STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Vv. PETITIONER, CASE NO. 2013-06912 RONALD LYNCH, M.D., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, by and through its undersigned counsel, hereby files this Administrative Complaint before the Board of Medicine aga alleges: nst Respondent, Ronald Lynch, M.D., and in support thereof 1. Petitioner is the state department charged with regulating the practice of m 456, Florida S 2. At licensed phys edicine pursuant to Section 20.43, Florida Statutes; Chapter tatutes; and Chapter 458, Florida Statutes. all times material to this Complaint, Respondent was a cian within the state of Florida, having been issued license “number ME 509990. DOH vs. RONALD Lynch, M.D., CASE NO, 2013-06912 1 3. Respondent's address of record is 2500 West Lake Mary Boulevard, Lake Mary, Florida, 32746. 4. — Respondent is board certified in Family Medicine. - 5. The Agency for Health Care Administration (AHCA) is the agency charged with regulating and issuing licenses for participation in the Florida Medicaid program. 6. On or about June 28, 2013, Respondent was issued a Final Order (Order) by AHCA terminating him from the Florida Medicaid program. The Order was based on his conviction of trafficking in oxycodone and morphine. 7. Section 456.072(1)(kk), Florida Statutes (2012), provides that being terminated from the state Medicaid program pursuant to s. 409.913, any other statle Medicaid program, or the federal Medicare program, unless eligibility to participate in the program from which the practitioner was terminated has been restored, constitutes grounds for denial of a license of disciplinary action. . 8. On or about June 28, 2013, Respondent was terminated from the Florida Medicaid program by the Order from AHCA, DOH ys, RONALD LYNCH, M.D., CASE NO. 2013-06912 2 9, Based on the foregoing, Respondent has violated Section 456.072(1)(kk), Florida Statutes (2012), being terminated from the Florida Medicaid program by the June 28, 2013 Order. HEREFORE, the Petitioner respectfully requests that the Board of 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. SIGNED this 6° day of eZ. i , 2014. FILED DEPARTMI sonra CLERKBNG RO DLidend oate:_APR 2 1/2014 JRZ PCP: April 18,)2014 John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health o LE. Assistant General Counsel DOH-Prosecution Services Unit 4052 Bald Cypress Way-Bin C-65 2585 Merchants Row, Suite 105 Express mail Tallahassee, Florida 32399-3265 Florida Bar # 0083617 (850) 245-4444 Ext. 8117 (850) 245-4684 fax Email: Jonathan _Zachem@doh.state.fl.us PCP Members: Dr. Ashkar; Dr. Zachariah; Ms. Di Pietro DOI vs. RONALD LYNCTH, MD. CASE NO. 2013-06912 3 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. DOH vs. RONALD LYNCH, M.D., CASE NO, 2013-06912 4

Docket for Case No: 14-003553PL