STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, VS. CASE NUMBER: 2001-05099 WILLIAM GLOVER, III, D.M.D. 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, WILLLAM GLOVER, Ul, D.M.D., referred to as "Respondent", and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of Dentistry pursuant to Section 20.43, Florida Statutes, Chapter 456, Florida Statutes, (formerly Chapter 455, Part II; see Chapter 2000-160, Laws of Florida), and Chapter 466, Florida Statutes. Pursuant to Section 20.43(3)(g), Florida Statutes, the Department 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 11757. Respondent's last known address is 1320 S. Orlando Avenue, Suites 1 & 2, Winter Park, Florida 32789. 3. On or about November 6, 2000, Patient O.W. a minor, presented to the Respondent for a new patient examination and cleaning. 4. The Respondent's dental records for Patient O.W. on or about November 6, 2000, included a treatment plan that listed the following treatment: a child prophylaxis, an occlusal filling on tooth number A, an occlusal filling on tooth number J, and sealants on teeth numbers nineteen and thirty. 5. The Respondent's dental records on or about November 6, 2000, for Patient O.W. do not include a written consent form from the Complainant, Patient O.W.'s mother, for the aforementioned treatment. 6. The Respondent's billing statement on or about November 6, 2000, for Patient O.W. included the following services: a comprehensive oral evaluation, a child prophylaxis, a one- surface posterior resin on tooth number A, a one-surface posterior resin on tooth number J, a topical application of fluoride, a sealant on tooth number nineteen, and a sealant on tooth number thirty. The billing statement for the aforementioned services totaled one hundred seventy-six dollars ($176.00). 7. The Respondent's dental records for Patient O.W. included a copy of a charge to the Complainant's Visa card on November 6, 2000, paid to the Respondent in the amount of one hundred seventy-six dollars. 8. On or about Apri] 2, 2001, Patient O.W. presented to a subsequent treater for an oral evaluation. 9. The subsequent treater evaluated Patient O.W.'s mouth and determined that there was a small occlusal composite in tooth number A and that there was no filling in tooth number J. The subsequent treater further determined that Patient O.W.'s teeth numbers nineteen and thirty had not erupted yet. 10. On or about April 11, 2001, Patient O.W. presented to a second subsequent treater for an oral evaluation. 11. The second subsequent treater examined Patient O.W.'s mouth, took bitewing tadiographs, and a photo of Patient O.W.'s mouth. The second subsequent treater determined that tooth number A had a small filling, that there were no fillings in any other teeth, and that teeth numbers nineteen and thirty had not had sealants placed because tecth numbers nineteen and thirty had not erupted yet. 12. On or about May 3, 2001, the Respondent made a swom statement that on or about November 6, 2000, he had placed occlusal fillings in Patient O.W.'s teeth numbers I and J, and that he had placed sealants on Patient O.W.'s teeth numbers nineteen and thirty. 13. On or about October 17, 2001, Patient O.W. presented to an agency expert for an examination. The agency expert examined Patient O.W., reviewed the Respondent's dental records for Patient O.W., and detennined the following: 1) Patient O.W.'s teeth numbers nineteen and thirty had not erupted therefore, making it impossible for the Respondent to have placed sealants on them; 2) Patient O.W.'s tooth number A had a small composite filling on the occlusal side; 3) Patient O.W.'s tooth number J appeared to have had a small amount of preparation for a filling, however no filling was present; 4) Patient O.W.'s tooth number I did not have a filling or show any evidence of preparation for a filling: and 5) The Respondent's dental records for Patient O.W, did not contain a written consent for fillings or sealants to be performed. 14. The agency expert opined that the Respondent violated Florida Statutes by charging the Complainant for services he did not perform and by not obtaining a written consent for the services from the Complainant. COUNT I 15, Petitioner realleges and incorporates by reference the foregoing allegations as if fully stated herein. 16. 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) (1), Florida Statutes (2000), for fraud, deceit, or misconduct in the practice of dentistry. COUNT II 17. Petitioner realleges and incorporates by reference fully the allegations contained in paragraphs one (1) through fourteen (14), 18. 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) (0), Florida Statutes (2000), for performing professional services, which have not been duly authorized by the patient or client, or her or his legal representative, except as provided in ss. 766.103 and 768.13. 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 and costs, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. , 20M. SIGNED this!“ day of _ ae UX. 4 John Agwunobi, M.D. Secretary, Department of Health BY: Nancy M. Snurkowski C Chief Attorney Agency for Health Care Administration COUNSEL FOR AGENCY Alan Jackson Florida Bar Applicant Agency for Health Care DEPARTMENT OF HEALT+ DEPUTY CLERIC Administration Practitioner Regulation P.O. Box 14229, mail stop 39 CLERK Pads Znon 32317- 4229 Ueki R 4 e pate, 2. | 2S foe Supervising Attorney © po = imal Alctt mS Oo nmo< PCP: FG /we/GE Sm aan A om —~ 2 we DATE: &/7/d 2 William Glover, DN Case number: 01-05099 Date: Novernber 15, 2001 5

Docket for Case No: 02-001946PL