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FLORIDA SOCIETY OF OPHTHALMOLOGY, INC.; EMANUEL NEWMARK, M.D.; AND WAITE S. KIRKCONNELL, M.D. vs DEPARTMENT OF PROFESSIONAL REGULATION, 90-003285RP (1990)

Court: Division of Administrative Hearings, Florida Number: 90-003285RP Visitors: 28
Petitioner: FLORIDA SOCIETY OF OPHTHALMOLOGY, INC.; EMANUEL NEWMARK, M.D.; AND WAITE S. KIRKCONNELL, M.D.
Respondent: DEPARTMENT OF PROFESSIONAL REGULATION
Judges: LARRY J. SARTIN
Agency: Department of Health
Locations: Tallahassee, Florida
Filed: May 29, 1990
Status: Closed
DOAH Final Order on Thursday, August 9, 1990.

Latest Update: Aug. 09, 1990
Summary: Whether the Petitioners have alleged facts sufficient to prove their standing to challenge the Respondent's proposed amendment to Rule 21-18.002, Florida Administrative Code?Ophthalmology Association and practitioners not have standing to challenge amend- ment of drug formulary for optometrists.
90-3285.PDF

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS


FLORIDA SOCIETY OF OPHTHALMOLOGY ) INC., EMANUEL NEWMARK, M.D., ) and WAITE S. KIRKCONNELL, M.D., )

)

Petitioner, )

)

vs. ) CASE NO. 90-3285RP

) STATE OF FLORIDA, DEPARTMENT OF ) PROFESSIONAL REGULATION, )

)

Respondent. )

and )

) FLORIDA OPTOMETRIC ASSOCIATION ) and STEVEN A. MARKOW, O.D., )

)

Intervenors. )

)


FINAL ORDER


Pursuant to written notice a motion hearing was held in this case before Larry J. Sartin, a duly designated Hearing Officer of the Division of Administrative hearings, on July 3, 1990, in Tallahassee, Florida.


APPEARANCES


For Petitioners: Karen L. Goldsmith, Esquire

Dempsey & Goldsmith, P.A. Post Office Box 1986 Orlando, Florida 32802-1980

and

John Miller, Esquire Dempsey & Goldsmith, P.A. Post Office Box 10651 Tallahassee, Florida 32302


For Respondent: Charles Tunnicliff, Esquire

Department of Professional Regulation 1940 North Monroe Street, Suite 60

Tallahassee, Florida 32399-0792


For Intervenors: James C. Adkins, Esquire

Leonard A. Carson, Esquire John D.C. Newton II, Esquire Lucille D. Turner, Esquire Carson & Linn, P.A.

Mahan Station

1711-D Mahan Drive Tallahassee, Florida 32308

STATEMENT OF THE ISSUES


Whether the Petitioners have alleged facts sufficient to prove their standing to challenge the Respondent's proposed amendment to Rule 21-18.002, Florida Administrative Code?


PRELIMINARY STATEMENT


On May 29, 1990, the Petitioners the Florida Society of Ophthalmology, Inc., Emanuel Newmark, M.D., and Waite S. Kirkconnell, M.D., filed a Petition to Determine the Invalidity of a Rule. The Petition was assigned to the undersigned. The formal hearing of the case was scheduled for June 28, 1990, by Amended Notice of Hearing entered June 1, 1990. A Motion for Continuance filed by the Petitioner was granted.


On June 8, 1990, a Petition to Intervene of Florida Optometric Association and Steven A. Markow, O.D., was filed. An Order Granting Petition to Intervene was entered on June 21, 1990.


A number of motions, including Intervenors' Motion to Dismiss, were filed between the date the Petition was filed and July 3, 1990. The Intervenors requested oral argument on one of the motions and, pursuant to written notice, a motion hearing was held on July 3, 1990. After hearing argument of the parties, the undersigned indicated that a Final Order would be issued granting the Intervenors' Motion to Dismiss. The other motions, therefore, were moot.


The Petitioners and the Intervenors have filed proposed orders. To the extent that they have proposed findings of fact in their proposed orders, those findings of fact have been or are hereby accepted in this Final Order. The Respondent did not file a proposed order.


