15. In reality, MedVance does not prepare its students for certification exams and

employment in a turbulent and competitive job market. Plaintiffs were hastily pushed through

the filling out of federal loan paperwork, and in many cases, MedVance prepared the paperwork

for Plaintiffs. Instead of carefully counseling its students on the pros and cons of incurring debt,

the financial aid department sought only the minimum information required to fill out federal

loan documents. Across the board, MedVance's Career Services Office did little to connect

students with worthwhile job opportunities. In hindsight, Plaintiffs see their time and money

spent at MedVance as wasted. And at the end of the day, even if Plaintiffs do not receive the

training promised, MedVance remains the beneficiary of substantial federal-backed student

loans.

Donesia Best

16. Donesia Best was enrolled in the Medical Office Administration night program at

MedVance's West Palm Beach campus between October 2009 and June 2010. She graduated

with a 3.85 GPA. Ms. Best received some financial aid but incurred federal student loan debt of

about $11,500. She was attracted to MedVance by the promise that, after graduation, she would

be hired for a full time position with benefits. After expressing skepticism at filling out loan

paperwork given her financial position and the inability to pay a routine $25 filing fee, a recruiter

told her, "between you and me, there's a $25 fee and I will front it if you do not tell anyone."

MedVance Recruiters and financial aid personnel had no interest in Ms. Best's ability to repay

her loan and simply assured her that she would find a job in her field after graduation. They

hastily procured her personal information so that they could fill out loan paperwork on her

behalf. After filling out the paperwork, MedVance employees told Ms. Best to write down the

names and addresses of friends who might also be interested in enrolling. Ms. Best recalled that

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instructors lacked effort and in a highly technical transcription class that required textbooks,

weeks went by without textbooks as the instructor simply passed the time.

17. During her studies, MedVance's Career Services Office told Ms. Best they would

help her with her resume, but they simply added a line for MedVance institute and sent it back to

her. They sent her on 2 "interviews": one consisted of dropping a resume in a pile at a nearby

job fair; the other was at a doctor's office, where she was told that she did not have requisite

experience. Ms. Best knows of one peer out of approximately 100 in the Medical Office

Administration Program who found gainful employment. After MedVance, she enrolled at

Broward College as a general studies major seeking to satisfy prerequisites to be a registered

nurse. Broward does not recognize the credits she earned, at a hefty rate, at MedVance. Ms.

Best currently works part time at Publix and considers her graduation from MedVance and the

experience in general as "worthless."

Guerlande Exantus

18. Ouerlande Exantus was enrolled in the Medical Office Administration night

program at MedVance's West Palm Beach campus between November 2009 and August 2010.

Ms. Exantus graduated with about a 3.5 OPA. She incurred federal loan debt split between

subsidized and unsubsidized loans totaling approximately $11,000. She became involved with

MedVance when they called her directly and promised a great education and further

employment. MedVance's financial aid department hastily completed Ms. Exantus' loan

paperwork and their Career Services Office did nothing to help her find a job or even an

internship.

19. When she asked for assistance, the Career Services Office told Ms. Exantus that

she was "on her own" and urged her to go to various medical offices to ask if they were hiring.

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Ms. Exantus used to be a customer relations employee and has been out of work for over four

years. She has stated that her debts are piling up and that MedVance was a major waste of time

and money.

Diana Medina

20. Diana Medina was enrolled in the Medical Office Administration night program

at MedVance's West Palm Beach campus between November 2009 and August 2010. Ms.

Medina completed her studies with a perfect 4.0 GP A. She paid approximately $3,000 out-of-

pocket in tuition and incurred federal student loan debt of about $9,000. Ms. Medina found

MedVance while searching online and was attracted by the opportunity to attend night classes

and better her job prospects. She contacted MedVance's West Palm Beach campus and was

assured by recruiter Norma Jimenez that she would definitely get a job as a medical office

manager nearby upon graduation. MedVance's financial aid department told Ms. Medina that

they would take care of the loan paperwork and that she would not have to worry about it until

she got a job. During class, Ms. Medina recalls that answers to tests were spoon-fed to students

and that when she asked for clarification of a difficult subject, instructors would tell her to just

read the book. Instructors were woefully unqualified and would often ramble about their

personal lives or gossip, instead ofthoughtfully teaching the subject matter.

21. Since completing her studies, Ms. Medina has received no help finding a job from

MedVance's Career Services Office. Ms. Medina, who attended the University of Florida,

considers her education at MedVance worthless and omits the experience from her resume. She

has stated that, "you are basically paying for a piece of paper that says, I graduated here, and I

still have no experience." She currently works at Publix but is actively seeking employment in

the Medical Office Administration field.

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Teri Dolecki

22. Teri Dolecki was enrolled in the Medical Coding and Billing night program at

MedVance's Stuart campus between August 2008 and July 2009. Ms. Dolecki graduated with a

perfect 4.0 GPA. She incurred federal student loan debt of about $15,000. Ms. Dolecki saw a

commercial on TV and went on MedVance's website, where she was attracted by representations

that the medical coding and billing fields were in high demand. Ms. Dolecki, who had been out

of school for 30 years and whose husband had recently passed away, was interested in the

prospect of going from "classroom to career in a year." She was recruited by MedVance's

Tamara Stephens who promised her that the program was perfect for middle-aged individuals,

that she could work part time from home after graduation, that jobs in the field were in demand,

and that MedVance would prepare her for the Certified Professional Coder (CPC) examination.

