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Department ealth
ty Agency Clerk
Final Order No. DOH-13-0501- 6 -MQA
FILED DATE _MAR 1 1 2013
STATE OF FLORIDA BOARD OF DENTISTRY
DEPARTMENT OF HEALTH, Petitioner,
VS. Case No.: 2010-21138 License No.: DN 13667
DANA CUCULICI, DMD, Respondent.
FINAL ORDER ADOPTING SETTLEMENT AGREEMENT
This matter appeared before the Board of Dentistry at a duly-noticed public meeting on February
22, 2013, in Tampa, Florida, pursuant to Sections 120.569 and 120.57(4), Florida Statutes for
consideration of a Settlement Agreement (attached hereto as Exhibit "A"). Petitioner was
represented by Adrienne Rodgers, Assistant General Counsel. Respondent was present and was
represented by Randolph Collette, Esquire. Upon consideration of the Settlement Agreement,
the documents submitted in support thereof, the arguments of the parties and otherwise being
advised in the premises, it is hereby
ORDERED AND ADJUDGED that the Settlement Agreement be and is hereby approved and
adopted in toto and incorporated by reference herein. Accordingly, the parties shall adhere to
and abide by all the terms and conditions of the Settlement Agreement. Costs are assessed in the
amount of $6,728.73. This Final Order shall take effect upon being filed with the Clerk of the
Department of Health.
DONE AND ORDERED this /7 day of MARCH , 2013.
BOARD OF DENTISTRY
Sue Foster Executive Director on behalf of Daniel Gesek, DMD, CHAIR
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic mail to Dana Cuculici, DMD, do Randolph Collette, Esquire, R( ollertc a t bed ociors.c(mi; David D. Flynn, Assistant Attorney General, day id.li fin ir 1,1‘ Iloridalc4tal.coin ; and Adrienne Rodgers, Assistant General Counsel, Department of Health, karieniic (1011,st:1c.11.11. this 1t day of MARCH, 2013.
atAriced,
Deputy Agency Clerk
a STATE OF FLORIDA BOARD OF DENTISTRY
DEPARTMENT OF HEALTH,
Petitioner,
v. CASE NO. 2010-21138
DANA CUCULICI, D.M.D.,
Respondent.
SETTLEMENT AGREEMENT
Pursuant to Section 120.57(4), Florida Statutes, the above named
parties hereby offer this Settlement Agreement (hereinafter "Settlement
Agreement" or "Agreement") to the Board of Dentistry (hereinafter
"Board")1 as disposition of the Administrative Complaint, in lieu of any other
administrative proceedings. The terms herein become effective only if and
when a Final Order accepting this Agreement is issued by the Board and
filed with the Agency Clerk of the Department of Health. In considering
this Agreement, the Board may review all investigative materials regarding
For purposes of this Settlement Agreement, where terms of the Agreement require the Board to undertake action or grant approval, the Board can appoint a representative or designee to act in its stead. In light of this, references to the "Board" can also refer to the Board's designee.
Page 1 Respondent initialW
this case. If this Agreement is not accepted by the Board, the Agreement
and its presentation to the Board shall not be used against either party.
STIPULATED FACTS
1. For all times pertinent herein, Respondent was a licensed
dentist in the State of Florida, having been issued license number 13667.
2. Respondent's address of record is 4917 Ehrlich Road, Suite 100,
Tampa, FL 33624.
3. Respondent was charged by an Administrative Complaint with
violating Chapter 466.028, Florida Statutes. The Administrative Complaint
was filed by the Department of Health (hereinafter "Department") and
properly served upon Respondent.
4. Respondent neither admits nor denies the factual allegations in
the Administrative Complaint and is entering into this Settlement
Agreement for the purpose of settlement in these administrative
proceedings only.
STIPULATED LAW
1. Respondent admits that Respondent is subject to the provisions
of Chapters 456 and 466, Florida Statutes, and the jurisdiction of the
Department of Health and the Board.
Page 2 Respondent Initial cp
2. Respondent admits that the stipulated facts, if proven true,
constitute violations of Florida laws as alleged in the Administrative
Complaint.
3. Respondent admits that the Settlement Agreement is a fair,
appropriate, and reasonable resolution to this pending matter.
PROPOSED DISPOSITION
1. APPEARANCE: Respondent shall be present when this
Settlement Agreement is presented by the Department to the Board, and
under oath, Respondent shall answer questions posed by the Board
concerning this case and the disposition thereof.
