Oct 3 200? 11:25 Oct 3 2007 11:22 P.05 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, . v. CASE NO. 2004-33945 Kazi Hassan, MD RESPONDENT. EE NISTRATIVE COMPLA Petitioner, Department of Health, by and through undersigned counsel, files this Administrative Complaint before the Board of Medicine against Respondent, Kazi Hassan, MD, 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 66904. 3. Respondent's address of record is 6333 54” avenue N., St. Petersburg, FL 33709. DOH v. Hassan Case No. 2004-33948 J:\PSU\Medical\DPenton\+DHP'sMEDICAL CASES\Hassan, 04-33948\Hassan AC 2.doc wal atl) Oct 3 200? 11:25 Oct 3 2007 11:22 P. O06 4. Onor about July 25, 2001, Patient EM a 72 year old male with the Respondent for treatment of lumbar and cervical degenerative disk ~ disease, Patient EM had been referred to the Respondent for complaints of neck and back pain. 5, On or about July 25, 2001, the Respondent gave Patient EM a cervical epidural steroid injection at the C7-T1 (cervical segment 7 and thoracic segment 1) level of the spine. A cervical epidural steroid injection is used to deliver steroids directly into the epidural space in the spine. The procedure also involves the injection of Xylocaine, a local anesthetic. The C7-T1 level of the spine is where the C-8 nerve root is located, around the neck region. 6. - On or about July 25, 2001, the Respondent conducted the cervical epidural steroid injection after sedating Patient EM with Versed and 50 mg of Diprivan. Patient EM was placed into the sitting position during the cervical epidural steroid injection. 7. Versed (Midazolam) is frequently used, usually in combination with other agents, to sedate patients prior to surgery or other invasive medical procedures. 8. Diprivan (Propofol) is a short-acting general anesthetic agent that can be used for both induction (establishing a depth of anesthesia 2 Oct 3 200? 11:25 Oct 3 2007 11:22 P.O? adequate for surgery) and maintenance of anesthesia as part of a balanced anesthesia technique, for inpatient and outpatient surgery. 9, The use of Diprivan to anesthetize a 72year-old patient in the sitting position is contraindicated, because the drug may cause the patient to lose consciousness, which can lead to significant cardiac blood pressure changes. 10. The Respondent failed to make use of a fluoroscopy (a procedure to view the interior of the human body with a fluoroscope (an. instrument with a fluorescent screen which allows obscure objects to be seen clearer]) with a contrast dye during the cervical epidural steroid injection administered to Patient EM on or about July 25, 2001. 11. In order to place the needle properly into the epidural space, the use of a fluoroscopy with a contrast dye is indicated when a patient undergoes a cervical epidural steroid injection. 12. On or.about July 25, 2001, Patient EM experienced cardiac arrest following the cervical epidural steroid injection, though ultimately successfully resuscitated. 13. Cardiac arrest can occur where Xylocaine is improperly injected into the subarachnoid space or spinal fluid space during a cervical epidural " steroid injection, rather than being injected into the epidural space. Oct 3 2007 11:26 Oct 3 2007 11:23 P. 08 14, Section 458.331(1)(t), Florida Statutes (2001), sets forth grounds for disciplinary action by the Board of Medicine for gross or repeated malpractice or the 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. | 15. Respondent failed 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 in one or both of the following ways: (a) By failing to make use of a fluoroscopy with contrast dye during the cervical epidural steroid injection performed on Patient EM on or about July 21, 2001; (b) By using Diprivan to anesthetize Patient EM in the sitting position during the cervical epidural steroid injection performed on patient EM on or about July 21, 2001. 16. Based on the foregoing, Respondent has violated Section 458.331(1)(t), Florida Statutes (2001), by failing to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably Oct 3 2007 11:26 Oct 3 2007 11:23 P.09 prudent similar physician as being acceptable under similar conditions and circumstances. WHEREFORE, the Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: 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 excluding permanent revocation or suspension of Respondent's license, SIGNED this’ __ day of s/0/4u ary , 2007. Joseph 3. Chiaro, M.D., FAAP Interim Secretary, Department of Health ee, DEPARTM T OF HEALTH Dons H. Penton ; | CLERK A“ y/, y ssistant General Counse DATE as hast - DOH Prosecution Services Unit i, "4052 Baid Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar No.: 0540080 (850) 245-4640 Telephone (850) 245-4683 Facsimile PCP: January 12, 2007 PCP Members: Ashkar, Lage, Beebe Oct 3 2007 11:26 Oct 3 2007 11:23 P.10 Hassan, M.D, 2004-33948 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.

Docket for Case No: 07-004538PL