The financial aid department hastily processed her paperwork and told her it would be easy to

payoff loan debt. To entice her, they refunded a $300 enrollment fee. Recruiters and financial

aid employees neglected to inform her that maintaining a license in the field costs about $200 a

year. Ms. Dolecki was one of the many students who signed up for the new 4-week curriculum,

whereby MedVance would teach subjects in four, rather than six weeks. This new curriculum

hurts students and teachers, who must speed through the material; it helps MedVance, which is

able to recruit and sign up more students per year. During her extemship, Ms. Dolecki was

placed at Martin Memorial Hospital and Treasure Coast Surgical Center. At these placements,

she received some coding experience, but spent most of her time xeroxing reports, copying

papers, stuffing envelopes and answering phones.

23. Ms. Dolecki took and passed the CPC exam and upon information and belief, was

the only student in her program to do so. She recalled that reading the textbook was more useful

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than MedV ance' s exam prep classes, which consisted of crossword puzzles. See Exhibit C. Ms

Dolecki accepts the possibility that her 25 years experience in medical transcription and

terminology helped prepare her for the exam more than MedVance did. After certification and

graduation, MedVance's Career Services Office put her in contact with employers who only

wanted her to answer phone calls; they did not put her in touch with any potential part time

coding employers, despite initial promises. Highly motivated, Ms. Dolecki offered to volunteer

at medical offices to learn more about coding, but employers told her that she lacks the requisite

experience. MedVance never told her during recruitment and enrollment that almost all medical

coding and billing employers are only seeking certified employees with at least two years

experience in the field. She is currently living off of her pension and actively seeking a coding

job, which she has been unable to attain, despite her 4.0 OPA and passage of the CPC exam. Ms.

Dolecki has stated that she was "proud of herself for having the courage to go back to school, but

it was all a waste."

Diana Meyer

24. Diana Meyer was enrolled in the Medical Coding and Billing night program at

MedVance's Stuart campus between August 2008 and July 2009. Ms. Meyer attended classes

but left after her extemship and did not graduate. Ms. Meyer paid for MedVance by incurring

federal loan debt of about $11,500 and Pell grants of about $5,000. MedVance recruiter Tamara

Stephens promised Ms. Meyer, who has 20 years of accounting experience, a job that paid

approximately $50,000 upon graduation and passage of the CPC Exam. Ms. Stephens told Ms.

Meyer that MedVance was accredited and that passage of the exam would be a virtual certainty

after a MedVance education. After Ms. Meyer told Ms. Stephens that she wanted to speak with

her husband before filling out loan paperwork and enrolling, Ms. Stephens pressured her to

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emoll by stressing that if she did not sign up right then, she would have to wait months or a year

to fill a spot in another program. MedVance's financial aid department told Ms. Meyer that

paying the loans off would not pose a problem and that other MedVance graduates easily paid

off the debt. Ms. Meyer was placed at a 32-hour-a-week extemship for no pay with All

American Physicians LLC in Port St. Lucie. Although given the opportunity to do some medical

coding, her supervisor was not qualified and failed to give her guidance or teach her more about

the field. After the extemship, Ms. Meyer left MedVance when the instructors gave her and her

peers crossword puzzles and word searches in order to prepare for the intensive CPC exam. See

Exhibit C. According to Ms. Meyer, instructors were not qualified and one in particular had not

even passed the CPC exam. She recalls that much of the classroom teaching directly conflicted

with the textbook and caused confusion for students.

25. Ms. Meyer, like over 90% of her classmates, eventually failed the CPC exam and

was not properly prepared by MedVance, despite their promises. She is currently unemployed

and has no prospects finding employment in the medical coding or billing fields.

Linda O'Neill

26. Linda O'Neill was enrolled in the Medical Coding and Billing night program at

MedVance's Stuart campus between October 2008 and September 2009. Ms. O'Neill graduated

with a perfect 4.0 GP A. She incurred federal loan debt of about $15,000. Ms. O'Neill has stated

that she was "sucked in" by a recruiter who stated that "most girls" get a job that pays about

$40,000 after graduation. She recalls that during orientation, new students wore nametags that

said, "Future Biller or Coder." She was rushed through the loan application process and was not

told to carefully consider the implications of incurring substantial debt. Ms. O'Neill remembers

that instructors were unqualified and textbooks needed to be updated. During her unpaid

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extemship at an eye doctor's office, she folded letters, stuffed and stamped envelopes and

completed other menial tasks unrelated to forging contacts and developing professionally in the

medical billing or coding fields. She has stated that she "did her time," in order to receive

extemship credit, a requirement to graduate.

27. Ms. O'Neill did not pass the CPC exam and has stated that MedVance did not

properly prepare her for it because classes were rushed and students were made to complete

crossword puzzles and word searches. During classes and after graduation, MedVance's Career

Services Office did nothing to help her find a job anywhere within 30 miles of Jupiter, where she

lives. Ms. O'Neill currently works at a small cleaning business, lives with her family and has no

prospects finding a job related to her studies at MedVance despite her best efforts.

COUNT I - Breach of Contract

28. Plaintiffs incorporate paragraphs 1-27.

29. The Plaintiffs entered into a binding contract with MedVance. MedVance's

literature assures that students "have made a commitment to us and to their future and we in tum,

have a commitment to help them realize it." In statements by recruiters and literature provided,

MedVance offered Plaintiffs a quality education that would, at a minimum, give a realistic

chance of employment after graduation. Plaintiffs accepted this offer, with consideration in the

form of incurring thousands of dollars of federal-backed student loans, and the expenditure of

time and effort.

30. Plaintiffs fully performed their obligations under the agreement by paying tuition

and making a good faith effort to attend classes, externship placements, and pursue available

employment avenues.

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31. Defendants breached the education contract by failing to provide a quality

education in the fields of Medical Coding or Billing and Medical Office Administration.

MedVance fell woefully short of making good on their many oral and written promises that good

jobs were attainable after earning a MedVance degree. For example, students in the Medical

Coding and Billing program were told that a MedVance education would prepare them for the

CPC exam. It did not. MedVance also breached the agreement by failing to connect Plaintiffs

with area employers.