FINDINGS OF FACT


  1. The Florida Society of Opthalmology, Inc., Emanuel Newmark, M.D. and Waite S. Kirkconnell, M.D)., filed a Petition to Determine The Invalidity of a Rule (hereinaffter referred to as the "Petition"), with the Division of Administrative Hearing on May 29, 1990.


  2. In the Petition the Petitioners challenged the validity of a proposed amendment to Rule 21-18.002, Florida Administrative Code (hereinafter referred to as the "Rule Amendment").


  3. The Rule Amendment was filed with the Secretary of State on March 3, 1990, with the Rule Amendment to take effect on May 7, 1990. The Rule Amendment allows licensed, certified optometrists to administer and prescribe certain Steroids and certain Steroid/Sulfonamide combinations.


  4. It is alleged in the Petition that the Petitioner, Florida Society of Ophthalmology, Inc. (hereinafter referred to as "FSO"), is:


    a Florida not-for-profit incorporated association of ophthalmologists, who are allopathic and osteopathic physicians, specializing in the medical diagnosis of eye diseases, anomalies and disorders, and treatment with medication, surgery,

    and corrective lenses and prisms. FSO acts and is organized to further the education, professional, and economic interests of Florida ophthalmologists, improve quality of health care administered to the public, and to educate the public to its needs for adequate health care. FSO routinely represents and serves its members through public relations activities, interactions with governmental agencies, and participation in administrative

    proceedings, legislative affairs and litigation.


    Pages 1 and 2 of the Petition.


  5. The following allegations concerning Dr. Newmark and Dr. Kirkconnell are included in the Petition:


    That Petitioner, DR. NEWMARK, is a physician licensed by the State of Florida pursuant to chapter 458, Florida Statutes. DR. NEWMARK maintains an office for the practice of medicine in Atlantis, Florida. Petitioner, DR KIRKCONNELL, is a physician licensed by the State of Florida pursuant to chapter 458, Florida Statutes. DR. KIRKCONNELL maintains an office for the practice of medicine in Tampa, Florida. Both physicians specialize in the field of ophthalmic medicine or ophthalmology.

    Many of these Petitioners' patients also visit optometrists for some of their vision care needs.

    3. That Petitioners DR. NEWMARK and DR. KIRKCONNELL file this Petition on behalf of themselves and all other persons similarly situated; i.e., licensed Florida physicians practicing ophthalmic medicine in the State of Florida. These Petitioners also file this Petition on behalf of their patients, who are consumers of eye care

    and vision care services in the State of Florida.


    Page 2 of the Petition.


  6. The Petition contains two Counts challenging the Rule Amendment. In support of the Petitioners' standing, the following allegations are contained in Count I:


    1. That the Rule Amendment purports

      to authorize the practice of medicine by persons who are not licensed to practice medicine by chapters 458 and 459, Florida Statutes, thereby adversely

      affecting Petitioners' property right to practice medicine.

    2. That Petitioners are concerned with protection of the public by ensuring that persons engaged in the various health care professions are qualified to do so, and Petitioners believe that the Rule Amendment with illegally authorize certified optometrists to adversely affect the public health through utilization of drugs which they are not qualified to prescribe, administer or monitor.


      Page 5 of the Petition.


  7. In Count II of the Petition, allegations almost identical to paragraph

    17 of the Petition are made.


  8. On June 13, 1990, the Intervenors filed Intervenors' Motion to Dismiss. On June 27, 1990, the Petitioners filed Petitioners' Response to Respondent's [sic] Motion to Dismiss. On June 28, 1990, the Petitioners filed Amendment to Petitioners' Response to Respondents' [sic] Motion to Dismiss correcting the title of the Motion and correction of a citation to a court decision contained in the Motion.


  9. In the Petitioners' Response to Respondent's [sic] Motion to Dismiss the Petitioners state the following:


    1. The pleadings allege adequate facts in the following paragraphs from the petition:

      1. ".... improve quality of health care administered to the public, and to educate the public to its needs for adequate health care . . .

      2. .... Many of Petitioners' patients also visit optometrists for some of

        their vision care needs ....

      3. .... These Petitioners also file this Petition on behalf of their patients, who are consumers of eye care and vision care services in the State of Florida.


    The Petitioners also quoted paragraphs 17 and 26 of their Petition.


