eee fi A NN men STATE OF FLORIDA, DEPARTMENT OF HEALTH, BUREAU OF RADIATION CONTROL, Petitioner, vs. CASE NO: 0248488 EDMUNDO L. CAMACHO, 02 -dY 5 (PL Respondent. / ee ADMINISTRATIVE COMPLAINT YOU ARE HEREBY NOTIFIED that twenty-one (21) days from the receipt of this Complaint, Petitioner, State of Florida, Department of Health, Bureau of Radiation Control (hereinafter "Department") intends to impose the following administrative action against the Respondent, Edmundo L. Camacho, (hereinafter "Respondent’) as authorized by section 468.3101, Florida Statute (F.S.): Revoke the Respondent's General Radiographer certificate #15486; deny all future applications for continuing education (CE) course approvals from the Respondent, revoke all the Respondent's existing CE course approvals; and pay an administrative fine in the amount of $125.00. The Respondent's certificate will remain revoked until the Respondent's registration with the American Registry of Radiologic Technologists has been fully reinstated without restriction. As grounds therefore, the Department states the following: 1. The Department has jurisdiction over the Respondent by virtue of the provisions of Chapter 468, Part IV, Florida Statutes (F.S.). 2. On December 17, 1986, the Respondent was initially certified as a General Radiographer by the Department, under certificate #1 5486. A 3. On October 16, 2001, the Respondent's certificate was renewed and bears an expiration date of August 31, 2003. 4. The Respondent is presently certified to perform radiologic technology procedures in the state of Florida. 5. The Respondent is presently an approved provider of CE for radiologic technology in the state of Florida. 6. The American Registry of Radiologic Technologists (ARRT) is the national certification and crecientialing organization for radiologic technologists, recognized by many states, including Florida as establishing state and national eligibility standards, administering examinations, and certifying and registering radiologic technologists who meet specific ethical and professional practice requirements. 7. in October of 1994, the ARRT initially certified and registered the Respondent to perform radiologic technology procedures, under certificate #300283. 8. On August 25, 2001, the ARRT revoked the Respondent's registration to practice radiologic technology. The ARRT revoked the Respondent because the Respondent falsified CE attendance records, created fraudulent CE certificates and provided them to other technologists. 9. On April 4, 2002, the ARRT notified the Respondent that CE credits issued by Respondent would no longer be accepted by the ARRT because the Respondent falsified CE attendance records, created fraudulent CE certificates and provided them to other technologists. 10. On April 29, 2002, the Department received from the ARRT a disciplinary case summary of the complaint against the Respondent including an outline of the allegations, supporting documentation, exhibits and attachments. 41, On August 6, 2002, the Department mailed a certified letter to the Respondent requesting a written narrative of the Respondent's knowledge of this incident and the ARRT registration revocation, and giving the Respondent fourteen (14) days from receipt of letter to respond to the department. 42. On September 5, 2002, the department received a letter from the Respondent denying the Respondent's participation in fraudulent activity as outlined in paragraph "11." 13. In committing the actions described in paragraphs "8," "9" and "10," the Respondent violated the provisions of section 468.3101 (1)(b), F.S., by having a certificate to practice radiologic technology revoked, suspended, or otherwise acted against, including being denied certification by the certification authority of another state, territory, or country. 44. The violations listed in paragraph "13" are grounds for revocation of the Respondent's certificate #15486 to practice radiologic technology pursuant to section 468.3101(2)(b), F.S. 45. The violations listed in paragraph "13" are grounds for revocation of the Respondent as a provider of approved CE for radiologic technologists pursuant to section 468.3101(2)(b), F.8. 