32. Plaintiffs were damaged as a result of Defendants' breach of the agreement in the

form of being burdened with heavy loan debt without leaming necessary skills, forging important

contacts, or obtaining jobs with area employers. They are entitled to expectation damages,

which include both incidental and consequential damages for Defendants' breach.

COUNT II - Breach of Good Faith and Fair Dealing

33. Plaintiffs incorporate paragraphs 1 - 27.

34. As an educational institution entering into contracts with its students whereby

students give money and the institution gives education and a path to employment, a fiduciary

relationship was created between Plaintiffs and MedVance. In every contract, there is an implied

covenant of good faith and fair dealing.

35. MedVance was obligated to not take action which would deprive Plaintiffs of

their benefits arising from the contract and had to, in good faith, execute its contractual duties.

36. MedVance breached their duties by baiting students to enter into the education

contract by using deceptive recruiting practices. For example, recruiters told Plaintiffs that loans

would be easy to repay since jobs were in high demand and that MedVance provided the tools

and connections necessary to surely secure employment.

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37. MedVance also breached their duties by offering classes and placing Plaintiffs in

extemships that did not further professional development in the Medical Office Administration

and Medical Coding and Billing fields.

38. Plaintiffs have been damaged by MedVance's breach of duties arising from the

contract. They owe Plaintiffs damages proximately resulting from this breach.

COUNT III - Fraud in the Inducement

39. Plaintiffs incorporate paragraphs 1-27.

40. MedVance's recruiters and financial aid personnel made numerous

misrepresentations of material fact to Plaintiffs in order to procure enrollment. For example,

they informed Plaintiffs that they would obtain employment upon graduation and that because of

this employment, loans would easily be paid off.

41. Specifically, Plaintiff Best was told that she could easily find a full time job with

benefits upon graduation. When expressing uncertainty about taking out a loan, she was told,

"we are sure that you will find a job, the field is in demand, so do not worry about it."

42. Plaintiff Exantus was falsely promised employment contacts during her education

andjob opportunities after her education by MedVance recruiters.

43. Plaintiff Medina was assured by recruiter Norma Jimenez that she would

definitely get a job as a medical office manager nearby upon graduation. She was told by

financial aid personnel to take out a loan because "you will not have to worry about it until after

graduation, when you have ajob."

44. Plaintiff Dolecki was recruited by MedVance's Tamara Stephens, who promised

her that the program was perfect for middle-aged individuals, that she could work part time from

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home after graduation, that jobs in the field were in demand, and that MedVance would prepare

her for the Certified Professional Coder (CPC) examination.

45. Plaintiff Meyer was promised by MedVance recruiter Tamara Stephens that ajob

paying approximately $50,000 a year was awaiting after graduation. Ms. Stephens told Ms.

Meyer that passage of the exam would be a virtual certainty after a MedVance education.

Financial aid personnel told Ms. Meyer that it would be "easy" to payoff loan debt.

46. Plaintiff O'Neill was told by a recruiter that most graduates acquire a job paying

about $40,000 a year after graduation. The recruiter told Ms. O'Neill MedVance success stories

about graduates attaining high-paying jobs and promotions with the opportunity to travel.

47. The GAO cited MedVance on August 4, 2010 for "encouraging fraudulent

practices" and for making "deceptive or otherwise questionable statements."

48. MedVance personnel knew, or should have known, the falsity of these statements.

Through their difficulties placing students at worthwhile extemships, awareness of loan default

rates, and operation of a marginally effective Career Services Office, MedVance knew that their

representations were false.

49. MedVance intended that their false representations would induce Plaintiffs to rely

and act. MedVance intended to, and achieved their goal of, having Plaintiffs fill out loan

paperwork and incur substantial debt in order to emoll and attend classes.

50. Plaintiffs, through expenditures of time and money, suffered injury in justifiable

reliance on MedVance's false representations.

COUNT IV - Fraudulent Misrepresentation


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52. Plaintiffs Meyer, Dolecki and O'Neill, were entolled in the Medical Billing and

Coding program, which required them to complete an offsite extemship in order to graduate and

sit for the certification exam.

53. In order to keep these Plaintiffs emolled, MedVance made false statements that

they would get on-the-job training, forge important employment contacts, and would learn more

about the field through hands-on experience via the extemship program.

54. Defendants, unable to place so many students at worthwhile extemships or find

eventual employment for its students, knew that these statements were false when they were

made.

55. These misrepresentations were made with the intent to induce Plaintiffs to act, in

the form of staying emolled and being responsible for tuition.

56. Aside from being unable to ultimately find jobs, Plaintiffs were damaged by their

reliance on these misrepresentations by being effectively forced to complete menial tasks with

little or no bearing to the Medical Coding and Billing field. Plaintiffs also incurred loan debt in

reliance on these misrepresentations.

COUNT V - Misleading Advertising

57. Plaintiffs incorporate paragraphs I - 27.

58. According to Fla. Stat. § 817.41, which provides for a private cause of action,

misleading advertising is prohibited. Misleading advertising is defined at Fla. Stat. § 817.40(5).1

I "The phrase 'misleading advertising' includes any statements made, or disseminated, in oral, written, or printed form or otherwise, to or before the public, or any portion thereof, which are known, or though the exercise of reasonable care or investigation could or might have been ascertained, to be untrue or misleading, and which are or were so made or disseminated with the intent or purpose, either directly or indirectly, of selling or disposing of real or personal property, services of any nature whatever, professional or otherwise, or to induce the public to enter into any obligation relating to such property or services."

