)
RECOMMENDED ORDER
Pursuant to notice, this cause came on for formal hearing before P. Michael Ruff, duly-designated Administrative Law Judge of the Division of Administrative Hearings, on October 11, 1996, in Tallahassee, Florida.
APPEARANCES
For Petitioner: Lawrence E. Suess, D.O., Ph.D., pro se
Owensboro Psychiatric Institute 1700 Frederica Street, Suite 106
Owensboro, Kentucky 42301
For Respondent: M. Catherine Lannon, Esquire
Department of Legal Affairs The Capitol, Room PL-01
Tallahassee, Florida 32399-1050
STATEMENT OF THE ISSUES
The issue to be resolved in this proceeding concerns whether the licensure examination taken by the Petitioner qualifies him under Section 459.007(3), Florida Statutes, for licensure as an osteopathic physician in the State of Florida.
PRELIMINARY STATEMENT
This cause arose upon the application by the Petitioner for licensure as an osteopathic physician, pursuant to Section 459.007(3), Florida Statutes. An order was issued by the above- named Board on November 9, 1995, in which licensure upon a condition was granted, such that within one year, the Petitioner must successfully complete Part III of the National Board of Osteopathic Medical Examiners (NBOME) examination for purposes of licensure in Florida (not for diplomate status).
The Board found that the Petitioner had not passed all three parts of that examination and had submitted certification of passage of only Parts I and II. The Board further found that the Federation Licensure Examination (FLEX) was not a substantially- similar examination to the NBOME examination, since it did not contain an osteopathic medicine component. The Board also found that the completion by the Petitioner of a board certification examination was not substantially similar to completion of the NBOME examination because such a board certification examination tests only a single subject matter and not the broad principles
of osteopathic medicine contained in Part III of the NBOME examination.
On November 13, 1995, the Board received a petition for formal hearing from the Petitioner, in which he complained that he could not complete Part III of the NBOME examination because he was already beyond the time period allowed for taking of Part
He further claimed that the FLEX was a substantially similar examination to the NBOME. In any event, the cause was ultimately transferred to the undersigned for formal proceeding on March 27, 1996.
The cause came on for hearing as noticed. The Petitioner testified on his own behalf and introduced three exhibits. The admission of those exhibits into evidence was, however, made contingent upon the Petitioner supplying copies of them to the Administrative Law Judge and to counsel for the Respondent. He was allowed to do this by mailing the exhibits to those persons within five days after the date of the hearing, but the exhibits were never provided and, therefore, are not admitted into evidence.
The Respondent presented the testimony of Morton Morris, D.O., J.D. The Respondent also had two depositions admitted into evidence. These depositions were admitted subject to the Administrative Law Judge’s consideration of whether the deponents were proper experts in the relevant subject areas. A review of those depositions reveals that they are appropriate expert
witnesses. Therefore, the depositions have been admitted into evidence.
Upon conclusion of the hearing, the parties requested the opportunity to file Proposed Recommended Orders. Those Proposed Recommended Orders, after the granting of an extension of time for their filing, were timely filed by the parties.
FINDINGS OF FACT
The Petitioner, Lawrence Edward Suess, is an osteopathic physician licensed by the Boards of Medical Examiners in Texas, Alabama, and Kentucky. He seeks licensure in Florida, pursuant to Section 459.007(3), Florida Statutes. He is also licensed in Arizona and Texas as a registered nurse, holds BS and MS degrees in child development and nursing and a Ph.D. in nursing.
The Respondent, the Board of Osteopathic Medicine (Board), is an agency of the State of Florida, charged with regulating the admission to practice and the practice and licensure standards of osteopathic physicians licensed or seeking to be licensed in the State of Florida. The Board issued an order, as corrected, on November 9, 1995, granting application of licensure to the Petitioner upon the condition that within one year, he successfully complete Part III of the NBOME examination for purposes of licensure in the State of Florida, and not for diplomate status. The Board found in that order that the Petitioner had not passed all three parts of the NBOME
examination and had submitted certification of passage of only Parts I and II. The Board found that the “FLEX” examination was not a substantially-similar examination to the required NBOME examination since the FLEX examination did not contain an osteopathic medicine component. The Board also found that the completion by the Petitioner of a Board certification examination was not substantially similar to the NBOME examination because it tested only a single subject matter and not the broad principles contained in Part III of the NBOME examination.