  10. Pursuant to written notice a motion hearing was held on July 3, 1990, to consider the Intervenors' Motion to Dismiss and other motions previously filed by the parties.


  11. Following oral argument of the parties, the parties were informed that the Intervenors' Motion to Dismiss would be granted.

  12. The FSO and the individual ophthalmologists in Board of Optometry v. Society of Ophthalmology, 538 So. 2d 878 (Fla. 1st DCA 1989), cert. denied, 545 So. 2d 1367 included the following allegations of fact concerning their standing in their Petition in that case:


    1. Petitioner FSO is a Florida net- for-profit incorporated association of

    ophthalmologists, who are allopathic and osteopathic physicians (M.D.'s and D.O.'s) specializing in the medical diagnosis of eye diseases, anomalies and disorders, and treatment with medication, surgery, and corrective lenses and prisms. FSO acts and is organized to further the education, professional, and economic interests of the Florida ophthalmologists. FSO routinely represents and serves its members through public relations activities, interactions with governmental agencies, and participation in administrative proceedings, legislative affairs and litigation. In addition to the representation of its members, FSO is committed as an organization to protecting, maintaining and improving the quality of eye care which is available to the public.

    3. Petitioners Broussar, Patrowicz, and Byerly are physicians licensed by

    the State of Florida pursuant to Chapter 458, Fla. Stat. Broussard maintains an office for the practice of medicine in Melbourne, Florida; patrowicz in Mount Dora, Florida; and Byerly in Tallahassee, Florida. Each physician specializes in the field of ophthalmic medicine opthalmology. Ophthalmology consists of the medical diagnosis of eye diseases, anomalies and disorders, and treatment with medication, surgery and corrective lens and prisms. Many of these Petitioners' patients also visit optometrists for some of their vision care needs. . .


  13. The following allegations were included in the petition in Board of Optometry, concerning the substantial affect on the FSO and the individual opthalmologists:


    1. The physician Petitioners and a substantial number of the members of the association Petitioners are substantially affected by the Board's proposed certification of any optometrist as a certified optometrist in the following ways:

      1. Petitioners believe that the certification of optometrists, and the concomitant authorization of such certified optometrists to use and prescribe medications in their practice of optometry encroaches on the right of physicians licensed to practice medicine pursuant to Chapter 458, Fla. Stat. The right to practice medicine is a valuable property right in Florida, and subject to the protection of the due process clauses of the Florida and United States Constitutions. Petitioners have been denied due process in regard to the impending infringement on or diminution in value of their property rights.

      2. Petitioners also believe that the quality of eye care and health care available to the public will decline as optometrists are certified to use and prescribe medicine in the practice of optometry. Petitioners believe that allowing optometrists to administer and prescribe drugs presents a danger to the public, including but not limited to Petitioners' patients.

      3. Petitioners believe that the general public is uninformed as to the distinction between optometrists and ophthalmologists, when in fact significant differences exist in education, training, ability, experience, and scope of practice. The designation of some optometrists as "certified optometrists" further adds to the confusion and will result in the treatment by optometrists of patients who should be treated by Physicians. This not only will result in economic injury to physicians, including the. physician Petitioners and all other similarly situated, but also in injury to their practices, loss of public respect for their profession, and

    to the health and welfare of Petitioners' patients and the patients of other similarly situated physicians.


    CONCLUSIONS OF LAW


  14. The Division of Administrative Hearings has jurisdiction of the parties to and the subject matter of this proceeding. Section 120.54, Florida Statutes (1989).

  15. Section 463.0055(1), Florida Statutes (1989), authorizes certified optometrists in the State of Florida to prescribe and administer topical ocular pharmaceutical agents. Section 463.0055(2), Florida Statutes (1989), establishes the requirements for becoming a certified optometrist.


  16. Section 463.0055(4), Florida Statutes (1989), establishes the procedure for adopting a formulary of topical ocular pharmaceutical agents (hereinafter referred to as the "drug formulary"), that may be administered and prescribed by certified optometrists. This Section creates a committee which is charged with responsibility for developing the drug formulary and submitting it to the Respondent for adoption as a rule. The initial drug formulary was adopted as Rule 21-18.002, Florida Administrative Code. Rule 21-18.002, Florida Administrative Code, was challenged and was found to be valid by a Hearing Officer of the Division of Administrative Hearings in Florida Society of Ophthalmology v. Department of Professional Regulation, 10 F.A.L.R. 438 (DOAH 1987).