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59. To further their sale of services and to encourage students to enroll, MedVance

advertised, both in print and with the use of recruiters. Brochures suggest that MedVance

graduates "will be able to seek entry-level positions in healthcare facilities ... With strong skills

sets in office technology, office management and customer service, the graduate will possess the

knowledge and be positioned to work within the team dynamic required in healthcare

administration today." See Exhibit B. More directly, recruiters told Plaintiffs that securing solid

jobs after graduation was a virtual certainty. Financial aid employees told Plaintiffs that paying

back student loans would be easy. After all, they would eventually be gainfully employed

according to MedVance personnel. These statements, as well as other representations by

MedVance discussed herein, are known, or through the exercise of reasonable care or

investigation could or might have been ascertained, to be untrue or misleading.

60. These statements were made for the purpose of selling services, namely,

educational services.

61. Plaintiffs relied on these false statements and advertising strategies to their

detriment, by incurring loan debt and attending classes and extemships that were, in effect,

worthless.

62. Defendant's false advertising practices were the proximate case of Plaintiffs'

injuries; were it not for MedVance's assurances and advertisements, Plaintiffs would not have

enrolled. In other words, had MedVance truthfully communicated Plaintiffs true job prospects

and the actual implications of applying for hefty federal loans, Plaintiffs would not have enrolled

at MedVance.

COUNT VI - Unfair or Deceptive Trade Practices


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64. Fla. Stat. § 501.204 provides for a private cause of action for those harmed by

"[u]nfair methods of competition, unconscionable acts or practices, and unfair or deceptive acts

or practices in the conduct of any trade or commerce .... "

65. MedVance, a for-profit private college, is engaged in the trade and commerce of

emolling students and collecting tuition payments.

66. Student recruitment is a vital aspect of MedVance's form of trade and commerce,

and their methods of recruitment are deceptive and unfair. The experiences of the individual

Plaintiffs have been confirmed by reports from govermnent and media. See Exhibit A.

Essentially, MedVance promised results that they knew were not forthcoming in order to make

money at Plaintiffs' expense.

67. MedVance's unfair and deceptive trade practices caused Plaintiffs to emoll, incur

federal loan debt, expend time and effort, and not pursue other opportunities.

68. Plaintiffs suffered damages as a result of MedVance's unfair and deceptive trade

practices. All Plaintiffs have had no success securing employment in their respective fields and

are currently burdened with crippling student loan debt.

Demand for Jury Trial

Plaintiffs demand a trial by jury on all issues so triable.

Prayer for Relief

Plaintiffs pray that this Court enter judgment in their favor against Education Affiliates

Inc. and KIMC Investments, Inc., both d/b/a MedVance Institute and award Plaintiffs:

A. Compensatory damages equal to the amount of money paid in tuition;

B. Compensatory damages equal to the amount of interest and fees paid or payable to

Plaintiffs' student loan lenders;

17 SARELSON LAW FIRM, PA, 1401 Brickell Avenue, Suite 510, Miami, Florida 33131, 305-379-0305, 800-421-9954 (fa.",)

www.FloridaConsumcrLawyerBlog.com www.Sarc1son.com

C. Attorneys' fees where applicable by statute;

D. Pre- and post-judgment interest;

E. Costs;

F. All other relief, both in law and in equity, this Court deems appropriate.

18

Fla. BarNo. 888281 Max M. Nelson, Esq. Fla. Bar No. Pending SARELSON LAW FIRM, P.A. 1401 Brickell Avenue, Suite 510 Miami, Florida 33131 305-379-0305 800-421-9954 (fax) [email protected] [email protected]

SARELSON LAW FIRM, PA, 1401 Brickell Avenue, Suite 510, Miami, Florida 33131, 305-379-0305, 800-421-9954 (fa. ... ) www.FloridaConsumerLawyerBlog.com

www.Sarelsoo.com

GAO: 15 for-profit colleges used deceptive recruiting tactics Page 1 of2

CiJbe tutt9btngton $109t

GAO: 15 for-profit colleges used deceptive recruiti l1gtactics ...................................................................................... .

Washington Post Staff Writer By Daniel de Vise and Paul Kane Thursday, August 5, 2010 Congressional officials on Wednesday identified IS for-profit colleges where recruiters allegedly encouraged investigators posing as prospective students to commit fraud on [mancial aid applications or misled them about such matters as tuition costs and potential salaries after graduation.

The Government Accountability Office's findings, presented to a congressional committee along with grainy video clips captured by hidden cameras, may ampliry federal scrutiny of the fastest-growing highereducation sector.

Many ofthe largest for-profit entities were named among the 15 sites targeted by GAO investigators: University of Phoenix, with more than 400,000 students; Argosy University, part of the 136,000-student Education Management Corp.; Kaplan College, part of the 119,000-student Kaplan Higher Education operation owned by The Washington Post Co.; and Everest College, part of the llO,OOO-student Corinthian Colleges.

Also named: Westech College in California, Bennett Career Institute and Potomac College in the District, MedVance Institute in Florida, College of Office Technology in Illinois, Anthem Institute in Pennsylvania, and Westwood College and AT! Career Training in

Texas. Kaplan, Everest and Phoenix each were cited twice, for different campuses.

Four ofthe colleges -- Westech, MedVance, Anthem and Westwood -- "encouraged fraudulent practices" in meetings with undercover investigators, the report says. All IS "made deceptive or otherwise questionable statements. "

At a morning Senate hearing, some of the most powerful revelations came in a brief video presentation, spliced together from hidden-camera feeds.

Attendees watched as a MedVance admissions officer told an applicant he needn't worry about loading up student debt: "It's not like a car note -- if you don't pay it, they won't come after you."

A Texas admissions officer tells an applicant

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GAO: 15 for-profit colleges used deceptive recruiting tactics

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not to report his savings on a loan application: "They don't need to know how much cash you have."

And a Florida recruiter quips to a reluctant applicant, "What are you really afraid of?" and then rips up his application.

