May 4 2005 16:25 MAY-@4-2885 16:37 AHCA _ P.B3 oo STATE OF FLORIDA DEPARTMENT OF HEALTH O5-jol ote DEPARTMENT OF HEALTH, '. - PETITIONER, v. CASE NO. 2002-31136 IQBAL AHMED, M.D., RESPONDENT. | ADMINISTRAT. COMP T COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Medicine against Respondent, Iqbal Ahmed, M.D., and in support thereof alleges: | 1. Petitioner is the state department charged with regulating the practice of Medicine pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 458, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed physician within the state of Florida and was issued license - number ME 71118. 3. On or about April 15, 2000, Respondent was employed as a May 4 2005 16:26 MAY-@4-2485 16:37 AHCA P.a4 om _~ physician at Highlands Regional Medical Center (Highlands Regional) in Sebring, Florida. | 4. On‘or about April 15, 2000, Respondent had oversight responsibility for Melody M. McSorley, PA, a Physician’s Assistant at Highlands Regional with license number 3320. 5. Onor about April 15, 2000, Patient J.W., a fifty-nine (59) year- old female, presented to the Emergency Room at Highlands Regional Medical Center with nausea, vertigo, headache, neck pain and recent change in mental status. 6. On or about April 15, 2000, Patient J.W. was examined by Respondent and his physician’s assistant. 7. Onor about April 15, 2000, Respondent diagnosed Patient J.W. with right lower lobe pneumonia and labyrinthitis. Patient J.W. had a subarachnoid hemorrhage, however, which was not identified or treated. 8. Section 458.331(1)(t), Florida Statutes (2001), sets forth grounds for disciplinary action by the Board of Medicine and provides that a physician may be subject to discipline for gross or repeated malpractice or the failure to practice medicine with that level of care, skill, and 2 Iqbal Ahmed, M.D., Case # 2002-31136 May 4 2005 16:26 MAY-@4-2885 16:37 AHCA P.@5 oo rN treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances. . 9, Respondent failed to practice medicine with that level of care, skill, and treatment which is recognized by a reasonably prudent similar physician as being acceptable under similar conditions and circumstances, in one or more of the following ways: (a) Respondent failed to identify and record symptoms of cerebrovascular and neurologic abnormality in Patient J.W. (b) Respondent failed to recommend adequate diagnostic procedures such as CT scan, testing such as lumbar puncture, or to obtain a timely neurology consult to evaluate and treat the cause of Patient J.W.’s abnormal symptoms. WHEREFORE, Petitioner respectfully requests that the Board of Medicine enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent's license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the 3 Igbai Ahmed, M.D., Case # 2002-31136 May 4 2005 16:26 MAY-@4-2085 16:38 AHCA P.@6 o~ -_ Board deems appropriate. oe SIGNED this _Z/~_ day of —Leahsccimy = 2004. John O. Agwunobi, M.D., M.B.A., M.P.H. Secretary, Department of Health FILED bert E. Fricke *ORH1S7 2 DEPARTMENT OF HEALTH Assistant General Counsel DEPUTY CLERK Robert E. Fricke ouenK Nitta Colman Prosecution Services Unit DATE, 2-dt-os 4052 Bald Cypress Way ae BIN C-65 Tallahassee, Florida 32399-3265 Florida Bar # 0567027 Reviewed and approved by: wz (nis) dal (date) PCP:February 18, 2005 PCP Members:,,_ Bahri, Coto, Dyches 4 Iqbal Ahmed, M.D., Case # 2002-31136 May 4 2005 16:27 MAY-@4-20@85 16:38 AHCA P.Q@? oN rN NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on Notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. 3 Iqbal Ahmed, M.D., Case # 2002-31136

Docket for Case No: 05-001616PL