  17. Additions or deletions to the drug formulary are to be accomplished in the same manner in which the initial drug formulary was created. Section 463.0055(4)(b), Florida Statutes (1989). The Respondent has previously amended the drug formulary as authorized by Section 463.0055(4)(b), Florida Statutes. Pursuant to this authority, the Respondent has again proposed to amend Rule 21- 18.002, Florida Administrative Code, by adding certain Steroids and steroid/Sulfonamide combinations to the drug formulary. It is the addition of these drugs through the Rule Amendment that the Petitioners have challenged.


  18. The Intervenors have alleged that the Petitioners have not and, indeed cannot, allege facts sufficient to prove their standing to challenge the Rule Amendment. Accordingly, the Intervenors have filed a motion requesting that the challenge be dismissed.


  19. In order to institute a rule challenge, the person challenging the rule must allege facts sufficient, if proven, to show that the person is substantially affected by the challenged rule. Section 120.54(4), Florida Statutes (1989) To challenge a proposed rule, Section 120.54(4)(b), Florida Statutes (1989), requires, among other things not relevant here, that a petition be filed in writing which "state[s] with particularity . facts sufficient to show the person challenging the proposed rule would be substantially affected it."


  20. In order to be considered substantially affected, it must be proved that the person challenging the rule will suffer a direct injury in fact of "sufficient immediacy and reality" as a result of the application of the challenged rule. Florida Department of Offender Rehabilitation v. Jerry, 353 So. 2d 1230, 1236 (Fla. 1st DCA 1978), cert. denied, 39 So. 2d 1215 (Fla. 1978)


  21. Based upon the allegations concerning standing contained in the pleadings filed by the Petitioners and the First District Court of Appeals' decision in Board of Optometry v. Society of Ophthalmology, 538 So. 2d 878 (Fla. 1st DCA 1989), cert. denied, 545 So. 2d 1367, it is concluded that the Petitioners, as argued by the Intervenors, have not and cannot allege facts sufficient to show that the Petitioners have standing to bring this rule challenge.

  22. In Board of Optometry, FSO and three individual ophthalmologists challenged the rule establishing the procedures and requirements to be certified as an optometrist. In support of their standing in Board of Optometry, FSO and the ophthalmologists alleged that the rule infringed upon the exclusive right of ophthalmologists to administer topical ocular drugs in providing eye care (a protected economic right) and that they had an interest in the quality of eye care being provided to the public. The court rejected FSO's and the ophthalmologists' alleged bases for standing. Of relevance to this proceeding, the court rejected the claim that FSO's or the individual ophthalmologists' interest in the welfare of the public was legally sufficient to give them standing to challenge a rule governing the regulation of optometrists:


    In the instant case, petitioners'

    right to administer topical ocular drugs is no longer exclusively reserved to their field of practice regulated by chapters 458 and 459, Florida Statutes, and they no longer are in a position, as they were in Board of Optometry and Florida Medical Association, to assert a protected economic right that has been impaired by the subject rule.

    Consequently, petitioners' continuing general interest in the quality of eye care being provided to the public is not predicated upon a legally

    right of sufficient immediacy and reality to support their standing to challenge the validity of the adopted rule. . .


    Board of Optometry, 538 So. 2d at 881.


  23. The facts concerning FSO and the individual ophthalmologist relied upon by the Petitioners in this case are the same in all material respects to the facts concerning FSO and the individual ophthalmologists relied upon by the Petitioners in Board of Optometry. Compare findings of fact 4 and 5, which quote the allegations of fact relied upon by FSO and the individual ophthalmologists in this case, with finding of fact 12, which quotes the allegations of fact relied upon by FSO and the individual ophthalmologists in Board of Optometry.


  24. The allegations concerning how the Petitioners in Board of Optometry believed they were substantially affected by the rule challenged in that case differ from the allegations concerning how the Petitioners in this case believe they will be substantially affected. Those differences are not material, however. Compare findings of fact 6 and 7 with finding of fact 13. The primary difference in the allegations of substantial affect in this case and in Board of Optometry is that the Petitioners in this case have dropped some of the injuries alleged in Board of Optometry, including the allegation that the right of ophthalmologists to administer topical ocular drugs is being infringed upon.