Leaders of industry giants Phoenix, Kaplan and Corinthian all announced internal investigations in response to the fmdings.

In a joint statement, Donald E. Graham, chairman and chief executive of The W ashington Post Co., and Andrew S. Rosen, chairman and chief executive of Kaplan Inc., described the tactics revealed in the videotaped interviews as "sickening."

"They violate in every way the principles on which Kaplan is run," they said in a statement posted on The Washington Post Co.'s Web site. "The GAO and the Senate [Health, Education, Labor and Pensions Committee] have done us a favor. We will do everything in our power to eliminate such conduct from Kaplan's education institutions. "

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For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say - Bloomberg Page 1 of 4

Search Quotes and News

Bloomberg Anywhere Professional Solutions About Lo,Io G G) G ~TOYOTA

Toyota Care Fe.atul'ing 3. compIimelltarr maintenance plan with roadside assistance. '

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For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say By John Lauerman - Sep 30, 2010 10:00 AM ET

Recommend, : 1 : Tweet {2) Linkedln Share Email Print

For-profit colleges leave students with high debt and inadequate educations that can harm them

for years after they graduate or quit school, witnesses are scheduled to testify today at a Senate

hearing in Washington.

Recruiters enticed Danielle Johnson, a mother from Iowa, to enroll in Washington Post CO.'s

Kaplan education unit, saying she could train at home to be a nurse, a claim that turned out to be

untrue, she said in testimony prepared for today's Senate Health, Education, Labor & Pensions

Committee hearing. Kaplan refused to release her transcripts, preventing her from transferring

into a cheaper community college, she said.

While working students must have access to programs that fit their schedules and training

requirements, they also need protection from the predatory recruiting programs and lending

fraud uncovered by a government probe of education companies, said Arnold Mitchem,

president of the Council for Opportunity in Education, in prepared comments for the hearing.

"Access is critical, but access to what?" Mitchem said in the prepared testimony. "Mountains of

debt?"

For-profit colleges represent about 12 percent of U.S. college students, according to the

Association of Private Sector Colleges and Universities, a Washington-based industry group

formerly called the Career College Association. Those students account for about a quarter of

U.S. student loan dollars, said Lauren Asher, president of the Institute for College Access and

Success, an advocacy group based in Oakland, California, in comments prepared for the hearing.

'Severe' Consequences

About 43 percent of all former students who defaulted by 2010 on loans they began paying offin

2008 were from for-profit colleges, Asher said. The consequences of those defaults are "severe

and long-lasting," she said in her remarks.

"You will likely be hounded by collectors, and your debt will increase significantly because of

default and collection fees," Asher said in her prepared comments. ''You cannot get federal

grants or loans to return to school, and the debt can follow you until you die. There is no statute

of limitations, and the government can garnish your wages, seize your tax refunds, and

eventually take a slice of your Social Security check."

For-profit colleges have helped improve the lives of many students who earlier failed at

traditional, nonprofit universities, said Harris Miller, president and chief executive officer of the

for-profit colleges' trade group.

'Anecdote Game'

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htlp:llwww.bloomberg.comlnews/20 1 0-09-30/for-profit-colleges-seeking-loans-rob-stude... 10/12/2010

For-Profit Colleges Seeking Loans 'Rob' Students, Senate Testimony to Say - Bloomberg Page 2 of4

"We can all play the anecdote game," Miller said in a telephone interview before the hearing

began. "We have plenty of students who would be glad to tell the committee how OUf schools

have turned their lives around."

About 1,500 students, teachers and administrators rallied in front of the U.S. Capitol building

yesterday to oppose proposed industry regulations that would force for-profit colleges to show

that graduates are repaying their loans and make enough to afford repayment.

"All State does a great job of preparing you to present yourself for ajob," said Sarah Martin, 22, a

student at All State Career School in Baltimore who rode to Washington on one of six buses the

college sent to the rally.

"It's up to you to take advantage of the situation," Martin said.

For-profit colleges have come under fire since a government report released Aug. 4 found that

recruiters at 15 colleges misled students to boost enrollment. Senator T0111 Harkin, the Iowa

Democrat who heads the education committee, said he plans to hold another hearing the first

week in December. Harkin said he will release information at today's hearing collected from

education companies.

No Degree

"The companies get the profits, and the students get the debt," Harkin said in a telephone

interview before the hearing. "And many times they don't even get a degree."

Deceptive marketing has hurt low-income, minority students across the U.S., Mitchem said in

his prepared testimony. Mitchem's group submitted a list of stories from students who said they

had been misled by recruiters and administrators.

D'angelo Walker, a former student at Hoffman Estates, Illinois-based Career Education Corp.'s

Sanford-Brown College whose story was included in the submission, said his degree failed to

help him get a job, and other colleges won't accept the credits he earned.

Starting Over

"I feel like I've been robbed," Walker said in the testimony. "Every school is telling me that 1 will

have to start over."

Almost half of the students at for-profit colleges are minorities and about two-thirds of the

schools' students have incomes below the median for all undergraduates, Asher said. These

students are three times as likely to borrow to pay for their education as those attending

nonprofit colleges, Asher said.

"The data clearly show that across levels of income and categories of racejethnicity, for-profit

college students borrow more than those who attend elsewhere," she said in her testimony.

Kathleen A. Bittel, who works in Education Management Corp.'s Art Institute of Pittsburgh

online divi~ion, al~o is scheduled to testify at the hearing. The company assembled deceptive

career-placement data by counting entry-level jobs at Toys "R" Us, Starbucks and a convenience

store as related to students' degrees, Bittel said in a letter to Congress obtained by Bloomberg

News. The company investigated Bittel's claims and determined they were unfounded,

Education Management said yesterday in a statement.