2. DISCIPLINE: Respondent's license shall receive a Letter of
Concern.
3. FINE: The Board shall impose an administrative fine of six
thousand dollars ($6,000) against the license of Respondent. Respondent
acknowledges that the timely payment of the fine is Respondent's legal
obligation and responsibility. Respondent shall pay the fine by either
cashiers check or money order made payable to the Board of Dentistry
within eighteen months of the filing of the Final Order issued in this matter.
Respondent shall send payment(s) to: Florida Department of Health,
Page 3 Respondent Initlarp
Division of MQA/Client Services, P.O. Box 6320, Tallahassee, FL
32314-6320.
4. COSTS: Pursuant to Section 456.072(4), Florida Statutes,
Respondent shall pay all actual costs associated with the investigation and
prosecution of this matter. Actual costs will be determined at the time this
Settlement Agreement is presented to the Board, but shall not exceed
$6,728.73, if this Agreement is accepted no later than December 7,
2012. Respondent shall pay all costs by either cashiers check or money
order made payable to the Board of Dentistry within eighteen (18) months
of the filing of the Final Order issued in this matter. Respondent shall send
payment(s) to: Florida Department of Health, Division of
MQA/Client Services, P.O. Box 6320, Tallahassee, FL 32314-6320.
5. CONTINUING EDUCATION: Within eighteen (18) months of
the filing of the Final Order adopting and incorporating this Agreement,
Respondent shall successfully complete a minimum of three to six (3-6)
hours of continuing education in the subject[s] of: diagnosis and
treatment, and crown & bridge to be taken in person at or through an
accredited college of dentistry; and Respondent shall successfully complete
a minimum of three to six (3-6) hours of continuing education in the
subject[s] of: record keeping, and ethics to be taken at or through an
accredited college of dentistry or Board-approved course provider whose
Page 4 Respondent Initial:7D C-
course is specifically approved to satisfy the final order, unless another
subject area is designated by the Board. These continuing education hours
shall be in addition to the continuing education hours normally required for
renewal of Respondents license. Home study courses will not be accepted
to satisfy this condition, Upon completion of the course, Respondent shall
provide documentation to the Board verifying of successful completion and
documentation of course content shall be submitted to the Compliance
Officer at the address referenced in paragraph three (3). Should
Respondent be unable to demonstrate the level of competency
recommended by failing to achieve competency within the assigned
level, Respondent shall be restricted from performing those dental
procedures until remediation is completed.
6. PATIENT REIMBURSEMENT: Respondent shall refund to
the patient(s), identified by his/her initials in the Administrative
Complaint, the amount of the "out-of-pocket" fees and costs that
the patient(s) paid to the Respondent. Also, the Respondent shall refund to
any third party payor, if applicable, the amount paid on behalf of the
patient(s) identified herein for the treatment that the Respondent provided in
this cause. Proof of payment must be made available to the Department's
prosecuting attorney prior to presenting this settlement to the Board of
Page 5 Respondent Initial(.0C
Dentistry.
7. LAWS & RULES EXAM: Respondent shall thoroughly review,
study and possess a clear understanding of the laws and rules governing
the practice of Dentistry in the State of Florida, specifically including but
not limited to: chapters 456 and 466, Florida Statutes, and the Rules of the
Board of Dentistry. Within twelve (12) months of the filing of the Final
Order adopting and incorporating this Agreement, Respondent shall pass
the Laws & Rules Examination governing the practice of dentistry in the
State of Florida.
8. SERVICE AS A QUALIFIED MONITOR: Respondent
understands that Respondent shall not him/herself serve as a "qualified
monitor" until Respondent has complied with all of the obligations imposed
by the Final Order adopting and incorporating this Agreement.
Furthermore, if Respondent is serving as a "qualified monitor," at the time
the Final Order in this case is filed, Respondent shall provide written notice
of the Final Order and terminate all monitory relationships within one (1)
day of the filing of the Final Order.
9. VIOLATION OF TERMS: It is expressly understood that
Page 6 Respondent InftlaITC,
violating any of the terms of this Agreement shall be considered a violation
of a Final Order of the Board, for which disciplinary action may be initiated
pursuant to Chapters 456 and 466, Florida Statutes.
10. SETTLEMENT AGREEMENT SUBJECT TO BOARD
APPROVAL: It is expressly understood that this Agreement is subject to
approval by the Board and has no force or effect until the Board adopts,
incorporates or bases an Order, properly filed, upon it.