On November 13, 1995, a Petition for Formal Hearing was filed by the Petitioner disputing the decision of the Board which precluded him from obtaining licensure to practice medicine in the State of Florida because of failure to complete Part III of the NBOME examination. He contended that he was outside the time period in which he would be allowed to take Part III. He further contended that the FLEX examination was a substantially-similar examination to the NBOME examination.
The Petitioner contends that taking the FLEX examination should be sufficient to justify licensure, although he also acknowledged that Part III of the NBOME examination tests osteopathic philosophy and principle; and he acknowledged that the FLEX examination does not, although he was attempting to testify and argue that the FLEX examination was substantially similar to the NBOME examination. He provided no testimony or
evidence, however, to establish that the FLEX examination tests osteopathic philosophy and principle.
The Respondent presented the testimony of Joseph Smoley, Ph.D. by deposition. Dr. Smoley holds a Ph.D. in educational measurement and has served for ten of the last eleven years as Executive Director of the NBOME. The NBOME is an organization that develops an examination that is independent of the osteopathic medical schools to evaluate osteopathic physicians who are either currently in undergraduate or in graduate medical programs. The NBOME’s main mission is to provide state licensing examinations with an independent assessment of the knowledge base of candidate osteopathic physicians.
Dr. Smoley oversees NBOME policy and supervises educational measurement within the osteopathic profession. His oversight responsibilities include the examination section of the NBOME. He provides a constant review of the process of testing for the Board of Directors. The NBOME developed its examination by having questions drafted by faculty members and osteopathic physicians in independent practice. Faculty members may be D.O.’s or Ph.D.’s in the various basic sciences, and there is a multi-tiered process for preparing and reviewing questions. A copy of the bulletin of information concerning the NBOME examinations was attached to and made part of the deposition.
Dr. Smoley testified that typically the candidates take Part I as a sophomore during medical school, Part II as a senior, and Part
III as an intern in their first post-graduate year. He established that the purpose behind that examination is “the integration of osteopathic principles and practices as well as the philosophy of osteopathic medicine.”
No allopathic physicians are involved in the grading process of that examination. Some allopathic physicians associated with osteopathic colleges may submit questions that, after the review process, may be used on the examination. The purpose of the NBOME examination, as shown by Dr. Smoley, is to make sure that each question integrates osteopathic principles and practices in some way and that the entire examination is reflective of the practice of osteopathic medicine.
Dr. Smoley is also familiar with the FLEX examination, as well as the current licensure examination for allopathic physicians, the USMLE. The Federation of State Medical Boards (FSMB) does not prepare any complete examination or any additional components for its regular examination concerning manipulation or osteopathic practice and principles. According to Dr. Smoley, there has never been an official comparison or analysis between the NBOME examination and the FLEX examination. Based upon his experience and educational measurement, he has determined that if one examination, the NBOME, contains osteopathic principles and practice and the other examination, the FLEX, does not incorporate those principles and practices, then the two examinations could not be considered equivalent.
The NBOME examination is more extensive because it integrates osteopathic principles and practice throughout its content. This osteopathic examination is not simply one that tests manipulation. Therefore, it is not asserted to be appropriate for chiropractors or M.D.’s who have been trained in manipulation but only for persons who have received an osteopathic medical education.
The Respondent also presented the testimony by deposition of James R. Winn, M.D. He is Executive Vice President of the FSMB. The FSMB assists state medical boards in conducting their evaluation of physicians regarding their fitness to practice medicine. The FSMB developed examinations which are administered by state boards. Dr. Winn serves as the supervisor for the examination services section of the FSMB. Those examinations are developed in cooperation with the National Board of Medical Examiners. The current examination available from the FSMB is the United States Medical Licensing Examination (USMLE) used since 1992. Prior to that time, the FSMB administered the FLEX examination, which was for the evaluation of all physicians requesting licensure. The FLEX examination did not have a section on osteopathic practice, as shown by Dr. Winn. The FSMB allows all physicians seeking licensure in the United States to take that examination, including graduates of osteopathic medical schools and graduates of foreign medical schools. With the FLEX examination, unlike the NBOME examination, medical students are
not eligible, only graduates of medical schools are eligible to take the examination.
Dr. Winn is familiar with the examination of the NBOME and its purpose. He is not aware of any side-by-side comparison between the two examinations to determine equivalency. In his expert opinion, there would have to be such an evaluation in order to determine whether the examinations are equivalent.