Education Secretary Arne Duncan said in August that he will beef up his department's

enforcement ann to help stamp out predatory recruitment practices. The Education Department

is preparing to publish rules that strengthen sanctions for recruiters who mislead applicants,

and require for-profit colleges to tell students how many students graduate and get placed in

jobs.

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http://www.bloomberg.comlnews/20 1 0-09-30/for-profit-colleges-seeking-loans-rob-stude... 10/12/2010

[!MedVance --lll:SI'I'r(!Tf~--

2009· MedVance Institute Overview·. Palm Springs -Campus

A Vision For The Future A Commitment To Excellence

MedVartce Institute is dedicated to preparing qualified candidates for careers in the medical field and has been doing so for decades. .

·.Achieve your educational goals in a supportive environment • Choose from a variety of medical training programs • Complete your medical career training in 7 to 24 months • Enjoy the convenience of day, afternoon, and evening class schedules • Experience the benefit of small classes and hands-on learning • Gain valuable real world experience through externships • Learn from qualified instructors who are highly trained professionals

Graduates work in a variety of medical settings including hospitals, laboratories, physicians' offices, long-term care facilities, home· health care businesses, radiology and surgical centers, cancer treatment facilities, insurance

companies, and other medical businesses.

MedVance Institute has campuses in many states offering Certificate, Diploma, Occupational Associate Degree, Associate In Occupational Studies, and Associate of Applied Science Degree Programs .

Our Purpose: Innovatively Creating Opportunities ... IT'S PERSONAL

At MedVance lnstihlte, INNOVATION is the key to our success. What we do, healthcarc career training, is highly regulated and standardized throughout our industry. However, how we do what we do is up to us. What does that

mean? It means we have the ability to create an experience that is extraordinary and will keep our customers talking about us long after graduation. Innovation is key to unlocking that extraordinary experience. Innovation means

thinking differently about something familiar. H's about going beyond the ordinary and creating something better.

CREATING OPPORTUNITIES is our core purpose. Every day we create opportunities for our customers, our communities and ourselves. Opportunities can take many foims. Just remember that for every obstacle ... there is an

. opportunity waiting to be discovered.

IT'S PERSONAL describes how we fulfill our purpose. We are accountable for ensuring our .customers receive a personal, friendly and supportive educational experience. We do not want them to feel like just another number.

They have made a commitment to us and to their future and we in turn, have a commitment to help ·them realize it. IT'S PERSONAL also serves a dual purpose and is an acronym for our values.

www.medvance.edu This catalog was prepared by McdVnncc Institute. Curriculum, tuition, fccs,-cxpcnscs, academic requirements, etc. arc subject to change at the discretion o'fthe

SchooL Information contained in this catalog is true and accurate to the best knowledge of the School's Administration.

Overview Palm Springs 49 © 2009 MedVance Institute. All rights reserved.

2009 Academic Programs .- Palm Springs Campus

Medical Office Administration

Diploma Program monthsJ36 ,:"e~ks .~.x..~!.u_~!!1g

PROGRAM OBJECTIVE The program is designed to provide students with the multidimensional skill sets required to excel in administrative roles today~ Students learn the basics of communications in healthcare which include medical tenninology, computers and practice management. Students also learn to navigate and manage databases, client infonnation, and the laws and ethics related to client data management. -This course also provides training to students in transcription, billing & coding, human resources, de;sktop publishing, records management and infonuatics, skills in business communications, accounting and the critical importance of strong customer service.

Upop completion of this program, graduates will be able to seek entry-level positions in healthcare facilities or other industries in an administrative support capacity, working in areas such as front office, admissions, client -relations~ office revenue, unit coordination, healthcare services administration and out-patient facilities offices. With strong skill sets in office technology, office- ma'nagement and customer service, the graduate will possess the knowledge and be positioned to work within the team dynamic required in healthcare administration today.

. PROGRAM OUTLINE

Course # Course Title Qtr Cr.ditl Clock Hours

AHCl40 HealthCare Facilities & Business 4.0/40 Infrastructure

MAS!03 Medical Office Procedures 6.0/80

MCSl05 Introduction to ICD-9 & CPT 3.0/40 Coding

COMIOI* Communications 4.0/40

OADl20 Computerized Accounting & 6.0/80 Fiscal Management

810117 Medical Terminology 4.0/40

OADIIO Word Processing 6.0/80

OADl30 Records Management & Unit 3.0/40

47

r5MedVance --\III~TII'\;'flt--

OADlOO

OAD140

OADl50

OADl60

TOTALS

Coordination

Keyboarding Skill Building & 2.0/40 10-Key Desktop Publishing 6.0/80

Transcription 5.-0/80

Human Resources 6.0/80

Qtr Credit Hours/ Clock Hours 55.0/720

• denotes general

COURSE DESCRIPTIONS

AHC140 Healthcare Facmtie~ & Business Infrastructure 4.0QH .In this course. students y.till learn the ethical expectations of all individuals working in healthcare regardless of their role. Students will develop reasonable expectations of the range of client reactions in the sensitive healthcare environment, as well as the appropriate response level that healthcare workers reasonably display. Students are trained in healthcare law related to patient information, HIPPA, safety and compliance with applicable local, -county, state and federal rules and regulations. This COurse includes instruction in Basic First Aid _including Bloodborne/Airborne Pathogens. 40 lecture ,hours. Prerequisite: None.

MASI03 Medical Office Procedures 6.0 QH Students will learn the primary duties performed in the medical office by the medical manager including compiling office policies and procedures, patient registration-, human resource functions, appointment scheduling, patient billing, medical insurance and basic coding. Students' will apply a practical approach to understanding these medical office procedures. Students also learn the fundamental principles of computer technology including computer concepts, tenninology and applications. 40 lecture hours/40 laboratory hours. Prerequisite: None.

