STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 97-6988 ra wn LISA RENEE CALHOUN, RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner”, and files this Administrative Complaint before the Board of Chiropractic against LISA RENEE CALHOUN, hereinafter referred to as “Respondent”, and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of chiropractic pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter’ 455, Florida Statutes; and Chapter 466, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(f), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed chiropractor in the State of Florida, having been issued license number CH A006508. Respondent’s last known address is 16600 Panama City Beach Parkway, Panama City Beach, Florida 32413. 3. On or about September 19, 22, 26, and 29, 1997, the Respondent advertised free chiropractic services or a special gift in the Panama City News Herald. 4. Section 455.664, Florida Statutes, states that in any advertisement for a free, “discounted fee, or reduced fee service, examination, or treatment by a health care provider licensed under Chapter 460, the following statement shall appear in capital letters clearly distinguishable from the rest of the text: PATIENT AND ANY OTHER PERSON RESPONSIBLE FOR PAYMENT HAS A RIGHT TO REFUSE TO PAY, CANCEL PAYMENT, OR BE REIMBURSED FOR A PAYMENT FOR ANY OTHER SERVICE, EXAMINATION, OR. TREATMENT THAT IS PERFORMED AS A RESULT OF AND WITHIN 72 HOURS OF RESPONDING TO THE ADVERTISEMTN FOR THE FREE, DISCOUNTED FEE, OR REDUCED FEE SERVICE, EXAMINATION, OR TREATMENT. However, the required statement shall not be necessary as an accompaniment to an advertisement of a licensed health care provider defined by this section if the advertisement appears in a classified directory the primary purpose of which is to provide products and services at free, reduced, or discounted prices to consumers and which the statement prominently appears in at least one place. 5. The advertisements placed by the Respondent on or about September 19, 22, 26, and 29, 1997, failed to contain the disclaimer required by Section 455.664, Florida Statutes, and is not subject to any exception. 6. Based on the foregoing, the Respondent’s license to practice dentistry in the State of Florida is subject to discipline pursuant to Section 466.028 (1)(i), Florida Statutes, by violating Section 455.664, Florida Statutes, for failing to perform any statutory or legal obligation placed upon a licensed chiropractic physician. WHEREFORE, Petitioner respectfully requests the Board of Chiropractic 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 this” Z ud day of ae , 1998. Douglas M. Cook, Director BY: Naricy M. Snurkows: Chief Attorney Agency for Health Care Administration FILED COUNSEL FOR PETITIONER: DEPARTMENT OF HEALTH _ vay . CN egory W. Files CLERK Tyga saan Cnn—m Staff Attorney Agency for Health Care DATE a / 26 Administration Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 487-2225 GWFIryj pcp, g O4+ Rer pate: B/AIA%

Docket for Case No: 00-004187PL