STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION STATE OF FLORIDA, AGENCY FOR HEALTH CARE ADMINISTRATION, Ol SU { { Petitioner, vs. Case No. 2007008058 LAKESHORE SYSTEM SERVICES OF FLORIDA, INC. d/b/a HEALTHSOUTH EMERALD COAST REHABILITATION HOSPITAL, Respondent / ADMINISTRATIVE COMPLAINT Petitioner, the Florida Agency for Health Care Administration (“AHCA”), through undersigned counsel, files this Administrative Complaint against the above named Respondent (“Respondent”) pursuant to Sections 120.569 and 120.57, Florida Statutes (2004), and alleges: NATURE OF THE ACTION 1. This is an action to impose an administrative fine in the amount of $177,755 (the “Fine Amount’) against Respondent, per Sections 408.034 and 408.040, Florida Statutes and Florida Administrative Code Rules 59C-1.013 and 59C-1.021. 2, For the calendar year 2004 (the “Calendar Year”), Respondent failed to comply with the minimum of three point two percent (3.2%) of the total annual patient days in the 65- bed facility shall be provided to Medicaid patients and four point five percent (4.5%) of the 'Unless otherwise noted, all Statutes and rules hereinafter cited are to the indicated year’s version of the statute or rule, because this is the controlling year in question. Page 1 of 11 total annual patient days in the 65-bed facility shall be provided to charity care patients conditions upon its Certificate of Need (“CON”) (Exhibit “A”). JURISDICTION AND VENUE 3. This tribunal has jurisdiction over Respondent, pursuant to Sections 120.569 and 120.57, Florida Statutes, and also Sections 408.031-408.45, Florida’s “Health Facility and Services Development Act.” 4, Venue is determined by Florida Administrative Code Rule 28-106.207. PARTIES 5. Pursuant to Chapter 408, Florida Statutes, and Chapter 59C-1, Florida Administrative Code, AHCA is the licensing and enforcing authority with regard to a comprehensive medical rehabilitation facility laws and rules. 6. Respondent is a corporation authorized under the laws of Florida to do business. Respondent operates a comprehensive medical rehabilitation hospital located at 1847 Florida Avenue, Panama City, Florida 32405, and is the licensee on the CON issued on January 21, 2000, to add five (5S) comprehensive medical rehabilitation beds to the existing 60-bed freestanding comprehensive medical rehabilitation hospital in Bay County with the conditions that a minimum of three point two percent (3.2%) of the total annual patient days in the 65-bed facility shall be provided to Medicaid patients and four point five percent (4.5%) of the total annual patient days in the 65-bed facility shall be provided to charity care patients. The certificate number is CON #9221, a copy which is attached to this Complaint as Exhibit “A”. COUNT I (Respondent Failed to Meet Its Minimum Medicaid and Charity Care Patient Conditions) Section 408.040, Florida Statutes Rule 59C-1.013, Florida Administrative Code Rule 59C-1.021, Florida Administrative Code Page 2 of 11 7. AHCA re-alleges and incorporates by reference paragraphs one (1) through six (6) above. 8. Respondent filed an annual compliance report, which reflected that the facility did not comply with the Minimum Medicaid and Charity Care Patient Conditions for the Calendar Year 2004 (Exhibit ‘B’’), based on the following findings: The facility report indicated that the facility provided two point thirty-nine percent (2.39%) of its total annual patient days to Medicaid and one point fifty-five percent (1.55%) of its total annual patient days to Charity Care Patients. 