STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2017-01505 RAGON A. FROST, P.M.D., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner Department of Health (Department) files this Administrative Complaint before the Bureau of Emergency Medical Services (Bureau) against Respondent Ragon A. Frost, P.M.D., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of emergency medical services pursuant to Section 20.43, Florida Statutes and Chapters 401 and 456, Florida Statutes (2016). 2. Atall times material to this Complaint, Respondent was certified to practice as a paramedic within the State of Florida, having been issued certificate number PMD 19796, 3. Respondent’s dddress of record is confidential pursuant to Section 119.071(4)(d)2.b., Florida Statutes (2016). 4, At all times material to this Complaint, Respondent was employed at Hillsborough County Fire Rescue (HCFR) located in Tampa, Florida, 5. On October 29, 2016, HCFR staff required Respondent undergo a for-cause drug screen, which a Medical Review Officer confirmed was positive for amphetamine! and methamphetamine’. 6. Respondent did not have a lawful prescription and legitimate medical reason for using amphetamine and/or methamphetamine. 7. Dr, Debra M. Barnett, M.D., a physician specializing in Addiction Medicine, evaluated Respondent on April 25, 2017. 8. Dr, Barnett diagnosed Respondent with Amphetamine-Related Disorder not otherwise specified, Cannabis-Related Disorder not otherwise specified, Opioid Intoxication for October 27, 2016, Anxiety Disorder not otherwise specified, and Circadian Rhythm Sleep Disorder. 9, Dr. Barnett opined that Respondent is not able to practice as a ' According to Section 893.03(2), Florida Statutes (2016), amphetamine Is.a Schedule II controlled substance that has a high potential for abuse and has a currently accepted but severely restricted medical use in treatment in the United States. Abuse of amphetamine may lead to severe psychological or physical dependence. ? According to Section 893.03(2), Florida Statutes (2016), methamphetamine is a Schedule II controlled substance that has a high potential for abuse and has a currently accepted but severely restricted medical use in treatment in the United States. Abuse of methamphetamine may lead to severe psychological or physical dependence. 2 Administrative Complaint DOH v, Ragon A. Frost, P.M.D. DOH Case No,: 2017-01505 paramedic with reasonable skill and safety to patients. | COUNT I 10. Petitioner realleges and incorporates paragraphs one through nine as if fully set forth herein, 11. Section 456.072(1)(z), Florida Statutes (2016), authorizes discipline against a paramedic for being unable to practice with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, chemicals, or any other type of material or as a result of any mental or physical condition. 12. Respondent is unable to practice as a paramedic with reasonable skill and safety to patients by reason of one or more of the following: a. Amphetamine-Related Disorder not otherwise specified, and/or b. Cannabis-Related Disorder not otherwise specified, and/or - c, Opioid Intoxication, and/or d. Anxiety Disorder not otherwise specified, and/or e. Circadian Rhythm Sleep Disorder. 13. Based on the foregoing, Respondent violated Section 456.072(1)(z), Florida Statutes (2016). Administrative Complaint ; DOH v. Ragon A. Frost, P.M.D. DOH Case No.: 2017-01505 COUNT IT 14, Petitioner realleges and incorporates paragraphs one through nine as if fully set forth herein, 15, Section 456.072(1)(aa), Florida Statutes (2016), provides that testing positive for any drug, as defined in Section 112.0455, Florida Statutes, on any confirmed pre-employment or employer-ordered drug screening when the practitioner does not have a lawful prescription arid legitimate medical reason for using the drug constitutes grounds for disciplinary action. 16. On or about October 29, 2016, Respondent tested positive for amphetamine and methamphetamine on a confirmed employer-ordered drug screening when Respondent did not have a lawful prescription and legitimate medical reason for using amphetamine and/or methamphetamine. 17, Based on the foregoing, Respondent has violated Section 456.072(1)(aa), Florida Statutes (2016). (remainder of page intentionally blank) Administrative Complaint DOH v. Ragon A. Frost, P.M.D. BOH Case No.: 2017-01505 WHEREFORE, Petitioner respectfully requests that the Bureau 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 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 !4_ day of waa , 2017. Celeste Philip, M.D., M.P.H. Surgeon General and Secretary C Amy ab horn Assistant General Counsel FL DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar Number 92097 (P) (850) 245-4444 ext. 8154 (F) (850) 245-4662 (E) Amy. Thorn@flhealth.gov FILED “MENT OF HEALTH DEPAREPUTY GLERK CLERK Amber Ox DATE yn 1.9 2017 PCP; June 19, 2017 PCP Members: Steve McCoy Administrative Complaint DOH v. Ragon A, Frost, P.M.D. DOH Case No.: 2017-01505 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120,573, Florida Statutes, is not available to resolve this Administrative Complaint. 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 any other discipline imposed. Administrative Complaint DOH v. Ragon A. Frost, P.M.D. DOH Case No,: 2017-01505

Docket for Case No: 19-001121PL