    The Petitioners have, however, continued to rely upon the second basis for standing relied upon by the Petitioners in Board of Optometry: their interest in protecting the quality of eye care provided to the public. The court's ruling in Board of Optometry that the Petitioners' interest in protecting the quality

    of eye care provided to the public is not a legally recognized right of sufficient immediacy and reality to support their standing applies with equal weight to this case.


  25. The Petitioners have argued in their response to the Intervenor's Motion to Dismiss and in the Petitioners' Proposed Order on Standing that this case should not be compared with Board of Optometry or Florida Society of Ophthalmology v. State Board of Optometry, 532 So. 2d 1279 (Fla. 1st DCA 1988), cert. denied, 542 So. 2d 1333 (Fla. 1989), because of differences between this case and those cases. Although it is true that there are differences in the facts and the nature of the challenges in those cases, those differences are not sufficient to justify concluding that the Petitioners have standing to institute this rule challenge.


  26. Although the Florida Society of Ophthalmology case involved a challenge to the certification of optometrists and not a challenge to the drug formulary rule, the court's conclusions in that case support the conclusion reached in thin case that the Petitioners do not have standing to challenge the Rule Amendment. Like Board of Optometry, the court in Florida Society of Ophthalmology concluded that the ophthalmologists' alleged concern with the quality of eye care available to the public was legally insufficient to establish their standing for two reasons:


    1. The court held that FSO and the ophthalmologists were not authorized to represent their patients' rights; and


    2. The court concluded that acceptance of the alleged basis for standing would be an invitation to review whether optometrists in general should be allowed to administer topical ocular pharmaceutical agents. The court noted that this was a policy question already resolved by the Legislature.


  27. The Petitioners have failed to suggest any reason for ignoring the logic employed by the court in Board of Optometry or Florida Society of Ophthalmology. It does not automatically follow that, because there are differences in those cases and this case, the court's conclusions of law in Board of Optometry and Florida Society of Ophthalmology should not be followed to the extent applicable in this case. Absent some argument to the contrary, it is concluded that the reasoning of the court in those cases applies to this case.


  28. The Petitioners have also argued that they have standing because the Legislature has provided that two opthalmologists should serve on the drug formulary committee and the Secretary of the Respondent has appointed two opthalmologists to the committee. Therefore, the Petitioners have argued that "[i]t's obvious that members of a committee mandated by the legislature and appointed by the DPR secretary have a substantial interest in the work product of the committee on its affects on the citizens of this state." Petitioners' Response to Respondent's [sic] Motion to Dismiss, page 3. This argument is rejected. As pointed out by the Intervenors, the role of the drug formulary committee is limited by Section 463.0055(4), Florida Statutes (1989). Participation by two opthalmologists on the committee does not extend the interest of opthalmologists generally in protecting the interest of the public, or even the interest of opthalmologists in the actions of the committee in carrying out its limited function.

  29. The Petitioners have also cited Section 463.001, Florida Statutes (1989), in support of their standing. Section 463.001, Florida Statutes (1989), provides:


    The sole legislative purpose in enacting this chapter is to assure that every person engaged in the practice of optometry in this state meets minimum requirements for safe practice. It is

    the legislative intent that such persons who fall below minimum standards or who otherwise present a danger to the public shall be prohibited from practicing in this state. Nothing in this chapter shall be construed to prevent a person licensed under chapter 458, chapter 459, or part I of chapter 484 from performing those services which he is licensed to perform. The provisions of this chapter shall have no application to any person furnishing emergency assistance in case of an emergency.


    Nothing in Section 463.001, Florida Statutes (1989), indicates any intent of the Legislature that opthalmologists protect the safety and welfare of the public in the context of this case.


  30. In the Petitioners' Proposed Order on Standing the Petitioners have cited Section 458.301, Florida Statutes (1989), in support of their alleged standing. This section expresses the Legislature's intent that "every physician practicing in this state [meet] the minimum requirements for safe practice." The expression of this intent does not support a conclusion that the Legislature intended that opthalmologists protect the safety and welfare of the public by policing other professions.