9. Respondent failed to comply with the conditions set forth in its CON, as required by Sections 408.034 and 408.040, Florida Statutes; and Rule 59C-1.013, Florida Administrative Code which provide in part as follows: 408.040 Conditions and monitoring (1)(a) The agency may issue a certificate of need predicated upon statements of intent expressed by an applicant in-the application for a certificate of need. Any conditions imposed on a certificate of need based on such statements of intent shall be stated on the face of the certificate of need. (b) The agency may consider, in addition to the other criteria specified in s. 408.035, a statement of intent by the applicant that a specified percentage of the annual patient days at the facility will be utilized by patients eligible for care under Title XIX of the Social Security Act. Any certificate of need issued to a nursing home in reliance upon an applicant's statements that a specified percentage of annual patient days will be utilized by residents eligible for care under Title XIX of the Social Security Act must include a statement that such certification is a condition of issuance of the certificate of need. The certificate-of-need program Page 3 of 11 shall notify the Medicaid program office and the Department of Elderly Affairs when it imposes conditions as authorized in this paragraph in an area in which a community diversion pilot project is implemented. (c) A certificate holder may apply to the agency for a modification of conditions imposed under paragraph (a) or paragraph (b). If the holder of a certificate of need demonstrates good cause why the certificate should be modified, the agency shall reissue the certificate of need with such modifications as may be appropriate. The agency shall by rule define the factors constituting good cause for modification. (d) If the holder of a certificate of need fails to comply with a condition upon which the issuance of the certificate was predicated, the agency may assess an administrative fine against the certificate holder in an amount not to exceed $1,000 per failure per day. In assessing the penalty, the agency shall take into account as mitigation the degree of noncompliance. RRR 59C-1.013 Monitoring Procedures (4) Reporting Requirements Subsequent to Licensure or Commencement of Services. All holders of a certificate of need that was issued predicated upon conditions expressed on the face of the certificate of need shall provide annual compliance reports to the agency. The reporting period shall be January 1 through December 31 of each year. The holder of a certificate of need who began operation after January 1 will report from the date operation began through December 31. The compliance report shall be submitted no later than April 1 of the subsequent year. (a) The compliance report will contain information necessary for an assessment of compliance with conditions on the certificate of need, utilizing measures, such as Page 4 of 11 a percentage of patient days, that are consistent with the stated condition. The following information shall be provided in the holder’s annual compliance report: 1. The time period covered by the measures; 2. The measure for assessing compliance with each of the conditions identified and described on the face of the certificate of need; 3. The way in which the conditions were evaluated by applying the measures; 4. The data sources used to generate information about the conditions that were measured; 5. The person and position responsible for supplying the compliance report; 6. Any other information necessary for the agency to determine compliance with conditions; and 7. If applicable, the reason or reasons, with supporting data, why the certificate of need holder was unable to meet the conditions set forth on the face of the certificate of need. (b) A change in the licensee for a facility or service does not affect the obligation for that facility or service to continue to meet conditions imposed on a certificate of need and to provide annual condition compliance reports. (c) Conditions imposed on a certificate of need may be modified consistent with Rule 59C-1.019, F.A.C. (5) Violation of Certificate of Need Conditions. Health care providers found by the agency to be in noncompliance with conditions set forth in their certificate of need shall be fined as defined in Rule 59C-1.021, F.A.C. 10. The foregoing violation warrants imposition of the above-mentioned Fine Amount pursuant to Rule 59C-1.021, Florida Administrative Code which provides in part: 59C-1.021 Penalties. Page 5 of 11 (1) General Provisions. The agency shall initiate administrative proceedings for revocation of a