The testimony of Drs. Smoley and Winn was elaborated upon and corroborated by Dr. Morton Morris. Dr. Morris is a licensed osteopathic physician in the State of Florida and is board certified in osteopathic surgery by the American Osteopathic Board of Orthopedic Surgery. He is also certified by the American Board of Quality Medical Assurance and is a fellow of the American College of Legal Medicine. He is Vice-Chancellor for academic affairs in the health professions division at Nova Southeastern University, a Florida osteopathic medical school. Additionally, Dr. Morris is a licensed, practicing attorney in the State of Florida. He practices in the areas of medical malpractice, general health law and administrative law.
Dr. Morris is familiar with the NBOME examination, having served as a test item writer for the NBOME. He recognizes Dr. Smoley as one who helps develop the philosophy of the examinations in question. The philosophy of the NBOME is that content concerning osteopathic practice and principles permeates the entire examination. Even when certain questions on their
face are not osteopathically oriented, the evaluation and the grading of the responses is carried out from an osteopathic viewpoint and philosophy. The test item writers are directed to draft test questions which include osteopathic philosophy.
In the past, the NBOME has agreed to allow a candidate to take only Part III or an equivalent examination and receive the score from the NBOME. In fact, Dr. Morris represented that person in his capacity as an attorney. He worked out the arrangements whereby that candidate could take and pass Part III of the NBOME examination in order to obtain a Florida osteopathic medical license, as the Petitioner seeks herein, even though, since he would not have taken Part III within the required seven years, he could not receive diplomate status with the NBOME. The Board’s order in this case specifically requires passage of Part III of that examination, but it does not require diplomate status. Such an arrangement would thus seem to provide a means to alleviate the Petitioner’s predicament in the instant situation.
The Petitioner, in questioning Dr. Morris upon cross- examination, inquired about the possibility of a person taking all three parts of the NBOME examination, even if he had already taken Parts I and II. Dr. Morris stated that that was possible. Page 7 of the Bulletin of Information, in evidence in Respondent’s Exhibit 1, although stating that the candidate cannot take the examination “to attempt to improve his score”,
states nothing to indicate preclusion of a candidate taking the entire examination for any other purpose. Dr. Morris stated that the Petitioner could take Part III of the examination and that the NBOME would make arrangements to allow him to do that, with the understanding that if he passed Part III, he would not be able to receive diplomate status from the NBOME (because of passage of time before taking Part III).
In making comparisons between osteopathic medical education and allopathic medical education, Dr. Morris acknowledged that in some cases, osteopathic medical colleges use the same textbooks as used by allopathic medical schools. That does not, however, make them similar professions. Although anatomy and physiology may not be different, the philosophy of treating the whole patient is different.
Responding to the Petitioner’s contention that having obtained board certification in his specialty area should count as equivalency to the entry level examination, Dr. Morris pointed out that all that the board certification accomplishes is to show that an osteopathic physician is recognized by his or her peers as competent to practice a specialty. It does not mean that the person is osteopathically oriented enough to be eligible for licensure and to be able to pass a minimum competency examination.
The Petitioner contends that having passed Parts I and II of the NBOME examination, FLEX should quality him for
osteopathic licensure in the State of Florida, in lieu of taking Part III of the NBOME examination, because anything of an osteopathic nature would have already been tested on Parts I and
II. Dr. Morris established to the contrary, however, that Part III is the clinical testing, the testing of how the individual puts to use his clinical evaluation in treatment of patients. It is the ultimate test of whether an individual has developed and is able to apply a philosophy of practice sufficient to show that he is competent to be an osteopathic physician. Parts I and II of the NBOME examination do not test clinical skills. The FLEX does test clinical skills, but it does not test for osteopathic practices as to clinical skills.
The NBOME requires that a person take Part III within seven years of having taken Part I, if that person wishes to be a diplomate of the NBOME. There is no apparent preclusion, however, in a person arranging to take only Part III, simply for purposes of state licensure. The record is not clear whether a person could take Parts I, II and III within the period of one year. It does seem apparent, however, that the Petitioner could take Part III within a one-year time period, which is all that is required in the Board’s order.
Further, the statute requires that a person take all parts of the NBOME examination or a substantially-equivalent examination. What the Petitioner attempts to do is to take two parts of the NBOME examination and then substitute a different
examination (FLEX) for Part III. This does not constitute a substantially-equivalent examination for the above reasons. A substantially-equivalent examination would have to be equivalent to all three parts of the NBOME examination.