MCSl05 Introduction to ICD-9 & CPT Coding 3.0 QH Students learn the theory and practice of coding medical services, supplies and equipment using the CPT manual. Shldents leam the technique for locating frequently used tenus in the manual index. Students also study' the ICD-9-CM systems and acquire an overview of the use of ICD-9 coding. 20 lecntre hours/20 laboratory hours. Prerequisite: None.

*COMlOl Communications 4.0QH Students will learn the concepts of adaptation and critical thinking in verbal and written communication. Upon successful completion of this course, students will demonstrate confidence and credibility in communicating in a range of communication situations. 40 lecture hours. PrerequiSite: None.

OAD120 Computerized Accounting & Fiscal Management 6.0 Q H This course includes an overview of basic mathematical skills including addition, subtraction, multiplication, division, fractions, decimals, and solving word problems. Students also learn foundational skills involving management of money including banking"interest, checkbook maintenance and reconciliation of bank accounts. Simple procedures for accurately maintaining a petty cash fund, as well as costs and ordering office supplies are covered. Snldents will learn basic bOOkkeeping and accounting principles in a fiscal cycle using manual forms, as well as fonnatting & calculating

1 :

: II II

II i) I I I i I \ i :

. ,

2009 Academic Programs· Palm Springs Campus

MEDICAL BILLING & CODING SPECIALIST Diploma Program

PROGRAM OBJECTIVE The Medical Billing & Coding 'Specialist program prepares students to analyze medical records and asstgn codes to medical conditions, diagnoses and procedures using a complex healthcare coding and classification system. Accurate codes are essential for research, statistical data and for detennining reimbursement of health care services.

Students build knowledge and skill in CPT (Common Procedural Terminology) and ICD-9 and lCD-l0 (International Classification of Diseases, 9,th & 10th Editions) coding as well as commonly used medical billing and medical record software systems. A strong foundation in the biosciences, medical law and ethics and career readiness provide a balanced education, preparing graduates to work effectively in the medical environment.

Graduates t!nd entry-level cmploymcnt opportunities in physician's offices, billing offices, hospitals, assisted living facilities, clinics, insurance companies, medical financial consulting practices and private, practice. Graduates are able to sit for the AAPC (American Academy of Professional Coders) and AHIMA (American Health Infonnation Management Association) Professional Coder certification examinations.

PROGRAM OUTLINE

Course # Course Title Qtr Creditl Clock Hrs

AHCl40 Hcalthcare Facilities,& Business 4.0/40 Infrastructure

AHCI47 Professional Development 4.0/80

AHC235 Career Development 2.0/40

Br0102' Anulurny & Phy~iology If 4.0/40

BrOIl3' /\ nat<Jrny & Physiology II 4.0140

MAS 103 lvkdical OffIce Procedmes 60/80

MCS105 Introduction to fCD-9 & CPT 3.0/40 C'o ... ting

44

eMedVance __ t,'i't'T\l'l f n' __

"''''''~I·''''"'''''''('c'",,,,n,.l",,'1-

MCSI07 Basic Insurance~ Delinquent Claims, & CoUections

MCSI09 Radiology, P9-thology & Medicine Coding'

MCSlll Anesthesia Coding, Pharmacy Coding & HCPCS

MCSll2 Evaluation & Management Coding & Modifiers

MCSl23 Surgery Coding

MCSl24 Insurance Verification. Claim Denials & Appeals

MCSl25 -Insurance Regulations & MedicarefMedicaid

MCSl75 ICD-9 & lCD-to Coding

MCSI85 Computerized Practice ManageIl}ent

MCSl86 Hospital Billing

MCSl88 Electronic Medical Records

MCS225 Medical Billing & Coding Extemship

TOTAL Qtr Credit HoursJClock Hours

*Denotes General Education course

COURSE DESCRIPTIONS

ACHl40 Healtncare Facilities & Business J nfrastructure

4.0/40

3.0/40

3.0/40

3.0/40

6.0/80

3.0/40

3.0/40

5.0/80

3.0/40

3.0/40

2.0/40

4.0/128

69.0/1008

4.0QH In this course, students \"ill learn the ethicat expectations of all ;ndividual~ working in he_althcare regardless of their role. StUdents will develop reasonable expectations of the range of client reactions in the s~llsili\'~ hca!thcarc environment, as \vcll tbe appropriate response level that healthcare '\vorkers reasonably' display. Students arc trained in heal theme law related to patient infotlllation, HlPPA. safety and compHance with applicable locaL county, state and. tcd~ra! fuks and r(;gu\ations. This course include.s IllstrlLction III Basi...: Firsl Aid including Bloodbomc!,t\irborne Pathogens. 40 Iccnlf0 hours. Prerequisite: None:.

AHC147 Professional Development 4.0 QH This course is CH) orientation to the world or work Professional business protocol, professional presence: and a cllstotncr-firsL attitude arc explored and discussed. Student") learn tll develop a standard of excellence and pride in work and _address ethics. trust, respect.

. strategic thinking, and leadership. Students \viH also gain skills in. time management, stress lnanagemeti.t, goal setting, communicating, presenting ideas and concepts as well as thinking critically and creatively. 25 .lecture hours!55 laboratoty hours. Pr'erequisitc: None

AHC235 Career Development t.O QH Students karn to prepare for the job search including researching prospective employers,_ performing self a~sessment evaluations, composing effective resumes, and developing techniques for successfhl interviews. Students also review for certifications. This course includes instruction in Basic First Aid including use of an AED, Adult, Child, and Infant CPR and Bloodbome/Airbome Pathogens. 10 leelme hours/30 laboratory hours. Prerequisite: None