certificate of need for violation of paragraphs 408.040(2)(a) and (b), F.S., or the assessment of administrative fines for failure to comply with conditions placed on a certificate of need as specified under Rule 59C-1.013, F.A.C. eR (3) Penaltiés for Failure to Comply with Certificate of Need Conditions. The agency shall review the annual compliance report submitted by the health care providers who are licensed and operate the facilities or services and other pertinent data to assess compliance with certificate of need conditions. Providers who are not in compliance with certificate of need conditions shall be fined. For community nursing homes or hospital-based skilled nursing units certified as such by Medicare, the first compliance report on the status of conditions must be submitted 30 calendar days following the eighteenth month of operation or the first month where an 85 percent occupancy is achieved, whichever comes first. The schedule of fines is as follows: (a) Facilities failing to comply with any conditions set forth on the Certificate of Need will be assessed a fine, not to exceed $1,000 per failure per day. In assessing the penalty the agency shall take into account the degree of noncompliance. (b) The assessed fine shall be paid to the agency within 45 calendar days after written notification of assessment by certified mail or within 30 calendar days after final agency action if an administrative hearing has been requested. If a health care provider desires it may remit payment according to a payment schedule accepted by the agency. The health care provider must submit the schedule of payments to the agency within 30 calendar days after the date of receipt of the notification of © Page 6 of 11 assessment or 21] calendar days after final agency action. The final balance will be due no later than 6 months after the health care provider has been notified in writing by the agency of the amount of the assessed fine or 6 months after final agency action. 11. AHCA, in determining the penalty imposed, considered the degree of non- compliance by the Respondent. WHEREFORE, AHCA demands the following relief (1) enter factual and legal findings as set forth in this Count; (2) impose the above-mentioned Fine Amount for the violation; and (3) impose such other relief as this tribunal may find appropriate. NOTICE RESPONDENT is hereby notified that it has a right to request an administrative hearing pursuant to Section 120.569, Florida Statutes. Specific options for administrative action are set out in the attached Election of Rights (one page) and explained in the attached Explanation of Rights (one page). All requests for hearing shall be made to the Agency for Health Care Administration, and delivered to the Agency for Health Care Administration, 2727 Mahan Dr., Bldg. 3, MS #3, Tallahassee, Florida, 32308; Attention: Agency Clerk. RESPONDENT IS FURTHER NOTIFIED, IF THE REQUEST FOR HEARING IS NOT RECEIVED BY THE AGENCY FOR HEALTH CARE ADMINISTRATION WITHIN TWENTY-ONE (21) DAYS OF RECEIPT OF THIS ADMINISTRATIVE COMPLAINT, A FINAL ORDER WILL BE ENTERED. - Submitted as of the date indicated on the below Certificate of Service. on Baalixs fae Senior Attorney Fla. Bar No. 0355712 Agency for Health Care Administration 2295 Victoria Avenue, Room 356C Fort Myers, Florida 33901 Phone: (239) 338-3209 Facsimile: (239) 338-2699 Page 7 of 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the original Administrative Complaint, Explanation of Rights form, and Election of Rights form have been sent by U.S. Certified Mail, Return Receipt Requested (receipt #7006 2150 0004 5871 1122) to Respondent, Lakeshore System Services of Florida, Inc., d/b/a HealthSouth Emerald Coast Rehabilitation Hospital, Attention: Administrator, 1847 Florida Avenue, Panama City, Florida 32405; Registered Agent, CT Corporation System, 1200 S. Pine Island Road, Plantation, Florida 33324 (receipt #7006 2150 0004 5871 0859), and Deborah S. Platz, Attorney for Respondent, Panza, Maurer and Maynard, P.A., 3600 North Federal Highway, Bank of America Building, Third Floor, Fort Lauderdale, Florida 33308 (receipt #7006 2150 0004 5871 1115) this gg@@,day of , 2007. 