STATE OF FLORIDA DEPARTMENT OF HEALTH " * DEPARTMENT OF HEALTH, ) ) PETITIONER, ) ) OM. ) CASE NO, 1999-59377 - JACK LIPPES, M.D. ) OI-13NS 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 Medicine against Jack Lippes, M.D., hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes, and Chapter 458, Florida Statutes. Pursuant to the provisions of ; Section 20.43(3), 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 physician in the state of Florida, having been issued license number ME 0053402. Respondent's last known address is 31 Hampton Hill Drive, Williamsville, NY 14221. gens Te Peper esc gem oe a 3. On or about November 2, 1998, Respondent was notified by the Board that his application to renew his license for the 1998-2000 period was incomplete in that Section IV, regarding completion of required CME hours, was not filled out. 4, Rule 64B8-13. 001(1), Florida Administrative Code, requires the completion ; of all forms provided by the Department for renewal of license. 5. Rule 64B8-13.005(1), Florida Administrative Code, requires the completion, of forty (40) hours -of continuing medical education (hereinafter referred to as cme) courses approved by the Board for the twenty-four (24) months preceding each biennial renewal period as established by the Agency. As Respondent was seeking license renewal for the 1998-2000 biennium, Respondent needed to supply proof of completion of CME credits between February 1, 1996 and January 31, 1998. 6. On or about October 15, 1999, Respondent sent a response to the Board which documented that he attended meetings, made weekly rounds, and conducted 2 research, for which he claimed a total of fifty-two (52) CME hours. 7. The Respondent's submitted CME documentation was not approved or recognized by the Board of Medicine. Respondent has not provided a completed renewal form or proof of completion of any Board-approved CME courses. 8. Respondent failed to show completion of forty (40) CME credit hours for . _the February 1, 1996 through January 31, 1998 biennium as required by Rule 64B15- 13.001, Florida Administrative Code, and failed to fill out the renewal form as required by Rule 64B8-13.005(1), Florida Administrative Code. a 9. Based on the foregoing, Respondent is in violation of Section 458. 331(1)09), Florida Statutes, for violating any provision of this chapter, a rule of the board or department, ora lawful order of the board ¢ or r department Previous| entered i in + a disciplinary hearing or falling to comply with a ‘awfully issued subpoena of the department. | order imposing one or more of the following penalties: permanent revocation or - suspension of the’ Respondent's license, | restriction of the Respondent's practice, Respondent on probation, the assessment of costs related to the investigation and Prosecution of this case as provided for in Section 456.072(4), Florida Statutes, and/or - “any other relief that the Board deems appropriate. SIGNED this Ad cay of _{ ni \ wr , 2001. Robert G. Brooks, M.D., Secretary - DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Ueki R. kenen Nancy M. Snurkowski Chief Attorney, Practitioner Regulation — DATE BAESUPY __— : Y 9 WHEREFORE, the Petitioner respectfully requests the Board of Medicine enter an . imposition of an “administrative fine, issuance of a reprimand, placement” of the

Docket for Case No: 01-001845PL