11. BOARD REVIEW NONPREJUDICIAL TO FURTHER
PROCEEDINGS: Respondent executes this Agreement for the purpose of
avoiding further administrative action with respect to this particular case.
In this regard, Respondent authorizes the Board to review and examine all
investigative file materials concerning Respondent prior to or in conjunction
with consideration of this Agreement. Respondent agrees to support this
Agreement at the time it is presented to the Board and shall offer no
evidence, testimony, or argument that disputes or contravenes any
stipulated fact or conclusion of law. Furthermore, should the Board not
accept this Agreement; the parties agree that the presentation and
consideration of this Agreement and other documents and matters by the
Board shall not unfairly or illegally prejudice the Board or any of its
Page 7 Respondent Initia0C
members from further participation, consideration or resolution of these
proceedings.
12. ADDITIONAL PROCEEDINGS: Respondent and the
Department of Health fully understand that this Agreement and subsequent
Final Order incorporating same, will in no way preclude additional
proceedings by the Board and/or Department of Health against the
Respondent for acts or omissions not specifically set forth in the
Administrative Complaint, attached hereto as Exhibit "A," filed in this cause.
13. WAIVER OF ATTORNEY FEES: Respondent waives the right
to seek attorney fees and/or costs from the Department of Health in
connection with this disciplinary proceeding.
14. WAIVER OF JUDICIAL REVIEW AND CHALLENGE: Upon
the Board's adoption of this Agreement, Respondent expressly waives all
further procedural steps, and expressly waives all rights to seek judicial
review of or to otherwise challenge or contest the validity of this
Agreement and the Final Order of the Board incorporating said Agreement.
WHEREFORE, the parties hereby request the Board to enter a Final
Order accepting and implementing the terms contained herein.
SIGNED this a21 day of it/ , 2012.
Page 8 Respondent Initial TC
My Commission Expires
(7,1 2012.
John H. Armstrong, MD State Surgeon Gener and
Jeff G. Peters Florida Bar Number 718343 Assistant General Counsel Department of Health Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 (850) 245-4640 voice (850) 245-4683 FAX 3GP
etary of Heait
-4A ce.d.Q Dana Cuculici, D.M.D. Case No. 2010-21138
STATE OF FLORIDA COUNTY OF '
Before me personally appeared
whose identity is known to me by personal knowledge or by presentation of as identification (type of
identification), and who acknowledges that their signature appears above. Sworn to or affirm or- me this D. of
2012.
No ary Public ,
APPROVED this 17 day of
Page 9 Respondent Initial.
STATE OF FLORIDA DEPARTMENT OF HEALTH
DEPARTMENT OF HEALTH,
PETITIONER,
v.
DANA B. CUCULICI, D.M.D.
RESPONDENT. /
CASE NO. 2010-21138
ADMINISTRATIVE COMPLAINT
COMES NOW Petitioner, Department of Health, by and
through its undersigned counsel, and files this Administrative
Complaint before the Board of Dentistry against the Respondent,
Dana B. Cuculici, D.M.D., and in support thereof alleges:
1. Petitioner is the state department charged with regulating
the practice of Dentistry pursuant to Section 20.43, Florida Statutes;
Chapter 456, Florida Statutes; and Chapter 466, Florida Statutes.
2. At all times material to this Complaint, Respondent was a
licensed dentist within the State of Florida and was issued license
number DN 13667.
3. Respondent's address of record is 4917 Ehrlich Road,
Suite 100, Tampa, Florida 33624.
4. Respondent provided treatment to Patient T.G., Patient
T.G. is also known as Patient P.G., from on or about February 21,
2006, through on or about October 8, 2009,
5. On or about February 21, 2006, Patient T.G. presented as
a new patient to Respondent's practice. This was a consultation visit
concerning the overall appearance of Patient T.G.'s teeth. The
treatment notes documented that an estimate was given to Patient
T.G.
