ro rm emt te Mi Bid " STATE OF FLORIDA DEPARTMENT OF HEALTH /. DEPARTMENT OF HEALTH, “ PETITIONER, OLW77 vs. a CASE NUMBER: 98-17378 STEPHEN O. AYENI, RESPONDENT. fy ~ ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Pharmacy against STEPHEN O. AYENI, hereinafter referred to as “Respondent,” and alleges: 1. Effective J uly 1, 1997, Petitioner is the state agency charged with regulating the practice of pharmacy pursuant to Section 20.43, Florida Statutes ; Chapter 455, Florida Statutes: and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20. 43 3), Florida Statutes, the Petitioner has contracted | with the Agency of Health Care “Administration to + provide consumer complaint, investigative, and prosecutorial s services ss iequired by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2 Respondent i is, ‘and has been at tall ti times material hereto, a a licensed Pharmacist f Florida, having been issued license number PS 0023591. Respondent’s last known address is 3705 Winners Court, Gotha, Florida 34734. : participation i in such continuing e education, 3. On or about July 15, 1998, a complaint was received alleging that Respondent had failed to comply with the requirements of Continuing Professional ~ Education for the calendar years 1995 and 1996. COUNTI 5. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 6. Based on the foregoing, Respondent is subject to discipline pursuant to Section 465.016(1)(n), Florida Statutes by violating Rule 64B16-26.103, Florida Administrative Code, for failing to submit proof satisfactory to the Board that during each year - of the biennial period that he has participated in not less than fifteen (15) hours of approved courses of continued professional pharmaceutical education for a total of not less than thirty (30) hours in the biennial period preceding the renewal period. | COUNT II : ‘ 7. Petitioner realleges and incorporates by reference the allegations of fact _ contained in the foregoing paragraphs as if fully stated herein. 8. Based on the foregoing, Respondent is subject to discipline pursuant to ‘Section 465 .016(1)(n), Florida Statutes by violating Rule 64B16-26.603, Florida Administrative Code, for failing to report programs of continuing professional education compliance during the applicable renewal period, and retaining documentation of “COUNT iia 9. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 10. Based on the foregoing, Respondent is subject to discipline pursuant to Section 465.016(1)(n), Florida Statutes, by violating Rule 64B16-26.606, Florida Administrative Code, for failing to submit proof in the form of certification to the Board the completion of not less than fifteen (15) hours per year of continuing professional education. “ WHEREFORE, Petitioner respectfully requests the Board of Pharmacy enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an 7 administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. ogee rages iM Le) SIGNED this! 4+Anaay of Mit