4 Alay Jace Senior Attorney Mary Daley Jacobs Senior Attorney Agency for Health Care Administration 2295 Victoria Avenue, Room 346C Fort Myers, Florida 33901 (nteroffice Mail) Copies furnished to: Administrator Lakeshore System Services of Florida, Inc. d/b/a HealthSouth Emerald Coast Rehabilitation Hospital 1847 Florida Avenue Panama City, Florida 32405 Certified U.S. Mail Registered Agent CT Corporation System 1200 S. Pine Island Road Plantation, Florida 33324 (Certified U.S. Mail) James McLemore Unit Manager Certificate of Need Agency for Health Care Administration 2727 Mahan Drive, Bldg #1, MS #28 Tallahassee, Florida 32308 (Interoffice Mail) Deborah S. Platz Attorney for Respondent Panza, Maurer and Maynard, P.A. 3600 N. Federal Highway Bank of America Building, Third Floor Fort Lauderdale, Florida 33308 (Certified U.S. Mail) Page 8 of 11 EXPLANATION OF RIGHTS UNDER SECTION 120.569, FLORIDA STATUTES (To be used with the attached Election of Rights form) In response to the allegations set forth in the Administrative Complaint issued by the Agency for Health Care Administration (“AHCA” or “Agency”), Respondent must make one of the following elections within twenty-one (21) days from the date of receipt of the Administrative Complaint and your Election of Rights in this matter must be received by AHCA within twenty-one (21) days from the date you receive the Administrative Complaint. Please make your election on the attached Election of Rights form and return it fully executed to the address listed on the form. QPTION.1. If Respondent does not dispute the allegations in the Administrative Complaint and Respondent elects to waive the right to be heard, Respondent should select OPTION 1 on the election of rights form. A final order will be entered finding you guilty of the violations charged and imposing the penalty sought in the Complaint. You will be provided a copy of the final order. OPTION 2. If Respondent does not dispute any material fact alleged in the Administrative Complaint (Respondent admits all the material facts alleged in the Complaint.), Respondent may request an informal hearing pursuant to Section 120.57(2), Florida Statutes before the Agency. At the informal hearing, Respondent will be given an opportunity to present both written and oral evidence to reduce the penalty being imposed for the violations set out in the Complaint. For an informal hearing, Respondent should select OPTION 2 on the Election of Rights form. OPTION 3. If the Respondent disputes the allegations set forth in the Administrative Complaint (you do not admit them) you may request a formal hearing pursuant to Section 120.57(1), Florida Statutes. To obtain a formal hearing, Respondent should select OPTION 3 on the Election of Rights form. In order to obtain a formal proceeding before the Division of Administrative Hearings under Section 120.57(1), F.S., Respondent’s request for an administrative hearing must conform to the requirements in Section 28-106.201, Florida Administrative Code (F.A.C), and must state the material facts disputed. IF YOU SELECT OPT. 3, CAREFULLY READ THE FOLLOWING PARAGRAPH: In order to preserve the right to a hearing, Respondent’s Election of Rights in this matter must be RECEIVED by AHCA within 21 days from the date Respondent receives the Administrative Complaint. If the election form with Respondent’s selected option is not received by AHCA within 21 days from the date of Respondent’s receipt of the Administrative Complaint, a final order will be issued finding the deficiencies and/or violations charged and imposing the penalty sought in the Complaint. Page 9 of 11 STATE OF FLORIDA AGENCY FOR HEALTH CARE ADMINISTRATION RE: HealthSouth Emerald Coast Rehabilitation Hospital . Case No. 2007008058 ELECTION OF RIGHTS FOR ADMINISTRATIVE HEARING PLEASE SELECT ONLY 1 OF THE 3 OPTIONS (An Explanation of Rights form is attached) OPTION _ONE (1) oc Respondent does not dispute the allegations of fact contained in the Administrative Complaint and waives Respondent’s right to object or to be heard. Respondent