During discussion of the difference between osteopathic and allopathic schools of medicine, Dr. Morris pointed out that many osteopathic physicians use the same modalities that allopathic physicians use. It is just that they also use osteopathic modalities. He gave the example of a cardiac patient whom an osteopathic physician would treat just as a medical doctor would treat the basic condition with appropriate drugs but then would incorporate osteopathic philosophy, such as the “lymphatic pump”, meaning that the osteopathic physician would incorporate muscle techniques of stretching and passive manipulation in order to help the patient. The osteopathic physician would possibly use manipulative techniques on the lymphatic system and not just use drugs or other allopathic techniques. In the context of the NBOME examination, a question might reference a cardiac patient. Although the question would not mention the lymphatic pump, a proper answer might entail a clinical response that would consider that modality of treatment. In orthopedics, Dr. Morris’ specialty, an osteopathic physician can make significant use of manipulative techniques, as well as general surgery, casting and other modalities normally used by allopathic physicians. Use of the FLEX examination, rather than
the NBOME examination, would not lower standards for osteopathic physicians. Rather, the FLEX examination simply embodies a different standard than the one used to test for competency in osteopathic principles and medicine.
The Petitioner acknowledged that he could have taken Part III of the NBOME examination but chose not to because it was then more convenient for him to take the FLEX examination to continue his training in the State of Texas which required passage of the FLEX examination for osteopathic licensure. The Petitioner contended that if he applied for a Florida osteopathic medical faculty certificate (MFC), the FLEX examination would be acceptable and he would be eligible. That fact, he contends, by analogy, establishes that he is qualified to practice osteopathic medicine in the State of Florida.
He has never applied for such a certificate nor has he been offered an osteopathic medical faculty position in the State of Florida. Thus, determination of that issue is not before this tribunal. Even if it were, there are significant differences between a full license to practice osteopathic medicine indefinitely and a medical faculty certificate. With the MFC, the Petitioner would not be allowed to be engaged in private practice of osteopathic medicine and the MFC would only allow him to practice in the academic realm for only two years.
Finally, the statutory requirements for an MFC do not require the passage of any licensure examination. Accordingly,
to the extent that the Petitioner’s argument and testimony implies some analogy or equivalency between eligibility for the MFC and eligibility for full licensure, such equivalency is not borne out by the greater weight of the evidence.
CONCLUSIONS OF LAW
The Division of Administrative Hearings has jurisdiction of the subject matter of and the parties to this proceeding. Section 120.57(1), Florida Statutes.
The Petitioner has applied for licensure by endorsement, pursuant to Section 459.007, Florida Statutes, which licensure method requires that an applicant must:
Have passed all parts of the examination conducted by the National Board of Osteopathic Medical Examiners or other similar examination approved by the board.
The burden of proof is on an applicant for licensure when that licensure has been initially denied by the agency and the same is true where licensure is granted but granted upon a condition which is then challenged. See, Balino v. Deportment of Health and Rehabilitative Services, 362 So.2d 21 (Fla. 1st DCA 1978), and Florida Department of Transportation v. J.W.C. Company, Inc., 396 So.2d 778 (Fla. 1st DCA 1981).
It is undisputed that the Petitioner obtained an appropriate osteopathic medical education and passed Parts I and II of the NBOME examination. He admittedly has not passed Part III of the NBOME examination but, instead, took the FLEX
examination. He did this as a matter of convenience because he graduated from medical school and it was then the examination accepted by the State of Texas at the time he sought licensure in that jurisdiction.
The Petitioner has presented no evidence that the FLEX examination is a substantially-similar examination to the NBOME examination, Part III, other than his own self-serving testimony. The testimony in evidence offered by the Respondent is preponderant in establishing that the NBOME examination tests osteopathic principles and practices and that those principles and practices are not tested by the FLEX examination. The Petitioner has not contended at anytime that the FLEX examination is equivalent to the entirety of the NBOME examination. This would seem to be what the statute requires; that the “substantially similar examination” approved by the Board for licensure has to be substantially similar to the entirety of the NBOME examination and not just to one part of it. Licensure as an osteopathic physician in the State of Florida, otherwise, would be available simply by picking and choosing parts of various examinations, cobbling them together to fabricate a favorable examination passage history for admission to osteopathic medical licensure, by arguing that that history is equivalent to passage of the comprehensive NBOME examination.
The Petitioner also argues that the fact that he is board certified means that he is qualified for Florida licensure
as an osteopathic physician. It is laudable that the Petitioner is board certified and that may show, as a factual matter, that he is a competent osteopathic physician. However, he unfortunately has not established that he meets the legal requirements for licensure in terms of the statutory standard of examination passage required for Florida licensure. The preponderant evidence establishes that board certification is based upon an examination in a narrow area of the practice of medicine, a specialty area, and is not a general examination covering clinical skills expected of all osteopathic physicians. The statutory requirement for licensure embodies a general examination covering all such clinical skills expected of osteopathic physicians in all potential areas of practice.