6. On or about February 22, 2006, Patient T.G. returned to
Respondent. The Respondent performed a new patient exam and a
FMX (full mouth series of radiographs) was exposed. The electronic
treatment notes documented a perio (periodontal) charting was
completed, and that no pockets were noted. There was no
documentation of the perio exam in the treatment records. There
was no documentation of a Medical History, charting of existing
conditions or complete soft tissue exam. An oral cancer check was
not performed/noted. The Respondent's treatment records did not
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contain a complete Treatment Plan. After an examination, the dentist
should formulate a comprehensive treatment plan with alternatives and
present the patient with the treatment plan to ensure full informed
consent. The Respondent failed to perform an adequate initial clinical
evaluation of Patient T.G. before initiating dental treatment. The
prevailing standard of care requires Respondent to complete a
comprehensive examination and adequately document the results in
the treatment notes. Respondent failed to meet these minimum
standards.
7. On or about February 28, 2006, Patient T.G. returned to
Respondent. The Respondent performed crown preps on teeth
numbers 23, 24, 25 and 26. Respondent failed to document in the
treatment notes any details about the temporaries. The Respondent
failed to adequately document the dental treatment that was
provided to Patient T.G. There is insufficient documentation for this
appointment to satisfy the recordkeeping requirement.
8. On or about April 6, 2006, Patient T.G. returned to the
Respondent. Respondent documented in the treatment notes that he
seated crowns on Patient T.G.'s teeth numbers 22 and 27. The
minimum standards of performance in diagnosis and treatment when
3
measured against generally prevailing peer performance requires a
dentist who permanently seats and places crowns to properly prep
the teeth being restored, and to properly make, seat and fit crown
restorations without open margins to prevent further recurrent decay
underneath the crown. Further, the dentist must check the margins
carefully to ensure that there are no open margins on the date that
they are permanently cemented, and must recognize and retreat any
and all open margins on that date or immediately treatment plan re-
treatment. Respondent failed to meet this minimum standard.
9. On or about April 12, 2006, Patient T.G. returned to the
Respondent. Respondent's treatment notes documented that a
bridge comprised of teeth numbers 11-14 was started, replacing
tooth number 13. Respondent's treatment notes document a build-
up of tooth number 14 was completed with a final impression. The
Respondent failed to document any details about the crown preps
for teeth numbers 11 and 14 and/or temporary restorations. A
treating dentist is required to keep written dental records justifying the
course of treatment of the patient. Respondent failed to meet this
standard.
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10. On or about May 1, 2006, Patient T.G. returned to the
Respondent. Respondent's treatment notes documented that teeth
numbers 21 and 28 were prepped for crowns. Respondent seated a
bridge for teeth numbers 11 through 14. The minimum standards of
performance in diagnosis and treatment when measured against
generally prevailing peer performance requires a dentist who
permanently seats and places crowns to properly prep the teeth
being restored, and to properly make, seat and fit crown
restorations without open margins to prevent further recurrent decay
underneath the crown. Further, the dentist must check the margins
carefully to ensure that there are no open margins on the date that
they are permanently cemented, and must recognize and retreat any
and all open margins on that date or immediately treatment plan re-
treatment.The Respondent failed to meet this standard.
11. On or about May 11, 2006, Patient T.G. presented back to
Respondent. Respondent's treatment notes documented "redo lower
crowns X 8." Respondent failed to document in the treatment notes
any details about why the "redo" was needed and failed to document
what teeth were involved. The Respondent failed to adequately
5
document the dental treatment that was provided to Patient T.G.
There is insufficient documentation for this appointment to satisfy the
recordkeeping requirement.
12. Patient T.G. was charged for dental treatment that may
have taken place on or about May 16, 2006. Patient T.G. was charged
for lumineers on teeth numbers 5, 6, 7, 8, 9, and 10. Respondent
failed to document in the treatment notes any details about the
lumineers. There is no documentation of any type of preparations or
impressions. The Respondent failed to adequately document the
dental treatment that was provided to Patient T.G. There is
insufficient documentation for this appointment to satisfy the
recordkeeping requirement.
13. On or about June 7, 2006, Patient T.G. presented back to
Respondent. The treatment notes documented that crowns were
seated on teeth numbers 22 through 27 and lumineers were placed
on teeth numbers 5 through 10. The minimum standards of
performance in diagnosis and treatment when measured against
generally prevailing peer performance requires a dentist who
permanently seats and places crowns to properly prep the teeth
being restored, and to properly make, seat and fit crown
6
restorations without open margins to prevent further recurrent decay
underneath the crown. Further, the dentist must check the margins
carefully to ensure that there are no open margins on the date that
they are permanently cemented, and must recognize and retreat any
and all open margins on that date or immediately treatment plan re-
treatment. The Respondent failed to meet this standard.
