pz STATE OF FLORIDA ri ED | ALTH CARE ADMINISTRATION AGENCY FOR HE ON yey PM ISI | STATE OF FLORIDA, OIVISIGN OF AGENCY FOR HEALTH CARE Ao INISTRATIVE ADMINISTRATION, . HEARING Petitioner : v. “ GASENO.YD/-CO2F LAKE CITY MEDICAL CENTER, Respondent. ADMINISTRATIVE COMPLAINT Petitioner, STATE OF FLORIDA, AGENCY FOR HEALTH CARE ADMINISTRATION (“Agency”) by and through the undersigned hereby issues this Administrative Complaint against Respondent, LAKE CITY MEDICAL CENTER (“LCMC’), for violation of state hospital licensure law, and imposes administrative fines in the amount of $10,000. As grounds for the imposition of such administrative fines, the Agency states: 1. The Agency has jurisdiction over LCMC and the enforcement of hospital licensure law pursuant to Chapter 395, Florida Statutes, and Rule 59A- 3, Florida Administrative Code. 2. LCMC is a hospital within the meaning of Section 395.002(11), Florida Statutes, and Rule 59A-10.002(2), Florida Administrative Code. 3. The Agency conducted an investigation from 4/5/2000 through 6/23/2000 based on a complaint alleging that LCMC failed to timely notify the Agency of a suspension of privileges of Dr. Ankem Ravindra on March 30, 1998, June 15, 1998, October 16, 1998 and on December 30, 1998 pursuant to Section 395.0193(4), Florida Statutes, and hereby determines that LCMC was in violation of hospital licensure requirements pursuant to Section 395.0193(4), Florida Statutes and is subject to fines, pursuant to Section 395.0193(6), Florida Statutes, as follows: a.) Hospital licensure violations 4. Hospitals are required to report any disciplinary actions taken pursuant to Section 395.0193(3) to the Agency in writing within thirty (30) working days of initial occurrence, and final disciplinary actions taken within ten (10) working days if different from actions reported previously as specified in Section 395.0193(4), Florida Statutes. 5. The Agency finds that the hospital suspended the privileges of Dr. Ankem Ravindra on March 30, 1998 for continued failure to complete patient medical records in a timely manner and did not report this action to the Agency until March 9, 1999. Therefore, LCMC has violated Section 395.0193(4), Florida Statutes. 6. The Agency finds that the hospital suspended the privileges of Dr. Ankem Ravindra on June 15, 1998 for continued failure to complete patient medical records in a timely manner and did not report this action to the Agency until March 9, 1999. Therefore, LCMC has violated Section 395.0193(4), Florida Statutes. 7. The Agency finds that the hospital suspended the privileges of Dr. Ankem Ravindra on October 16, 1998 for continued failure to complete patient 2 medical records in a timely manner and did not report this action to the Agency until March 9, 1999. Therefore, LCMC has violated Section 395.0193(4), Florida Statutes. 8. The Agency finds that the hospital suspended the privileges of Dr. Ankem Ravindra on December 30, 1998 for continued failure to complete patient medical records in a timely manner and did not report this action to the Agency until March 9, 1999. Therefore, LCMC has violated Section 395.0193(4), Florida Statutes. b.) Fines for violation of Hospital licensure law 9. The Agency hereby assesses an administrative fine against LCMC for failure to notify the Agency regarding repeated disciplinary actions suspending the privileges of Dr. Ankem Ravindra occurring on March 30, 1998, June 15, 1998, October 16, 1998 and December 30, 1998 in violation of Section 395.0193(4), Florida Statutes, of $10,000, pursuant to Section 395.0193(6), Florida Statutes. 10. Therefore, the total of administrative fines from the above specified violations of Hospital licensure law assessed against LCMC amounts to $10,000. c.) Rights to A Hearing 11. LCMC has a right to request an administrative hearing pursuant to Section 120.57, Florida Statutes, to be represented by counsel, to take testimony, to call or cross-examine witnesses, and to have argument if a hearing is requested. In order to obtain a formal proceeding under Section 120.57(1), Florida Statutes, LCMC’s request for a formal hearing must set forth with specificity disputed issues of material fact. Failure to so set forth such disputed issues of material fact may be treated by the Agency as an election of an informal proceeding pursuant to Section 120.57(2), Florida Statutes. LCMC has a right to request mediation pursuant to Section 120.573, Florida Statutes. Choosing mediation will not affect LCMC’s right to an administrative hearing. A request for hearing shall. be filed with: Agency for Health Care Administration, 2727 Mahan Drive, Building #3, Tallahassee, Florida 32308-5403, Attention: Sam Powers, Agency Clerk, General Counsel’s Office, with a copy to Anna Polk, Agency for Health Care Administration, 2727 Mahan Drive, Building #1, Tallahassee, Florida 32308-5403. LCMC should include a copy of this administrative complaint with any request for hearing. 12. If LCMC does not contest the matters asserted in this administrative complaint, the amount of the total fine should be remitted by check or money order payable to: Agency for Health Care Administration, 2727 Mahan Drive, Building #1, Tallahassee, Florida 32308-5403, Attention: Anna Polk. 13. Failure to pay the fine or request an informal or formal hearing within twenty one (21) days of receipt of this complaint will result in an admission of the facts alleged herein and an entry of a final order based upon such facts by the Agency. see ISSUED this 7 7 day of November, 2000. AGENCY FOR HEALTH CARE ADMINISTRATION Pete\Buigas _ Depyty Secretary State of Florida Agency for Health Care Administration 2727 Mahan Drive Ft. Knox Executive Center III Tallahassee, Florida 32308-5403 CERTIFICATE OF SERVICE | hereby certify that this Administrative Complaint was sent by U.S. Certified Mail Return Receipt Requested to: Mr. Todd Gallati Administrator Lake City Medical Center 1050 North Commerce Street Lake City, Florida 32055 this RO day of November, 2000. ST Mark S. Thomas, Esquire

Docket for Case No: 01-000029