The Petitioner maintains that taking Part III of the NBOME examination is an impossibility for two reasons: (1) because he is not permitted to take Part III since it has been more than seven years since he sat for Parts I and II; and (2) he could not take all three parts within one calendar year as would seem to have been required by the language of the Board’s order in his case.
Dr. Morris’ testimony refutes the implication that he is not permitted to take just Part III of the examination. Dr. Morris established that he himself had arranged with the NBOME to provide Part III of the examination to an applicant for licensure in Florida, which the NBOME agreed to do. This was with the
understanding that, although that person would be eligible for Florida licensure as an osteopathic physician if he passed Part III, he would not receive NBOME diplomate status by that method. The Petitioner’s testimony that he would not be able to do this did not embody any of the specificity required to overcome Dr.
Morris’ assertion to the contrary. There is no evidence that the Petitioner has attempted to obtain NBOME approval of such an arrangement.
Additionally, the Petitioner contends that he would be unable to take Part III within one year because in order to take Part III, he would have to first re-take the other two parts. However, a review of the booklet attached to Petitioner’s Exhibit
1 indicates that it might be possible for a person to schedule Parts I, II and III within one year, if he or she immediately applied for one examination upon completion of another.
The Petitioner has raised another issue concerning his purported eligibility for an MFC in an osteopathic medical school had he applied for that. He has not applied for that certification and no determination as to his eligibility for such an MFC is at issue in this case. He makes that argument apparently to show, by analogy, that if the statute recognizes that the FLEX examination he took should be an acceptable equivalent to the NBOME examinations for one applying for an MFC to teach in an osteopathic medical school, then it should be equivalent to NBOME Part III and acceptable for licensure.
Section 459.0077, Florida Statutes, deals with osteopathic faculty certificates. That provision provides that an applicant for an osteopathic MFC may receive that certificate based upon whether he is currently licensed to practice osteopathic medicine in another jurisdiction in the United States, can demonstrate that he is a graduate of an osteopathic medical school and has completed some other requirements not germane here. The statute explicitly states that the osteopathic faculty certificate can be issued without examination. Thus, even if the Petitioner were eligible under this statute for the two-year limited faculty certificate, that certificate would not be based upon examination equivalency, since no examination is required for the issuance of that certificate at all. That certification is simply based upon the fact that the Petitioner would be licensed in another jurisdiction and met other requirements of law not germane herein. Thus, his testimony that passing the FLEX qualified him for the MFC and, therefore, osteopathic licensure, as well, is not an apt analogy since the MFC does not depend on any examination at all.
The Petitioner attempts to combine an osteopathic medical education, which he clearly has, with a licensure examination which is acceptable for M.D. licensure. While this may adequately test his competency to factually and scientifically justify admission as a licensed osteopathic physician in Florida, the fact remains that it is simply not
legally acceptable under Florida’s statutory scheme. Florida, for whatever purpose, has explicitly determined that a demarcation line must be clearly drawn between the practice of osteopathic medicine, pursuant to Chapter 459, Florida Statutes, and the practice of allopathic medicine, pursuant to Chapter 458, Florida Statutes. The First District Court of Appeal in 1982 specifically found in Gulf Coast Hospital, Inc. v. Department of Health and Rehabilitative Services, 424 So.2d 86 (Fla. 1st DCA 1982), that it was the Legislature’s province to determine public policy with regard to the need for identifiable osteopathic facilities, as compared to allopathic medical facilities. In doing so, the court also recognized that osteopathy and allopathy were two separate and distinct schools of medicine, with differing philosophies and practice. In consideration of that principle, the court opined that it was not for administrative determination whether or not such distinctions were necessary but, rather, a matter for legislative judgment. When the Legislature has chosen to recognize separate and distinct professions and requirements for entry into those professions, it is not for the administrative forum to gainsay the manner in which the statutory determinations concerning those entry requirements are made and enacted.
In summary, the evidence has not demonstrated in a preponderant way that the FLEX examination, which the Petitioner seeks to have determined to be equivalent to the required portion
of the NBOME examination is, indeed, equivalent in terms of adequately testing osteopathic principles and practices.
Moreover, it has been demonstrated that a practical means for the Petitioner to take Part III of the NBOME examination exists and can likely be availed of by the Petitioner should he choose to do so.