  31. Finally, the Petitioners have cited two-cases in their Proposed Order on Standing which the Petitioners have argued support their standing in this case. Those cases are Florida Medical Association v. Department of Professional Regulation, 426 So. 2d 1112 (Fla. 1st DCA 1983), and City of Lynn Haven v. Bay County Council of Registered Architects, 528 So. 2d 1244 (Fla. 1st DCA 1988).


  32. The Florida Medical Association case was decided before the Board of Optometry decision and was relied upon by the Petitioners in the Board of Optometry case. The court, recognizing that the statutory law had changed since its decision in Florida Medical Association, refused to rely upon that decision to conclude that the Petitioners in Board of Optometry had standing. The Petitioners have presented no persuasive argument why, given the court's decision in Board of Optometry, Florida Medical Association should be followed in this proceeding.


  33. The Lynn Haven decision is also not persuasive. That case concerned the standing of a nonprofit corporation, whose members were registered architects, to challenge the process by which the City of Lynn Haven competitively bid a public safety building construction project. The court in Lynn Haven found that the nonprofit corporation had standing because the City's interpretation of statutory law denied the corporation's members potential

professional and economic benefits. The Lynn Haven decision does not support the Petitioners' position in this case because of the more specific decision of the court in Board of Optometry.


ORDER


Based upon the foregoing Findings of Fact and Conclusions of Law, it is ORDERED that the Petition in this case be dismissed with prejudice.

DONE and ENTERED this 9th day of August, 1990, in Tallahassee, Florida.



LARRY J. SARTIN

Hearing Officer

Division of Administrative Hearings The DeSoto Building

1230 Apalachee Parkway

Tallahassee, Florida 32399-1550

(904) 488-9675


Filed with the Clerk of the Division of Administrative Hearings this 9th day of August, 1990.


COPIES FURNISHED:


Karen L. Goldsmith, Esquire Post Office Box 1980 Orlando, Florida 32802-1980


John Miller, Esquire Dempsey & Goldsmith, P.A. Post Office Box 10651 Tallahassee, Florida 32302


Charles Tunnicliff, Esquire Department of Professional

Regulation

1940 North Monroe Street Suite 60

Tallahassee, Florida 32399-0792


James C. Adkins, Esquire Leonard A. Carson, Esquire John D.C. Newton II, Esquire Lucille D. Turner, Esquire Mahan Station

1711-D Mahan Drive Tallahassee, Florida 32308

Patricia Guilford Executive Director Board of Optometry

Department of Professional Regulation

1940 North Monroe Street Tallahassee, Florida 32399-0792


Kenneth D. Easley, Esquire General Counsel

Department of Professional Regulation

1940 North Monroe Street Tallahassee, Florida 32399-0792


Lawrence A. Gonzalez, Secretary Department of Professional

Regulation

1940 North Monroe Street Tallahassee, Florida 32399-0792


Carroll Webb, Executive Director Administrative Procedures Committee Holland Building, Room 120 Tallahassee, Florida 32399-1300


NOTICE OF RIGHT TO JUDICIAL REVIEW


PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW PURSUANT TO SECTION 120.68, FLORIDA STATUTES. REVIEW PROCEEDINGS ARE GOVERNED BY THE FLORIDA RULES OF APPELLATE PROCEDURE. SUCH PROCEEDINGS ARE COMMENCED BY FILING ONE COPY OF A NOTICE OF APPEAL WITH THE AGENCY CLERK OF THE DIVISION OF ADMINISTRATIVE HEARINGS AND A SECOND COPY, ACCOMPANIED BY FILING FEES PRESCRIBED BY LAW, WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITHIN 30 DAYS OF RENDITION OF THE ORDER TO BE REVIEWED.


Docket for Case No: 90-003285RP
Issue Date Proceedings
Aug. 09, 1990 Final Order (hearing held , 2013). CASE CLOSED.

Orders for Case No: 90-003285RP
Issue Date Document Summary
Aug. 09, 1990 DOAH Final Order Ophthalmology Association and practitioners not have standing to challenge amend- ment of drug formulary for optometrists.
Aug. 09, 1990 DOAH Final Order Ophthalmology Association and practitioners not have standing to challenge amend- ment of drug formulary for optometrists.
Source:  Florida - Division of Administrative Hearings

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