" STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, vs.” , Case No. 1999-51218 , JANET T. GOLDSTEIN, Us 4 3005? L Respondent. / ADMINISTRATIVE COMPLAINT Department of Health, hereinafter referred to as “Petitioner”, files this Administrative Complaint before the Board of Chiropractic Medicine against JANET GOLDSTEIN, hereinafter referred to as “Respondent”, and alleges: . 1. Petitioner is the state agency charged with regulating the practice of chiropractic medicine pursuant to Section 20.43, Chapter 455, and Chapter 460, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, 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. 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 0005446. Respondent’s last known address is 9892 Robin Nest Road, Boca Raton, Florida 33496- 2143. 3. On or about September 2, ‘1997, patient/complainant MS presented to Respondent for the care and treatment of lo w back discomfort. oe meer ener tiie Sn ke Be 4. Respondent did not obtain adequate patient history for the patient. Specifically, the Respondent did not obtain adequate history regarding the patient’s cervical spine. In order for the cervical spine to be treated, the following exams and/or tests of the cervical spine must occur: sensory testing, reflex test, and provocation . maneuver. None of these tests were taken. 5. On or about September 8, 1997, patient MS presented to Respondent’s partner for treatment. 6. The medical records for this patient do not clearly identify by signature, initials, or printed name on record, the name of the treating physician for each appointment. 7. Medical records for this patient do not legibly document the course and results of treatment. There are no examination results and no test results. 8. . Based on the foregoing, Respondent’s license to practice chiropractic medicine in the State of Florida is subject to discipline pursuant to Section 460.413(1)(m), Florida Statutes, by failing to keep legibly written chiropractic medical records that identify clearly by name and credential the licensed chiropractic physician rendering, ordering, supervising, or billing for each examination or treatment procedure medical record shall be legibly maintained and shall contain sufficient information to identify the patient, support the diagnosis, justify the treatment and document the course and results of treatment accurately... hat justify the course eof treatment at of the patient, including, but not limited to, patient AAR te ey WHEREFORE, Petitioner respectfully requests the Board of Chiropractic Medicine to 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 and costs, issuance of a reprimand, placement of the - Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED thick Hey of —f Lae , 2000. Robert G. Brooks, M.D Secretary, Department of Heath ori LED oo CLERK ‘i BY: ancy M. Snurkowski, Chief Attorney Agency for Health Care Administration ' DATE Czas 50 General Counsel - MQA , eee Practitioner Regulation — Legal COUNSEL FOR PETITONER: : Wings S. Benton, Senior Attorney by mEk i Fla. Bar. No. 149206 . Agency for Health Care Administration General Counsel - MQA Practitioner Regulation — Legal P.O. Box 14229 Tallahassee, Florida 32317-4229 Telephone (850) 487-9633 WSB/tu . oo Bae pean PCP: Perman and Glisson . ee DATE: 1/13/2000 - - Goldstein 99-51218CH

Docket for Case No: 01-003065PL