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Review Words M A N G I 0 P L A S T Y A R T H R 0 D E S I S P N E N A R T H R 0 D E S I S A N P E T E C H I A E T I T U 0 S L E M B 0 L E C T 0 M Y Y E M E R G E N C Y T E Y I C Y S U P I N E I N P N E U M 0 N E C T 0 M Y V C S S I I S Y L L T C Y C N E G R E M E M C V A U I N E A U S S S L A A I A 0 C C L U S I 0 N L A N P T E D T 0 L T A T L I C C A B L L E M E R G E N C Y A G 0 S T P C S P E T E C H I L A A I 0 S T Y I I E R R R I P C E C I A M P D U T Y G T C R A Y C S L P U E H D U F M T 0 I 0 B C 0 B S N T S C S G N I L I C M T B I A B A E H S A 0 A R I I N E I U N E L A D A E R N P 0 0 C P C Y I M L L S D S H N D B G A R N U C A P R U L N T E H I S A E I N A 0 E A S R C Y P Y M C E P I E E L T C I T Y N C E I C C I 0 E C C C M C U T E F CW E E N S A 0 L Y T Y I S 0 A M U H P 0 A Y E T L T S U P I N E E C A T 0 Y 0 L T E B A I T V C C E U o p S D S N I N C I A L M T T Y A A R A C E N H C 0 M S U P I N E I S H E T E Y H C S I G E E N E I H R Y E E I E G F S E N I P U S L B A I E 0 N T G A I 0 I S A T R I E S I N 0 G R A P H Y R S P 0 R R E A S R S E E T C T R A C T R L Y S I S E T N M I E Y E C C S M R E Y M 0 T C E L 0 B M E S 0 C D U C M T V 0 N E E N M C D 0 S I M E T R Y S U P I E E L E I 0 P Y C L E L C I R T N E V C T I 0 T N E P N E N S V Y E A E E E C A N 0 I T A T S E F I N A M P P P S N R C D I S A L R 0 U T I N E C H A R G E E N C U E P I Y E L C I R T N E V Y T r- U R A T I V E '-'

0 C 0 C D E D N B U C C A L C R N N 0 I S U L C C 0 I C T E D N 0 0 D I S T A L 0 E Y Y R T E M I S 0 D T U M N I I S I N E C 0 N T C R T E T W N E W E U C A B I L Y P I T N S A VV A A T S D I S T A L H R T Y C S G A C U M C T R I R R E A Y H P A R G 0 N I S I I I N C N S E A P N I 0 M L N A D R N L A C C U B C F S I I E C T R C P H I P R 0 U T I N E C H A R G E I E D D G I R T S T S 0 0 T T T N E I T A P N I P Y T D N E R N Y E S 0 I B U C C A L A T S I D E U C D R 0 E M E P R L D G E G R A H C E N I T . U 0 R P A 0 E R T C M A V E N T R I T S I S E T N E C A R 0 H T C H A Y E T E A S I S E T N E C A R 0 H T S T B A C E T C A D I N W E N I P U S S U P I N E D I S T A L R R A Y N E E P U S N 0 I T A T S E F N A M Y E p A R P R N T I Y F N P 0 I I G N I D N E T T A E C 0 C Y 0 E T I R N I C T T E I N S E I A I E I M N 0

Name __________ _ Date (Key # 1 - 601846)

Use the clue to figure out the word. Write the word and find the word in the word search puzzle.

1. type care provided in the ER; doesn't matter if the patient is new or established

Write the word: ________ _

found ___ time(s) in the puzzle

2. Prior authorization from a payer that must be received before elective hospital-based or outpatient surgeries are covered; also preauthorization or authorization.

Write the word:


3. closure of a blood vessel



4. one who has been formally admitted to a health care facility

Write the word:


5. the physician with the pr;manj responsibility for care ofthe patient

Write the word: _-, ______ _

found ___ time( s) in the puzzle

6. surgical or perQ procedure in a vessel to dilate vessel openings; used to treat arteriosclerosis disease

Write the word: __________ _


7. The total of the costs ofal! supplies that are customarily used to provide the service; items included in the routine charge should not be billed separately.

Write the word: _____________ _


8. suffix meaning to release or free

Write the word: ____ _

found ___ iime(s) in the puzzle

9. Characteristic sign or symptom of a disease.

Write the word: ____________ _


10. nothing by mouth

Write the word: __ _


11. the organ system relating to lungs, nose and sinuses



12. procedure for viewing interior or the body using x-rays and projecting it onto a TV screen



• Name ____________________ __

13. lying on the back

Write the word: _____ _

found ______ time(s) in the puzzle

14. removal of total lung


found ____ time(s) in the puzzle

15. farther from the point of attachment or origin

Write the word: _____ _


16. type of patient who has not received services within the past 3 years

Write the word: __ _


17. Tablet placed in the mouth between cheek and gum for absorption

Write the word:


18. removal of fluid from thoracic cavity


found ___ -time(s) in the puzzle

Date (Key # 1 - 601846)

19. Payment criterion of payers that requires medical treatments to be appropriate and provided in accordance with generally accepted standards of medical practice.

Write the word:


20. before meals

Write the word:

found ____ time(s) in the puzzle

21. removal of blockage from the vessels



22. surgical immobilization of a joint



23. Fee for services other than room and board provided during a patient's hospitalization, such as anesthesia, pharmacy, supplies, and therapies.

Write the word:


24. application of force to a limb

Write the word: _______ _


. ,

Name

25. radiographic recording of the sinus or sinus tract

Write the word: _________ _

found time( s) in the puzzle

26. chamber in lower part of the heart



27. scientific calculation of radiation emitted from various radioactive sources



28. small pinpoint hemorrhages



29. Medication prescribed to kill or remove the causative agent of a disease

Write the word: _______ _


30. after meals

Write the word:


Date (Key # 1 - 601846)

• Answer Key: Key # 1 - 601846

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R 0 H I E T I 1 M B R G N C Y I S U N E T 0 M Y

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