14. On or about June 13, 2006, Patient T.G. presented back to
Respondent. The treatment notes documented that Patient T.G.'s
lumineers were adjusted and polished. There is no documentation of
any diagnosis or justification for this dental treatment. The
Respondent failed to adequately document the dental treatment that
was provided to Patient T.G. There is insufficient documentation for
this appointment to satisfy the recordkeeping requirement.
15. On or about July 13, 2006, Patient T.G. presented back to
Respondent. Respondent's treatment notes documented that crowns
were seated and the lumineers were polished. The Respondent failed
to expose any radiographs to check the marginal integrity of the
crowns. The minimum standards of performance in diagnosis and
treatment when measured against generally prevailing peer
performance requires a dentist who permanently seats and places
7
crowns to properly prep the teeth being restored, and to properly
make, seat and fit crown restorations without open margins to
prevent further recurrent decay underneath the crown. Further, the
dentist must check the margins carefully to ensure that there are no
open margins on the date that they are permanently cemented, and
must recognize and retreat any and all open margins on that date or
immediately treatment plan re-treatment. The Respondent failed to
meet this standard.
16. On or about September 18, 2007, Patient T.G. presented
back to Respondent. Respondent's treatment notes documented that
tooth number 10 needed a three surface resin restoration, and tooth
number 3 needed the restoration replaced (that Respondent had placed
on or about March 14, 2006). There is documentation that the
lumineers for teeth numbers 5, 6, 7, 8, 9 and 10 were delivered. There
is no documentation concerning the removal of the existing veneers or
impressions, for replacement. The Respondent failed to adequately
document the dental treatment that was provided to Patient T.G.
There is insufficient documentation for this appointment to satisfy the
recordkeeping requirement.
8
17. On or about October 25, 2006, Respondent's treatment
notes documented that Patient T.G. felt the lumineers weren't shiny
enough. This treatment note also documented for the first time that
gingival inflammation is present, especially in the mandibular
anteriors.
18. On or about October 27, 2008, Patient T.G. presented
back to Respondent. The treatment notes documented that the
lumineer on tooth number 5 was removed and a new lumineer was
recemented. No other details concerning the dental treatment are
documented. The Respondent failed to adequately document the
dental treatment that was provided to Patient T.G. There is
insufficient documentation for this appointment to satisfy the
recordkeeping requirement.
19. Patient T.G. saw two periodontists, Dr. Rasmussen and Dr.
Johnson. Both periodontists documented periodontal complications
from both the mandibular anterior crowns due to marginal fit and
facial contour. Three general dentists agreed with this assessment.
Dr. Wise, Dr. Holbrook, and Dr. Muenchinger agreed with the
assessment by the periodontists. Dr. Muenchinger also documented
occlusal issues with Patient T.G.'s posterior teeth.
20. The final crowns Respondent fabricated/seated at Patient
T.G.'s teeth numbers 22 through 27, fit poorly with unacceptable
margins (poor marginal integrity). The crowns on teeth numbers 21
and 28 had unacceptable distal contacts that led to food impaction.
Radiographs revealed radiolucencies suggestive of caries (cavities)
on teeth numbers 4, 5, 8 and 9.
21. The minimum standards of dental performance require a
dentist who seats and places crowns to properly make, seat and fit
crown restorations without open margins to prevent further
recurrent decay and/or other post-op problems underneath or at
gum tissue surrounding the crowns. A dentist permanently seating
crowns should adequately detect any malocclusion of the crowns, as
well as detect poor fit/marginal discrepancies prior to, and/or post-
seating of the crowns with adequate clinical and/or radiographic
exam. Any malocclusion, particularly affecting bite/contact, and/or
marginal discrepancies in a permanently seated crown should be
addressed and remedied by the treating dentist, after the patient is
informed of the problem. The Respondent failed to meet these
standards.
COUNT I: STANDARD OF CARE
22. Petitioner re-alleges and incorporates paragraphs one (1)
through twenty-one (21) as if fully set forth herein.
23. Section 466.028(1)(x), Florida Statutes (2006-2008),
provides that "[b]eing guilty of incompetence or negligence by failing to
meet the minimum standards of performance in diagnosis and
treatment when measured against generally prevailing peer
performance, including, but not limited to, the undertaking of diagnosis
and treatment for which the dentist is not qualified by training or
experience or being guilty of dental malpractice[,]" shall constitute
grounds for disciplinary action by the Board of Dentistry.
