STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, vs. CASE NUMBER: 1999-59917 PARKER W. SHAFFER, D.MLD., p 00-2147 PL RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as "Petitioner", and files this Administrative Complaint before the Board of Dentistry against PARKER W. SHAFFER, hereinafter referred to as "Respondent", and alleges: 1. Petitioner is the state agency charged with regulating the practice of dentistry pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 466, Florida Statutes. Pursuant to the authority of Section 20.43 (3) (g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, . councils, or boards, as appropriate. 2. ) Respondent is, and has been at all times material hereto, a licensed dentist in the State of Florida, having been issued license number: DN 0002995. Respondent's last known address is 1998 S. Kings Road, Callahan, Florida 32011. 3. From on or about January 14, 1999 through June 16, 1999, Patient J.G. presented to Respondent for dental treatment, including, but not limited to, dentures. 4. On or about January 14, 1999, Respondent took impressions for upper and lower dentures of Patient J.G. 5. On or about March 11, 1999, Respondent seated the upper and lower dentures of Patient J.G. | 6. From on or about January 14, 1999 through June 16, 1999, Respondent made several adjustments to the upper and lower dentures of Patient J.G. 7. Section 466.018(3), Florida Statutes, states that: “Every dentist shall maintain written dental records and medical history records which justify the course of treatment of the patient. The records shall include, but not be limited to, patient history, examination results, test results, and, if taken, x- rays.” 8. Respondent failed to keep written dental records for Patient J.G. by failing to document the initial clinical examination results. The dental chart for Patient J.G. did not contain the minimum results such as: a) — poor ridge forms; b) large tori; c) ill-fitting dentures with decreased vertical dimension; and ‘d) lack of posterior palatal coverage. 9. On or about October 20, 1999, Patient J.G. made a written request for her dental records. 10. Onor about October 26, 1999, Respondent’s office manager sent a written response to Patient J.G. stating “we are unable to release your file until balance is paid in full.” 11. Respondent failed to provide Patient J.G. with a copy of her dental records. COUNT I 12. Petitioner realleges and incorporates by reference the foregoing allegations as if fully stated herein. 13. __ Based on the foregoing, the Respondent’s license to practice dentistry in the State of Florida is subject to discipline pursuant to Section 466.028 (1)(m), Florida Statutes, for failing to keep written dental records and medical history records justifying the course of treatment of the patient including, but not limited to, patient histories, examination results, test results, and x-rays, if taken. COUNT H 14. Petitioner realleges and incorporates by reference the allegations contained in paragraphs one (1) through (). 15. Based on the foregoing, the Respondent’s license to practice dentistry in the State of Florida is subject to discipline pursuant to Section 466.028 (1)(n), Florida Statutes, for failing to make available to a patient or client, or to her or his legal representative or to the department if authorized in writing by the patient, copies of documents in the possession or under control of the licensee which relate to the patient or client. WHEREFORE, Petitioner respectfully requests the Board of Dentistry 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 administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this | Kucay of yl 1 , 2000. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy M. Snurko Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: ew R. Lynn Lovejoy Senior Attorney Agency for Health Care Administration DEPARTMENT OF HEALTE Post Office Box 14229, Mail Stop 39 Veh CLERK Tallahassee, Florida 32317-4229 CLERK WthiR. Leno (850) 488-8904 DATE 7 -/BT DO9o RLL/rvt PCP: Lpece Chinen , “feher DATE: July 7, 200d) Parker W. Shaffer, D.M.D. Case No. 1999-59917 June 12, 2000

Docket for Case No: 00-005147PL