voce da sc a a el citi: aise MHA suspension nor STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, ’ Petitioner, vs. CASENO.: 97-15437 LV. AND PULMONARY PRESCRIPTION PROVIDERS, Respondent. / ee ——— ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Pharmacy against IV. AND PULMONARY PRESCRIPTION PROVIDERS, hereinafter referred to as “Respondent,” and alleges: 1 Effective huly 1, 1997, Petitioner is the state agency charged with regulating the practice of pharmacy pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 465, Florida Statutes. 2 P t to the authority of Section 20. 43(3)(, Florida Statutes (Supp. 1996), th ‘Petitioner has contracted with the Agency for Health are A stration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality " Assurance, councils, : ‘or “Boards, “as appropriate, including the issuance of emergency orders of a _. _ Respondent is, and has been at all times material hereto, .a licensed pharmacy in the state of Florida, having ‘been issued license e number PH 0010999. ge ea eerste nega gpemere nent Ba et wy Nd 4. Respondent’s last known address is 3129 West Hallandale Boulevard, Suite 106, Pembroke Park, Florida 33009. 5. ‘On or about April 30, 1997, Respondent dispensed prescription medication to © 6. On or about April 30, 1997, Respondent delivered patient medications to a third 7. Respondent failed to offer adequate patient counseling at the time of delivery. 8. Based on the foregoing, Respondent's license to practice as a pharmacy in the . ‘State of Florida is subject to discipline pursuant to Section 465.023(1)(c), Florida Statutes, in violation of Rule 64B16-27.820, Florida Administrative Code, which states that upon receipt of a new or refill prescription, the pharmacist shall ensure that a verbal and printed offer to counsel is nade to the patient ¢ or the patient s agent. | WHEREFORE, Petitioner respecflly requests the Board of Pharmacy enter an Order - imposing one or more of the following penalties: revocation or suspension of the Respondent's license, restriction of the Respondent's practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board . deems ‘appropriate. ___ SIGNED nig Dacllay of OSS nr , 1998. Douglas M. Cook Director FILED DEPARTMENT OF HEALTH _ DEPUTY CLERK — By: Nancy RK hall, } Wousah Chief Attorney DATE__jI- 13 ~9k On Behalf of the Agency for ; Health Care Administration W COUNSEL FOR AGENCY: Carolyn Taylor 7 Senior Attorney Florida Bar Number 0127884 Agency for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9644 CT/kmg PCP: Marina Garcia Wood Juan Mora, R.PH. DOM: September 15, 1998 Case No. 97-15437

Docket for Case No: 00-000684