STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, V. DOH Case No. 2018-24001 SHEETAL KANAR KUMAR, M.D., Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, the Department of Health (the Department), hereby files this Administrative Complaint before the Board of Medicine (the Board) against Respondent, Sheetal Kanar Kumar, M.D. (Respondent), and in support thereof alleges: 1. | The Department is the state agency charged with regulating the practice of medicine in Florida pursuant to section 20.43, Florida Statutes, and chapters 456 and 458, Florida Statutes. 2. At all times material hereto, Respondent was a licensed physician in Florida, having been issued license number ME 78776. 3. At all times material hereto, the Department’s address of record for Respondent was 1000 S.E. Federal Highway, Stuart, Florida 34994. 4. Onor about January 17, 2019, Respondent was charged, in the United States District Court for the Southern District of Florida, in case number 2:18-cr-14063-KAM, with twenty-nine (29) counts of health care fraud, in violation of title 18, United States Code, sections 1347 and 2. The Superseding Indictment provided in relevant part: Beginning in or around January 2014, until on or about July 19, 2017, in Martin County, in the Southern District of Florida, and elsewhere, the defendant, SHEETAL KANAR KUMAR, in connection with the delivery and payment for health care benefits, items, and services, did knowingly and willfully execute, and attempt to execute, a scheme and artifice to defraud health care benefit programs affecting commerce ..., that is Medicare, Medicaid, Blue Cross Blue Shield, Humana, Aetna, Inc., Cigna, and United Health Care Services, Inc., and to obtain, by means of materially false and _ fraudulent pretenses, representations, and promises, money and property owned by, and under the custody and control of said health care benefit programs, in that the defendant submitted and caused the submission of false and fraudulent claims seeking money for specific health care benefits, items, and services that were not provided as billed. 5. On or about February 15, 2019, Respondent was convicted or found guilty of twenty-three (23) counts of health care fraud, in violation of title 18, United States Code, sections 1347 and 2. DOH v. Sheetal Kanar Kumar, M.D., DOH Case Number 2018-24001 Administrative Complaint Page 2 of 6 COUNTTI 6. The Department re-alleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 7. Section 456.072(1)(c), Florida Statutes (2018), subjects a licensee to discipline in part for being convicted or found guilty of, regardless of adjudication, a crime in any jurisdiction which relates to the practice of, or the ability to practice, a licensee's profession. 8. On or about February 15, 2019, Respondent was convicted or found guilty of crimes in federal district court which relate to the practice of, or the ability to practice, her profession. 9. Based on the foregoing, Respondent violated section 456.072(1)(c), Florida Statutes (2018). COUNT II 10. The Department re-alleges and incorporates paragraphs one (1) through five (5) as if fully set forth herein. 11. Section 456.072(1)(Il), Florida Statutes (2018), subjects a licensee to discipline in part for being convicted of any misdemeanor or felony, regardless of adjudication, a crime in any jurisdiction which relates to health care fraud. DOH v. Sheetal Kanar Kumar, M.D., DOH Case Number 2018-24001 Administrative Complaint Page 3 of 6 12. On or about February 15, 2019, Respondent was convicted of misdemeanors or felonies in federal district court which relate to health care fraud. 13. Based on the foregoing, Respondent violated section 456.072(1)(Il), Florida Statutes (2018). WHEREFORE, the Department respectfully requests the Board 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 coilected, remedial education, and/or any other relief the Board deems appropriate. [This space intentionally left blank.] DOH v. Sheetal Kanar Kumar, M.D., DOH Case Number 2018-24001 Administrative Complaint Page 4 of 6 SIGNED this twenty-third day of April, 2019. Geoffrey M. Christian Geoffrey M. Christian, Esq. F | L E D Assistant General Counsel Florida Bar No. 0010325 DEPARTMENT OFAN Department of Health . rosecution Services Uni CLERK: Morus 4052 Bald Cypress Way, Bin C-65 pate:___APR 2.3 2019 Tallahassee, Florida 32399-3265 Telephone (850) 245-4661 Facsimile (850) 245-4684 E-mail Geoffrey.Christian@flhealth.gov Attorney for Petitioner PCP Date: April 23, 2019 PCP Members: M. Avila, M.D.; J. Orr, Jr., M.D. DOH v. Sheetal Kanar Kumar, M.D,, DOH Case Number 2018-24001 Administrative Complaint Page 5 of 6 DOH V. SHEETAL KANAR KUMAR, M.D. DOH CASE NUMBER 2018-24001 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 twenty-one (21) days from the day Respondent received this Administrative Complaint, pursuant to rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within twenty-one (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 this 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 the Department 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 Respondent in addition to any other discipline imposed. DOH v. Sheetal Kanar Kumar, M.D., DOH Case Number 2018-24001 Administrative Complaint Page 6 of 6

Docket for Case No: 19-004262PL