Based upon the foregoing Findings of Fact and Conclusions of Law, it is
Administrative Law Judge
Division of Administrative Hearings The DeSoto Building
1230 Apalachee Parkway
Tallahassee, Florida 32399-3060
(904) 488-9675 SUNCOM 278-9675
Fax Filing (904) 921-6847
Filed with the Clerk of the Division of Administrative Hearings this 28th day of February, 1997.
Lawrence E. Suess, D.O., Ph.D. Owensboro Psychiatric Institute 1700 Frederica Street, Suite 106
Owensboro, Kentucky 42301
M. Catherine Lannon, Esquire Department of Legal Affairs The Capitol, Room PL-01
Tallahassee, Florida 32399-1050
William H. Buckhalt, Executive Director Board of Osteopathic Medicine
Agency for Health Care Administration 1940 North Monroe Street
Tallahassee, Florida 32399-0757
Jerome W. Hoffman, General Counsel Agency for Health Care Administration 2727 Mahan Drive
Tallahassee, Florida 32309
All parties have the right to submit written exceptions within 15 days from the date of this Recommended Order. Any exceptions to this Recommended Order should be filed with the agency that will issue the Final Order in this case.
| Issue Date | Proceedings |
|---|---|
| Mar. 03, 1997 | Recommended Order sent out. CASE CLOSED. Hearing held October 11, 1996. |
| Dec. 10, 1996 | Respondent Board of Osteopathic Medicine`s Proposed Recommended Order received. |
| Dec. 10, 1996 | (Petitioner) Statement of Issues (filed via facsimile) received. |
| Nov. 26, 1996 | (Respondent) Notice for Extension of Time (filed via facsimile) received. |
| Nov. 08, 1996 | Notice of Filing; DOAH Court Reporter Final Hearing Transcript received. |
| Oct. 21, 1996 | Curriculum Vitae Lawrence Edward Suess received. |
| Oct. 11, 1996 | CASE STATUS: Hearing Held. |
| Oct. 03, 1996 | (M. Catherine Lannon) Notice of Substitution of Counsel received. |
| Jul. 03, 1996 | (Respondent) Notice of Taking Deposition received. |
| Jun. 10, 1996 | Order Granting Continuance and Amended Notice sent out. (Hearing rescheduled for 10/11/96; 9:30am; Tallahassee) |
| Jun. 03, 1996 | (Respondent) Motion for Continuance received. |
| May 14, 1996 | (Respondent) Notice of Conflict and Dates of Unavailability received. |
| May 09, 1996 | Amended Notice of Hearing (as to date only) sent out. (Hearing set for 9/6/96; 9:30am; Tallahassee) |
| May 07, 1996 | Notice of Hearing sent out. (Hearing set for 8/19/96; 10:00am; Tallahassee) |
| Apr. 29, 1996 | (Petitioner) Response to Initial Order received. |
| Apr. 19, 1996 | (Petitioner) Response to Initial Order received. |
| Apr. 05, 1996 | Letter to Hearing Officer from L. Suess Re: Requesting 10 additional days to respond to Initial Order received. |
| Apr. 04, 1996 | (Respondent) Response to Initial Order received. |
| Mar. 27, 1996 | Initial Order issued. |
| Mar. 20, 1996 | Agency referral letter; Petition for Formal Hearing, Letter Form; Corrected Order of Intent to Approved With Conditions; Request for Hearing, Letter Form; Agency Action letter received. |
| Issue Date | Document | Summary |
|---|---|---|
| Mar. 03, 1997 | Recommended Order | Petitioner did not show the Federation Licensure exam (FLEX), which also applies to allopaths, was substantially equivalent to part 3 of National Board of Osteopathic Medical Examiners (NBOME) exam because FLEX did not test osteopathic principles. |
BOARD OF OSTEOPATHIC MEDICAL EXAMINERS vs. DAVID STURDIVANT, 96-001413 (1996)
BOARD OF OSTEOPATHIC MEDICAL EXAMINERS vs. LAWRENCE E. URBAN, 96-001413 (1996)
DEPARTMENT OF HEALTH, BOARD OF OSTEOPATHIC MEDICINE vs ROBERT RAYMOND REPPY, D.O., 96-001413 (1996)
BOARD OF OSTEOPATHIC MEDICAL EXAMINERS vs. JOEL Z. SPIKE, 96-001413 (1996)
BOARD OF OSTEOPATHIC MEDICAL EXAMINERS vs. DAVID L. STURDIVANT, 96-001413 (1996)
