STATE OF FLORIDA BOARD OF DENTISTRY DEPARTMENT OF HEALTH, Petitioner, v. CASE NOS.: 2016-18116 2016-18117 ALEXANDRA SANCHEZ-URENA, D.R., D.H., Respondent. ADMINISTRATIVE COMPLAINT Petitioner Department of Health files this Administrative Complaint before the Board of Dentistry against Respondent, Alexandra Sanchez- Urena, D.R., D.H. In support thereof, Petitioner alleges: 1. Petitioner is the state agency charged with regulating the practices of dental radiography and dental hygiene pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida. Statutes; and Chapter 466, Florida Statutes. 2. At all times material to this Complaint, Respondent was a registered dental radiographer and a licensed dental hygienist within the State of Florida, having been issued dental radiographer certificate number DRi0515 on April 16, 1990, and dental hygiene license number DH11724 on October 1, 1996. 3. Respondent's address on record with the Department is 11860 Southwest 103 LN, Miami, Florida 33186. 4. At all times material to this Complaint, Art Dental Services (“ADS”) was a dental practice located at 11373 SW 211 Street, Miami, Florida 33189. 5. Section 466.018, Florida Statutes, mandates that each patient in Florida shall have a dentist of record who shall be identified in the patient’s records. 6. Section 466.024, Florida Statutes, and Rule 64B5-16, Florida Administrative Code, enumerates the tasks that are delegable to dental assistants/radiographers and dental hygienists. 7. At all times material to this Complaint, placing permanent restorations, performing root canals, and extracting teeth were not tasks delegable to dental assistants/radiographers and dental hygienists. FACTS PERTAINING TO PATIENT H.A. 8. Patient H.A. first presented to ADS on or about March 1, 2016. DOH v. Alexandra Sanchez-Urena, D.R., D.H. 2 DOH Case Nos. 2016-18116 and 2016-19117 9. ADS records for Patient H.A. show, in relevant part, that she received one or more fillings and that at least two extractions were planned for. 10. The records do not identify a dentist of record. 11. Respondent placed at least one of Patient H.A/s fillings and extracted at least one of her teeth while she was a Patient at ADS. FACTS PERTAINING TO PATIENT S.S. 12. Patient S.S. first presented to ADS on or about August 10, 2015. 13. ADS records for Patient S.S. show, in relevant part, that she received at least one root canal at the practice. 14. The records do not identify a dentist a of record. 15. A consent form for restorations dated April 22, 2016, contains signatures from Patient S.S. and from a “Dr. Alex”, who is presumably Respondent. 16. Respondent performed a root canal on at least one of Patient S.S.’ teeth while she was a patient at ADS. FACTS PERTAINING TO PATIENT D.B. 17. Patient D.B. first presented to ADS on or about February 3, 2016. DOH v. Alexandra Sanchez-Urena, D.R., D.H. 3 DOH Case Nos. 2016-18116 and 2016-19117 18. ADS records for Patient D.B. show, in relevant part, that he received at least one root canal and at least one filing at the practice. 19. The records do not identify a dentist a of record. 20. Respondent treated at least one of Patient D.B.’s teeth with a root canal and placed at least one of the fillings that he received while a patient at ADS. FACTS PERTAINING TO PATIENT G.D. 21. Patient G.D., who was the minor son of L.D., first presented to ADS on or about April 15, 2016. 22. ADS records for Patient G.D. show, in relevant part, that he received at least one filling and had at least one tooth extracted while a patient at ADS. 23. The records do not identify a dentist a of record. 24. Respondent placed at least one of Patient G.D,s fillings and extracted at least one of his teeth while he was a patient at ADS. COUNT I — PATIENT H.A. 25. Petitioner re-alleges and incorporates paragraphs i through 11 as if set forth fully herein. DOH v. Alexandra Sanchez-Urena, D.R., D.H. 4 DOH Case Nos. 2016-18116 and 2016-19117 26. Section 466.028(1)(y), Florida Statutes (2015-2016), subjects dental radiographers and dental hygienists to discipline for practicing or offering to practice beyond the scope permitted by law or accepting and performing professional responsibilities which the licensee knows or has reason to know that she or he is not competent to perform. 