STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2009-02997 ROBERT RAYMOND REPPY, D.O., RESPONDENT. tee ent ADMINISTRATIVE COMPLAINT COMES NOW Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Osteopathic Medicine against Respondent, Robert Raymond Reppy, D.O., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of osteopathic medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes, and Chapter 459, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed osteopathic physician within the State of Florida, having been issued license number OS 7246. Filed June 18, 2012 3:04 PM Division of Administrative Hearings 3. Respondent's address of record is 2727 W. MLK Jr, Bivd., Suite 760, Tampa, Florida 33607. 4. On or about December 31, 2007, the Board of Osteopathic Medicine filed a Final Order in Department of Health Case Numbers 2005- 50697, 2005-51664, and 2005-51879. 5. The December 31, 2007, Final Order required Respondent to, among other things, complete the “Prescribing Controlled Drugs: Critical Issues and Common Pitfalls of Misprescribing,” course sponsored by the University of South Florida or a Board approved equivalent within one year of the issuance of the Final Order and provide documentation of completion to the Department within one year of the issuance of the Final Order, or on or about December 31, 2008. 6. The December 31, 2007, Final Order required Respondent to, among other things, complete the “Quality Medical Records for Health Care Professionals,” course sponsored by the Florida Medical Association or a Board approved equivalent within one year of the issuance of the Final Order and provide documentation of completion to the Department within one year of the issuance of the Final Order, or on or about December 31, 2008. Page 2 JAPSU\MedicaliTobey\Osteo\ACs\Reppy, R 1009-02997(bb)--violatefinalorder.doc 7, The December 31, 2007, Final Order required Respondent to, among other things, complete the “Florida Laws and Rules Course,” course sponsored by the Florida Osteopathic Medical Association within one year of the issuance of the Final Order and provide documentation of completion to the Department within one year of the issuance of the Final Order, or on or about December 31, 2008. 8. As of June 23, 2009, Respondent has yet to complete and/or provide proof of completion regarding any of the required courses. 9. Section 459.015(1)(bb), Florida Statutes (2008), provides that violating a lawful order of the board or department previously entered in a disciplinary hearing or failing to comply with a lawfully issued subpoena of the board or department constitutes grounds for discipline by the Board of Osteopathic Medicine. 10. Respondent violated the December 31, 2007, Final Order through one or more of the following: a) By failing to complete and/or provide proof of completion regarding the “Prescribing Controlled Drugs: Critical Issues and Common Pitfalls of Misprescribing,” course sponsored by the University of South Florida or a Board approved equivalent on or before December 31, 2008; Page 3 JAPSU\Medical\Tobey\Osteo\ACs\Reppy, R 2009-02997(bb)~-violatefinalorder.doc b) By failing to complete and/or provide proof of completion regarding the “Quality Medical Records for Health Care Professionals,” course sponsored by the Florida Medical Association or a Board approved equivalent on or before December 31, 2008; c) By failing to complete and/or provide proof of completion regarding the “Florida Laws and Rules Course,” course sponsored by the Florida Osteopathic Medical Association on or before December 31, 2008 11. Based on the foregoing, Respondent has violated Section 459.015(1)(bb), Florida Statutes (2008), by violating a lawful order of the Board of Osteopathic Medicine previously entered in a disciplinary hearing. WHEREFORE, Petitioner respectfully requests that the Board of Osteopathic Medicine enter an order imposing one or more of the following penalties: permanent revocation 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. Page 4 JAPSU\Medical\Tobey\Osteo\ACs\Reppy, R 2009-02997(bb)--violatefinalorder.doc SIGNED this_(9* _dayof___ 4... , 2009. ARTMENT OF HEALTH DEP DEPUTY CLERK GLERK: Qing ela MATE __Sltaloa_. Ana M. Viamonte Ros, M.D., M.P.H State Surgeon General To Tobey Shuitz ) Assistant General sel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar No. 0542131 (850) 245-4640, Ext. 8176 (850) 245-4684 Fax PCP: 3 | Blo4q Ardrvley Slows Page 5 JAPSU\Medical\Tobey\Osteo\ACs\Reppy, R 2009-02997(bb)--violatefinalorder.doc 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. Page 6 JAPSU\Medical\Tobey\Osteo\ACs\Reppy, R 2009-02997 (bb)--violatefinalorder.doc

Docket for Case No: 12-002158PL