understands that by waiving Respondent’s rights, a final order will be issued that adopts the Administrative Complaint and imposes the sanctions sought. OPTION TWO (2) 5 Respondent does not dispute and Respondent admits the allegations of fact in the Administrative Complaint, but Respondent does wish to be afforded an informal proceeding, pursuant to Section 120.57(2), Florida Statutes, at which time Respondent will be permitted to submit oral and/or written evidence to the Agency in mitigation of the penalty imposed. OPTION THREE (3) co Respondent does dispute the allegations of fact contained in the Complaint and Respondent requests a formal hearing, pursuant to Section 120.57(1), Florida Statutes, before an Administrative Law Judge appointed by the Division of Administrative Hearings (“DOAH”). If Respondent chooses OPTION (3), in order to obtain a formal proceeding before the DOAH under Section 120.57(1), Florida Statutes, Respondent’s request for a hearing must conform to the requirements in Section 28-106.201, Florida Administrative Code (F.A.C), and must state the material facts you dispute. If you select Option 3, mediation may be available in this case pursuant to Section 120.573, Florida Statutes, if the Agency agrees to it. In order to preserve Respondent’s right to a hearing, Respondent’s Election of Rights in this matter must be received by AHCA within twenty-one (21) days from the date Respondent receives the Administrative Complaint. If the election of rights form with Respondent’s selected option is not received by AHCA within twenty-one (21) days from the date of the Respondent’s receipt of the Administrative Complaint, a final order will be issued finding the deficiencies and/or violations charged and imposing the penalty sought in the Complaint. If Respondent has elected either OPTION (2) or THREE (3) above and if Respondent is interested in discussing a settlement of this matter with the Agency, please also mark and check this block. o Mediation under Section 120.573, Florida Statutes, is not available in this matter. SEND NO PAYMENT NOW -- REGARDLESS OF THE OPTION SELECTED, PLEASE WAIT UNTIL RESPONDENT RECEIVES A COPY OF A FINAL ORDER FOR INSTRUCTIONS ON PAYMENT OF ANY FINES. (Please sign and fill in your current address.) Respondent (Licensee) Address: License. No. and facility type: Phone No. PLEASE RETURN YOUR COMPLETED FORM TO: Agency for Health Care Administration, Office of the General Counsel, Attention: Agency Clerk, 2727 Mahan Drive, Building 3, Mail Stop #3, Tallahassee, Florida 32308. Telephone Number: 850-921-8177; FAX 850-921-0158; TDD 1-800-955- 8771. Page 10 of 11 EXHIBITS (AHCA v. Lakeshore System Services of Florida, Inc. d/b/a HealthSouth Emerald Coast Rehabilitation Hospital, Case No. 2007008058) EXHIBIT “A” — Respondent’s CON #9221 requiring that a minimum of three point two percent (3.2%) of the total annual patient days in the 65-bed facility shall be provided to Medicaid patients and four point five percent (4.5%) of the total annual patient days in the 65-bed facility be provided to charity care patients. EXHIBIT “B” —- Respondent’s Annual Compliance Report for Year 2004. (All are copies.) Page 11 of 11 PAGE @3 STATE OF FLORIDA _ AGENCY FOR HEALTH CARE ADMINISTRATION . CERTIFICATE OF NEED | Under-the provisions of the “Health Facility and Services Development Act" (Sections ; 408,034-.045, Florida Statutes (Supp 1992), AND Chapter 58C-1, Florida Administrative Code), the Abency for Health Care Administration certifies the need far this project “ ‘ NUMBER: 9221 APPLICANT: : , . : : ; .. Lakeshore System Services of Florida, loc, ' PROJECT COST:_$255,535 : dibla HEALTHSOUTH Emerald Coast Rehabilitation Hospital . ISSUE DATE:_January 21, 2000 HealthSouth Corporation : TERMINATION DATE:__July 20, 2004 One HealthSouth Parkway : REVISED TERMINATION DATE: : Birmingham, Alabama. 35243 COUNTY: Bay | - DISTRICT: . 