Jan 19 200° 9:34 JAN-19-2087 @9!31 FL DEPT OF HEALTH B58 499 1855 oP STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv: CASE NO, 2005-03020 JEROME W, CRAFT, M.D. RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against Respondent, Jerome W. Craft, M.D., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 458, Florida Statutes, 2. At all times material to this Complaint, Respondent was a licensed | physician within the state of Florida, having been issued license number ME 10445. 3. Respondent's address of record is 8983 Okeechobee Boulevard, Suite 201, West Palm Beach, Florida 33411, 4. Respondent is board certified in plastic surgery. 5. On or about January 11, 2005, Patient G.B., a sixty-four (64) year old female presented to Respondent for a consultation, 6. Patient G.B. informed Respondent that she had cancer on her nose and feared losing her nose. Le] A O02 20 AYN Jan 19 200° 9:34 JAN-19-2087 Of a1 FL DEPT OF HEALTH 856 488 1855 P.@S 7. Respondent did not order a diagnostic biopsy of Patient G.B’s nose lesions. 8. Patient G.B.’s medical records indicate that Respondent discussed various forms of treatment of Patient G.B,’s nose lesion including (a) electrocautery, (b) freezing therapy, (c) surgical excision with pathology clearance that all cancer hes been excised, (d) excisional treatment program, (e) x-ray radiation, (f) laser treatment program, (g) chemotherapy, (h) biological or immunotherapy, and (i) and alternative medical treatment with an topical agent referred to as “Black Salve.” 9. “Black Salve” is a corrosive topical agent which burns the skin ‘and produces a thick, dry scab called an "eschar" on the skin after application. 10, Patient G.B’s medical records for January 11, 2004, indicate that Respondent described his successful use of “Black Salve” on his own nose to her. 11. = Patient G.B. chose the “Black Salve” treatment for her nose lesions. 12, Onor about January 19, 2005, Patient G.B. returned to Respondent for a second consultation. 13. Respondent = conducted | a dermatoscope (hand-held lighted magnifier/microscope) examination of her skin. 14. Patient G.B's medical records reveal indicate that based on the dermatoscope examination Respondent diagnosed upper level skin cancer in the dorsal and left skin of her upper nose, invading cancers in the full length of the end of the nose, and possible other small skin cancers that he was unable to see with the dermatoscope. Jan 19 2007 9:35 JAN-19-2087 Of a1 FL DEPT OF HEALTH 856 488 1855 P.@6 15. Patient G.B.s medical records indicate that she informed Respondent she did not want a biopsy because it would leave scars and deformities on her nose. 16. On or about January 21, 2005, Patient G.B. returned to Respondent for a bilateral blepharoplasty (eyelid surgery), removal of a benign skin tumor on her right forearm, and application of the “Black Salve.” 17. On or about January 23, 2005, Respondent visited Patient G.B. at home to evaluate the results of the application of “Black Salve” to Patient G.B.’s nose. 18. On or about January 25, 2005, Patient G.B. presented to Respondent complaining of pain in the area where the Black Salve was applied. 19. Respondent assured Patient G.B. that the salve was working as expected. 20. On or about January 29, 2005, Patient G.B. presented to Respondent with full thickness eschar on her nose. 21. Patient G.B.'s medical records indicate that Respondent prescribed Cipro, an antibiotic, and informed her he would remove the eschar on her nose or about February 4, 2005. 22, On or about January 31, 2005, Patient G.B. presented to Good Samaritan Medical Center in West Palm Beach, Florida, with full thickness necrosis (skin foss) on her nose and was admitted to the hospital. 23. On or about February 2, 2005, Patient G.B, underwent debridement of the nose skin, subcutaneous tissue and cartilage. 24. The operative report indicates that Patient G.B. suffered complete skin loss over the lower lateral cartilage domes and the anterior half of the columella (the fleshy section of the nase which separates the nostrils). Jan 19 2007 9:35 JAN-19-2087 9:32 FL DEPT OF HEALTH 856 488 1855 Pa? 25. On or about February 4, 2005, Patient G.B was discharged from Good Samaritan Medical Center. 26. Section 458.331(1)(t), Florida Statutes (2004) provides that failure to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances is grounds for disciplinary action by the Board of Medicine. 27, Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized as acceptable and appropriate by reasonably prudent similar health cate providers in Respondent's treatment of Patient G.B. in one or more of the following ways: (a) By administering “Black Salve” to Patient G.B.; and/or (b) By treating Patient G.B/’s skin cancer without knowing the exact nature and extent of the cancer; and/or {c) By failing to perform a biopsy of Patient G.B/s nose lesion(s) to determine the exact nature and extent of the skin cancer; and/or (d) By failing to refer Patient! GB. for additional treatment or consultation after she developed full thickness eschar on her nose. 7 28. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes (2004), by failing to practice medicine with that level of care, skill, and treatment which js recognized as acceptable and appropriate by reasonably prudent similar health care providers. WHEREFORE, the Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: permanent revocation Jan 19 2007 9:35 JAN-19-2087 9:32 FL DEPT OF HEALTH 856 488 1855 P.@8 or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. SIGNED this__' __ day of __ Moy , 2006. M. Rony Francois, M.D., M.S.PH., Ph.D. Secretary, Department of Health CEPARTMENT OF HEALTH Konsrs Re lever DEPUTY CLERK Maura M. Bolivar CLERK ONerne a Mekoun Assistant General Counsel DATE G-d-ob Department of Health Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar No. 0295840 (850) 245-4640 (telephone) (850) 245-4681 (facsimile) PCP: April 28, 2006 PCP Members: &/-Bahri, Cote, & Dyches Jan 19 2007 9:35 JAN-19-2087 9:32 FL DEPT OF HEALTH 856 488 1855 P.@9 Jerome Craft, M.D, DOH Case No. 2005-03020 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456,072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. TOTAL P.&9

Docket for Case No: 07-000408PL