ran oe 8) STATE OF FLoripa | $= P DEPARTMENT OF HEALT#y \g Pt 34 DEPARTMENT OF HEALTH, pis “VE. BOARD OF CLINICAL non nek a LABORATORY PERSONNEL, RUTH ARI Petitioner, vs. CASE NO. JC 2000-01755 SYED ATIQ AHSON, , Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, Department of Health, Board of Clinical Laboratory Personnel, and files this Administrative Complaint before the Board of Clinical Laboratory Personnel, against the Respondent, SYED ATIQ AHSON, and in support thereof would state: 1. Petitioner is the state agency charged with regulating the practice of Clinical Laboratory Personnel, pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 483, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration, hereinafter teferred to as the "Agency," to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. _ Respondent has been at all times pertinent hereto, a duly licensed Supervisor in the fields of Microbiology, Serology and Hematology, pursuant to Chapter 483, Florida Statutes, having been issued license number 649. | 4. Respondent's last known address is 900 North Robert Avenue, Arcadia, FL 34266. 5. From approximately 1997 to the present, SYED ATIQ AHSON has portrayed himself and practiced as a Laboratory Director at DeSoto Memorial Hospital, including but not limited to: using the title “Laboratory Director,” and “Clinical Laboratory Director,” assuming responsibility for the overall operation and administration of the clinical laboratory, assuring compliance with applicable state and federal laws, rules and regulations, drafting, reviewing and approving quality assurance policies and procedures, hiring and supervision of laboratory staff, and evaluating, purchasing and upgrading laboratory equipment and computer systems. AHSON does not have a license to practice as a Laboratory Director. AHSON does not possess the required qualifications to practice as a Laboratory Director. 6. From approximately 1994 to the present, AHSON directed and supervised the immunohematology section of DeSoto Memorial Hospital, including but not limited to, drafting, reviewing, and approving quality assurance policies and procedures for those sections. AHSON is not licensed to practice in the specialty of immunohematology. 7. By this conduct, Respondent is subject to disciplinary action, for violation of Section 483.825(2), Florida Statutes, by engaging in a clinical laboratory procedure or category of procedures not authorized pursuant to his license, Section 483.825(9) for knowingly advertising false services or credentials, and Section 483.825(19), Florida Statutes, by practicing beyond the scope permitted by law or rule, or accepting or performing professional services or responsibilities which the licensee knows or has reason to know that he or she is not competent to perform. . WHEREFORE, Petitioner respectfully requests the Board of Clinical Laboratory Personnel to enter an Order imposing one or more of the penalties proscribed by law, together with any other and further relief deemed just under the circumstances. SIGNED this (bay ol thal , 2000. Robert G. Brooks, M.D. Segyetary, Department of Health By: Nancy M. Snurkow. Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: © Yd eid & Herman oeoah ED enior Attorney ~ HEALTH Ba Bar No. 0113956 DEPUTY CLERK Agency for Health Care Administration CLERK Uehi R. 4 Gaon General Counsel's Office - MQA. Allied Health ° pare__ 5.3 2-Aoee P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-9670 CLE. hare & Donale Dok 7[27 } 0d

Docket for Case No: 00-004243PL