27. Respondent practiced or offered to practice beyond the scope permitted by law or accepted and performed professional responsibilities which Respondent knew or had reason know that she was not competent to perform in one or more of the following manners:, a) Placing one or more fillings in Patient H.A.’s teeth; and/or b) Extracting one or more of Patient H.A.’s teeth. 28. Based on the foregoing, Respondent has violated section 466.028(1)(y). COUNT II — PATIENT S.S. 29. Petitioner re-alleges and incorporates paragraphs 1 through 7 and 12 through 16 as if set forth fully herein. 30. Section 466.028(1)(y) subjects dental radiographers and dental hygienists to discipline for practicing or offering to practice beyond the scope permitted by law or accepting and performing professional responsibilities DOH v. Alexandra Sanchez-Urena, D.R., D.H. 5 DOH Case Nos. 2016-18116 and 2016-19117 which the licensee knows or has reason to know that she or he is not competent to perform. 31. Respondent practiced or offered to practice beyond the scope permitted by law or accepted and performed professional responsibilities which Respondent knew or had reason know that she was not competent to perform by treating one or more of Patient S.S,’ teeth with a root canal. 32. Based on the foregoing, Respondent has violated section 466.028(1)(y). COUNT ft — PATIENT D.B. 33. Petitioner re-alleges and incorporates paragraphs 1 through 7 and 17 through 20 as if set forth fully herein. 34. Section 466.028(1)(y) subjects dental radiographers and dental hygienists to discipline for practicing or offering to practice beyond the scope permitted by law or accepting and performing professional responsibilities which the licensee Knows or has reason to know that she or he is not competent to perform. 35. Respondent practiced or offered to practice beyond the scope permitted by law or accepted and performed professional responsibilities DOH v. Alexandra Sanchez-Urena, D.R., D.H. 6 DOH Case Nos. 2016-18116 and 2016-19117 which Respondent knew or had reason know that she was not competent to perform in one or more of the following manners: a) Placing one or more fillings in Patient D.B.’s teeth; and/or b) Treating one or more of Patient D.B/'s teeth with a root canal. 36. Based on the foregoing, Respondent has violated section 466.028(1)(y). COUNT IV — PATIENT G.D. 37. Petitioner re-alleges and incorporates paragraphs 1 through 7 and 21 through 24 as if set forth fully herein. 38. Section 466.028(1)(y) subjects dental radiographers and dental hygienists to discipline for practicing or offering to practice beyond the scope permitted by law or accepting and performing professional responsibilities which the licensee knows or has reason to know that she or he is not competent to perform. 39. Respondent practiced or offered to practice beyond the scope permitted by law or accepted and performed professional responsibilities which Respondent knew or had reason know that she was not competent to perform in one or more of the following manners: a) Placing one or more fillings in Patient G.D.’s teeth; and/or DOH v. Alexandra Sanchez-Urena, D.R., D.H. 7 DOH Case Nos. 2016-18116 and 2016-19117 b) Extracting one or more of Patient G.D.’s teeth. 40. Based on the foregoing, Respondent has violated section 466.028(1)(y). WHEREFORE, the Petitioner respectfully requests that the Board enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's certificate and 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. [SIGNATURE BLOCK ON NEXT PAGE] DOH v. Alexandra Sanchez-Urena, D.R., D.H. 8 DOH Case Nos, 2016-18116 and 2016-19117 siGnen this_|@ day of —§ M\ arr} 2020. FILED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK — ohngel Bander DATE MAR 1 9 2020 PCP: March 13, 2020 Scott A. Rivkees, MD State Surgeon General Octavio Simoes-Ponce, Esq. Assistant General Counsel Department of Health Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Phone: (850) 558-9902 Fax: (850) 245-4684 Florida Bar # 0096511 Octavio.Simoes-Ponce@fihealth.gov PCP Members: Claudio Miro, D.D.S., Leonard Britten, D.D.S., and Catherine Cabanzon, D.H. DOH v. Alexandra Sanchez-Urena, D.R., D.H. DOH Case Nos. 2016-18116 and 2016-19117 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. Please be advised that mediation under Section 120.573, Florida Statutes, is not available for administrative disputes involving this agency action. 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 v. Alexandra Sanchez-Urena, D.R., D.H. 10 DOH Case Nos, 2016-18116 and 2016-19117

Docket for Case No: 20-004763PL