2 —._—_- SUBDISTRICT: PROJECT DESCRIPTION: Add five comprehensive medical rehabilitation (CMR)-beds to the 60 existing CMR beds at ' HEALTHSOUTH Emerald Coast Rehabilitation Hospital. The project involves 2,688 GSF of renovation and construction © costs ‘of $128,520. . . . -6964 CONDITIONS: (1) A minimurnof 3.2 percent of the total patient days in the 65-bed facility shal! be provided to Medicaid ~ recipients; and (2) A minimum of 4.5 percent of the total patient days in the 65-bed facility shall be provided to charity. ~ care. , : a : . - oo Do, 850-922 FORM 1793, APRIL 1993 " 18/22/2887 68:63 93/21/2007 13:84 858-322-6364 CON PAGE LZ HE Caast THSOUTH September 21, 2005 ECEIVE SEP 26 2008 Con/Financiat Analysis Office James B. McLemore x. MailStop28 Agency for Health Care Administration 2727 Mahan Drive Mail Stop #28 Tallahassee, Florida 32308 RE: HEALTHSOUTH Emerald Coast Rehabilitation Hospital CON 8999, 9221, 9598 Conditions: Minimum of 3.2% of the total patient days shall be provided to Medicaid patients and a minimum of 4.5% of the total patient days shall be provided to charity patients, and an 8 Bed Brain & Spinal Cord program shal]: be maintained. ° Dear Mr. McLemore: Pursuant to Subsection 59c-1.013 (4)(d), Florida Administrative Code, this letter represents the condition compliance report for the referenced certificate of need: 1. Time period covered by the measure. January 1, 2004 through December 31, 2004 2. Measure for assessing compliance of, the condition identified and described. . Total patient days: 19,939 3. Way in which the conditions were evaluated by applying the measure. 477 Medicaid Patient Days / 19,939 Total Patient Days = 2.39% 477 Medicaid Patient Days / 2,744 Non-Medicare Patient Days = 17.38% 310 Charity Patient Days / 19,939 Total Patient Days = 1.55% 310 Charity Patient Days / 2,744 Non-Medicare Patient Days = 11.30% 4. Actual data sources used to generate the information on the condition to . be measured. The actual data sources used were the Fiscal year erded December 31, 2004 Patient Accounting System Census Reports and Account details. Bey ? EXHIBIT i) 1847 Florida Avenue * Panama City, FL 22405 - 850 914-8632 - Fax 850 914-8788 89/21/2887 13:84 859-922-6964 CON PAE ” \HEALTHSOUTH Emerald Coast Rehabilitation Hospital 5. The source of the data for the measure. The sources of the data were the Fiscal year ended December 31, 2004 Patient Accounting Systems Census Reports and Account details from the Patient Accounting System. 6. Reasonableness of the measures and confidence in measures. The measure used to calculate compliance with the CON conditions is the generally accepted approach to measuring a percentage of patient days attributable to specific payors. We are confident in the data reported because it ties to the Hospital’s billing records and general ledger totals. 7. Person and position responsible for defining measures and supplying compliance report. Angela Whitehurst, Accounting Manager Tony Bennett, CEO 8. Any information necessary to determine compliance with the condition. At HealthSouth Emerald Coast Rehabilitation Hospital, there is a full, good faith effort to comply with all CON requirements. It is our policy to accept any patients who are medically appropriate for rehabilitation, when open beds are available. This policy is applied regardless of the patient’s financial coverage or the ability to pay. 9, Reasons, with supporting data, why the, certificate of need holder was unable to meet the conditions set forth on the face of the certificate of need. As a specialty designated rehabilitation hospital, at HealthSouth, we are licensed to treat specific clinical criteria for admission (in addition té diagnostic requirements). These clinical criteria in¢lude: appropriateness of admission and ability to progress, benefit in/from rehabilitation services, and established disposition upon discharge. These criteria apply to all payor types, including Medicaid and indigent. During 2004, 32 defined charity referrals resulted in 20 charity admissions. Of the 12 potential charity patients who were not admitted: o 4 refused admission and chose to go an alternate rehabilitation facility, to a skilled nursing facility, or to go home with home health or outpatient services o 1 died © 5 were inappropriate for admission based bn requirements