16. Incornmitting the actions described in paragraphs "g." "9" and "10," the Respondent violated the provisions of section 468.3101 (1)(f), F-S., by engaging in unprofessional conduct, which includes but is not limited to, any departure from or the failure 3 to conform to, the standards of practice of radiologic technology as established by the Department in which case actual injury need not be established. 17. The vio'ations listed in paragraph "16" are grounds for imposition of an administrative fine of $125.00 payable by the Respondent to the Department pursuant to section 468.3104(2)(3), F.S. 48. The Respondent violated section 468.3101(1)(h), F.S., by not reporting Victor Barrios, Juana M. Carbonell, Gilbert Chavarria, Francisco J. Felix, Eric J. Haubner, Max J. Jardines, Franciso Lopez, Zuhdi Musa, and Philip Santiso to the Department although the Respondent knew these technologists had received fraudulent CE credits and been acted against by the ARRT, and were thus in violation of Chapter 468, Part IV, F.S. and Rule 64E-3. 19. The Respondent violated section 468.3101(1)(e), F.S., and Rule 64E-3.009 (9)(k), F.A.C., by providing written verification (course certificates) of CE activities to the following list of technologists who did not participate in said activities: Victor Barrios, Juana M. Carbonell, Gilbert Chavarria, Francisco J. Felix, Eric J. Haubner, Max J. Jardines, Franciso Lopez, Zuhdi Musa, and Philip Santiso. 20. The violations listed in paragraphs "18" and "49" are grounds for revocation of the Respondent's certificate #15486 to practice radiologic technology pursuant to section 468.3101(2)(b), F.S. 21. The violations listed in paragraphs "8," "9" and "10" are grounds for revocation of the Respondent's status as a provider of continuing education for radiologic technologists pursuant to section 468.3101(2)(b), F.S. - SE 1 a Wherefore, as specified in Chapter 468, Part !V, F.S., the Department respectfully demands that: the Respondent immediately cease and desist from practicing radiologic technology and return to the Depa Respondent's name, the Respond amount of $125.00; the Responde Respondent's registretion with the rtment all General Radiographer certificates bearing the lent pay the administrative fine identified above in the nt's certificate #15486 will remain revoked until the American Registry of Radiologic Technologists has been fully reinstated without restriction; all existing approvals for Respondents CE courses be revoked, and; all future requests for approval of respondent's CE courses denied. Witt. GI ave William A. Passetti, Chief Bureau of Radiation Control ERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been sent by U.S. CERTIFIED MAIL, # 7002 2030 0002 5965 6234, RETURN RECEIPT REQUESTED to Edmundo L. Camacho, 6993 W 25" ct., Hialeah, FL 33016 this 23 day of Woy, 2003. 01-085 AC-UPC rm Is nw apl 41202 5/21/2003 NOTICE OF RIGHTS A party whose substantial interest is affected by this order may petition for an administrative hearing pursuant to sections 120.569 and 120.57, F.S. Such proceedings are governed by Rule 28-106, F.A.C. A petition for administrative hearing must be in writing and must be received by Sam Power the Agency Clerk for the Department, within twenty-one (21) days from the receipt cf this order. The address of the Agency Clerk is 4052 Bald Cypress Way, BIN # A02, Tallahassee, Florida 32399-1703. The Agency Clerk's facsimile number is 850-410-1448. A copy of the petition should also be sent to Attn: William A. Passetti, Bureau of Radiation Control, 4952 Bald Cypress Way, BIN # C21, Tallahassee, FL 32399-1741. Mediation is not available as an alternative remedy. Your failure to submit a petition for hearing within twenty-one (21) days from receipt of this order will constitute a waiver of your right to an administrative hearing, and this order shall become a "final order." Should this order become a final order, a party who is adversely affected by it is entitled to judicial review pursuant to Section 120.68, F.S. Review proceedings are governed by the Florida Rules of Appellate Procedure. Such proceedings may be commenced by filing one copy of a Notice of Appeal with the Agency Clerk of the Department of Health anda second copy, accompanied by the filing fees required by law, with the Court of Appeal in the appropriate District Court. The notice must be filed within thirty (30) days of rendition of the final order.

Docket for Case No: 03-002451PL