24. The Respondent failed to meet the minimum standards of
performance in the diagnosis and treatment of Patient T.G. when
measured against generally prevailing peer performance, in one or
more of the following ways:
a) Respondent performed defective crown restoration treatment on mandibular anterior crowns teeth numbers 22 through 27, in Patient T.G.'s mouth on or about June 7, 2006, with the final restoration permanently seated by Respondent exhibiting poor marginal integrity, and/or poor fit;
11
b) Respondent performed defective crown restoration treatment on teeth numbers 21 and 28, in Patient T.G.'s mouth on or about June 7, 2006, leaving unacceptable distal contacts that led to food impaction;
c) Respondent provided insufficient periodontal care for Patient T.G. including, but not limited to, a failure to perform a complete periodontal charting; and/or
d) Respondent placed veneers on teeth numbers 4, 5, 8 and 9, but failed to diagnose and/or adequately treat the caries present in those same teeth, in Patient T.G's mouth on or about September 18, 2007.
25. Based upon the foregoing, Respondent's license to
practice dentistry in the State of Florida is subject to discipline
pursuant to Section 466.028(1)(x), Florida Statutes, for being guilty
of incompetence or negligence by failing to meet the minimum
standards of performance in diagnosis and treatment when
measured against generally prevailing peer performance, including,
but not limited to, the undertaking of diagnosis and treatment for
which the dentist is not qualified by training or experience or being
guilty of dental malpractice.
12
COUNT II: DEFICIENT RECORDKEEPING
26. Petitioner re-alleges and incorporates paragraphs one (1)
through twenty-one (21) as if fully set forth herein.
27. Section 466.028(1)(m), Florida Statutes (2006-2008),
provides that failing to keep written dental records and medical
history records justifying the course of treatment of the patient
including, but not limited to, patient histories, examination results,
test results, and X rays, if taken, constitutes grounds for disciplinary
action by the Board of Dentistry.
28. Rule 64B5-17.002(b), Florida Administrative Code,
provides that for the purpose of implementing the provisions of
Section 466.028(1) (m), Florida Statutes, a dentist shall maintain
written records on each patient which written records shall inter
contain the results of clinical examination of the patient and tests
conducted, including the identification, or lack thereof, of any oral
pathology or diseases, treatment plan proposed, and actual
treatment rendered to a patient.
29. Respondent failed to keep written dental records and
medical history records justifying the course of treatment of Patient
T.G. in one or more of the following ways:
13
a) By failing, on or about February 22, 2006, to adequately document Patient T.G.'s presenting conditions. An examination was completed, but was not adequately documented. There was no charting of existing conditions or complete soft tissue exam, no documented Periodontal Evaluation, periodontal pocket probings or periodontal diagnosis, and no evidence of a medical history;
b) By failing, on or about February 28, 2006, to adequately document details about the temporaries during the course of dental treatment;
c) By failing to document a comprehensive treatment plan being provided to Patient T.G., during the course of treatment;
d) By failing, on or about September 18, 2007, to adequately document anything regarding the removal of Patient T.G.'s existing veneers or impressions for replacement; and/or
e) By failing to take and/or maintain adequate diagnostic comprehensive radiographs, necessary to justify the course of treatment.
30. Based on the foregoing, Respondent has violated Section
466.028(1) (m), Florida Statutes (2006-2008)1 including but not
limited to Rule 64B5-17.002(b), by failing to keep written dental
records and medical history records justifying the course of treatment
14
H. Frank Farmer, Jr., M. State Surgeon General
D., Ph.D., F.A.C.P.
of Patient T.G., and Rule 64B5-14.010, failing to keep records
required when pediatric conscious sedation is administered.
WHEREFORE, Petitioner respectfully requests that the Board of
Dentistry enter an order imposing one or more of the following
penalties: permanent revocation or suspension of practice, restriction of
practice, imposition of an administrative fine, issuance of a reprimand,
placement of Respondent on probation, corrective action, refund of fees
billed or collected, remedial education and/or any other relief that the
Board deems appropriate.
SIGNED thisq-f-/ day of
2012.
Jeff G. Peters Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar # 718343 850.245.4640 FAX: 850.245.4683
PCP: 02-17-12 PCP Members: JTM, CM, & FG
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FILED DEPARTMENT OF HEALTH
DEPUTY CLERK
CLERK Angel Sanders DATE FEB 2 4 2012