STATE OF FLORIDA DEPARTMENT OF HEALTH BUREAU OF EMERGENCY MEDICAL OVERSIGHT DEPARTMENT OF HEALTH, mi a — om Petitioner, S = >a © cant vs. CASE NO.: 2012-08828 aA = om NORTH FLORIDA m COMMUNITY COLLEGE, =O Respondent. / ADMINISTRATIVE COMPLAINT The Department of Health, Bureau of Emergency Medical Oversight (Petitioner), by and through the undersigned attorney, files an Administrative Complaint against North Florida Community College (Respondent) and states: NATURE OF ACTION 1. Pursuant to § 401.411, Fla. Stat. (2012), this is an action to reprimand Respondent’s EMT and Paramedic Training Program license and impose administrative fines up to $1,000 per day as provided by law. JURISDICTION AND VENUE 2. The Petitioner has jurisdiction pursuant to Chapters 120 and 401, Fla. Stat. (2012) and Fla. Admin. Code R. 28-106. 3. Venue lies pursuant to Fla. Admin. Code R. 28-106.207. PARTIES 4. Petitioner is a state agency established in § 20.43, Fla. Stat. (2012), and is charged with regulating emergency medical services pursuant to Chapter 401, Fla. Stat. 5. At all times material hereto, Respondent has been licensed as an EMT and Paramedic Training Program, school code 64. 6. Respondent’s address of record and mailing address is 325 NW Tumer Davis Drive, Madison, Florida 32340. COUNT I RESPONDENT VIOLATED SECTION 401.411(1)(a), FLORIDA STATUTES, BY FAILING TO TIMELY RENEW EMERGENCY MEDICAL TECHNICIAN AND PARAMEDIC TRAINING PROGRAM LICENSE AS REQUIRED BY SECTION 401.2701(1)(a), FLORIDA STATUTES AND FLORIDA ADMININSTRATIVE CODE RULE 64J-1.020(5) 7. Petitioner re-alleges and incorporates paragraph 1 through 6 as if fully set forth herein. 8. Pursuant to § 401.2701(1)(a), Fla. Stat. (2012) and Fla. Admin. Code R. 64J-1 .020(5), in order to renew an EMT and Paramedic Training Program license, the licensee must submit an application for training program renewal not more than 180 days or less than 90 days prior to the expiration of the training program license. 9. Respondents training program license was due to expire on September 7, 2012, and its application for renewal was due no later than June 7, 2012. 10. Respondent’s submitted application for renewal was received by the Petitioner on or about June 13, 2012, six (6) days after the application for renewal was due. 11. Pursuant to § 401.411(7), Fla. Stat. (2012), the Petitioner may impose an administrative fine, not to exceed $1,000 per violation and each day constitutes a separate violation and is subject to a separate fine. 12. Based on the following, Petitioner may impose fines up to $6,000 for violating § 401.2701(1)(a), Fla. Stat. (2012), and Fla. Admin. Code R. 64J-1 .020(5). CONCLUSIONS OF LAW 13. Respondent violated § 401.2701(1)(a), Fla. Stat. (2012), and Fla. Admin. Code R. 64J- 1.020(5), by failing to timely submit an EMT and Paramedic Training Program application for renewal. 14. Pursuant to § 401.411(1)(a), Fla. Stat. (20 12), a licensee may be disciplined for violation of § 401.2701(1)(a), Fla. Stat. (2012), and Fla. Admin. Code R. 64J-1.020(5). 15. All classifications of EMS licensure held by Respondent are subject to any final order which issues in this case, as provided by § 401.411(2), Fla. Stat. (2012). CLAIM FOR RELIEF WHEREFORE, Petitioner respectfully requests that the following sanctions be imposed against Respondent: a. Make factual and legal findings in favor of Petitioner on Count L b. Pursuant to § 401.411(1), Fla. Stat. (2012), reprimand Respondent’s EMT and Paramedic Training Program license. ce. Pursuant to § 401.411(7), Fla. Stat. (2012), administratively fine Respondent $6,000 ($1,000 each day) for violating § 401.2701(1)(a), Fla. Stat. (2013), and Fla. Admin. Code R. 64J-1.020(5). d. Provide such other relief as may be proper. Dated this 11th day of September 2013. Respectfully submitted, 3 Chief Hégal Counsel Fla. Bar No. 0480649 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin #A02 Tallahassee, FL 32399-1703 Telephone: (850) 245-4005 Facsimile: (850) 413-8743 Email: caryl_kilinski@doh.state.fl.us CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by USS. certified mail to North Florida Community College, c/o Mack Leggett, Program Director, 325 NW Tumer Davis Drive, Madison, Florida 32340 on this / Me day of September, ( 2013. C ifski NOTICE O GHTS Respondent has the right to request or petition for an administrative hearing to be conducted in accordance with §§ 120.569 and 120.57, Fla. Stat. (2012). Respondent has the right to be represented by counsel or other qualified representative. Administrative hearings are governed by Fla. Admin. Code R. 28-106. A request or petition for an administrative hearing must be in writing and must be received by the agency clerk within twenty-one (21) days from the day you received this Administrative Complaint. A request or petition for a hearing must be in conformance with Fla. Admin. Code Chapter 28-106.2015(5) and must be sent to the Agency Clerk at the following address: Agency Clerk Department of Health 4052 Bald Cypress Way, Bin #A-02 Tallahassee FL 32399-1703. Mediation is not available as an alternative remedy. 4 Your failure to submit a petition for hearing within 21 days from receipt of this Administrative Complaint will constitute a waiver of your right to a hearing, and this complaint will thereby become a final order of the department.

Docket for Case No: 13-004126