for a licensed tehabilitation facility 1847 Florida Avenue + Panama City, FL 32408 - 850 914.8632 + Fax 850 914-9788 2 : Q9/21/2087 13:44 Bob-g2e-b'sbd {LIM ral 14 HEALTHSOUTH Emerald Coast Rehabilitation Hospital © 2 cases were during times when the hospital had 100% census, and therefore had not beds available. Referral was no longer valid when beds became available. None were turned away due to their lack of funding or their inability to pay. During 2004, 62 defined Medicaid referrals resulted.in 36 Medicaid admissions. Of the 26 potential Medicaid patients who were not admitted: © 12tefused admission and chose to go to am alternate rehabilitation facility, to a skilled nursing facility, or to go home with home health or outpatient services © 9 were inappropriate for admission based on requirements for a licensed rehabilitation facility. © 5 were denied a precertification by the Medicaid program. The patient days and referrals listed above are for Non-Medicare patients. While many Medicare patients may have Medicaid or be considered indigent, they are only considered as Medicare for our calculations. Medicare patient days made up 86% of the total patient days at this facility for 2004. From the remaining 14% of total patient days, 17.38% were Medicaid and 11.3% were charity; both exceeding the requirements when considering only Non-Medicare patients. Consistent with the Florida Administrative Code, section 59C-1.013(3) c, we believe we have complied in good faith, as best as the market can deliver, compliance with the Medicaid and charity care patient days available and as presented to our hospital. Our internal calculations clearly demonstrate good faith efforts in accepting all indigent and Medicaid patients referred and who have met criteria and who accepted and agreed to come to this facility. HEALTHSOUTH Emerald Coast Rehabilitation Hospital will continue to serve all patient populations and strive to meet or exceed the CON requirements. If further information is required, please feel free to contact me at (850) 914-8603. Thank you. Sincerely, Ong whe. L fits wt Angela Whitehurst Accounting Manager and Authorized Representative of CON Holder and Licensee HEALTHSOUTH Emerald Coast Rehabilitation Hospital 184? Florida Avenue + Panama City, FL 32405 + 830 914-3632 - Fax 850 914-8788 3 1s PAGE CON 858-322-6364 784 13 89/21/2087 a veISVLO pbivhird asp} test) Sp/SO/LO WelKL CSfOit Sb/S EO OS/EO/EO 9S/EOEO ISITOILO SoIPTED 08/6040 6L/5 1/60 TOEO/RO 64/61/50 ssironl SSIOTIEO 194110 PRITEION SITET Epil bRreso 65/60/F) ES/8 CO R9/6U/10 LPIST/OL SHIGEO SbISIIZI PSTAD Ib/Psily lasoit LO9TI0 L990 SSIOTITE sot) REPLIGI SOZESE1 CS6ISSL SRr6S6l ZOOBSEL STEL96T OEETS6) RETF) 6UL8S61 ChORSEl {9Stsol tLOT96) 66F0561 SOTLSel TILI961 196161 SHLISEL RSSSS6t OE9EVER SO9LS61 B6S9S5) SFG S61 W8sisel SLCISES LEGLSON L7Z1S61 TINAIGT CS PeSOl (CSS FTPT 9G) BOPOSGE 9697561 66P196T OZMIDEL 9006961 610861 aUON (sig ‘sheg Supyeaey On) GIVOIGAW OSV GETId LON AUWINId Ct¥IIGIW OStZ-Ot OSLZ-Ol OSLZ-O4 QSLeT-Ol QSLT-Ol QStz-O1 OSLZ-O1 ASLE-O1 OSLT-O1 OSLZ-O1 OSLe-OL OSL7-01 OSLZ-O1 OSLZ-OL OSLE-OL ASLT-OL OSET-OF OSLT-OF OSLT-OF OSLT-O1 Osct-ot (set-Or Qséz-ol OSL7-01 asee-ol Oséz-Ol OSL7-O1 Osce-ol Qsez-O} OSe7-0} OSL7-01 OSLT701 OSL7OI Oséen1 Osi7O1 Osten EEEEREES Peeereeieitedet ere ee eee eee Er Pm GTVLOL Dd LS09 NO GIVOIGSW §¢ Pepn}Pe)) CIYDIGIW OLSV GaTTd AWWA WVOIOINW SHYSIGIW NO AIVINTAW OL CATIA LON - FTSAISITE AIVOIGT i” LPOOCPEPRL d yOOTRIZI bUOTIOT 1% 9708969941 d POOZEVS POOUEZIL Ot SESTOSHISL d pOOTIEEIT PONZIOE/T 6 LBCLEBOTIR a pOoUcEs = PONIES fl COISELDYBE d pOOUMEL «= PONTE bt 16RILEZTS d pooweETt = pUOZIT IZA t ORZPURBILE a POOTIR/E po0z LE ol C8ZOGHETITZ d S00 ET PONTE TTI 8 OOS PIZOS d wOOTeL = FONT/ON/L tl OMOSHIZNZS d POOws Ib —- PONISI 0) OOS PI TUZS d HOO~ELE §—- FOOTIBIC 0z GSKERLERIS d POOTISZT = POOTRT/TY L SODTORSLL d FOOTE «= PONZ/L IIB el PZOSSSIC RT d POOTLID rOO2/b/o SI FREZDSPELL d yoNwLT/O = rONTEAOL ra} FESTIOLTSC d pOOT IZ roozoul 8 IPGOERLILR d pOOTILT HOTT fs) CPPS 1 ESSC d POOTENS = OZITP $1 OCBZSLL EL d POOP — PODT/NITZA 8 LEOPLLON PE d pOOTseT = OZLI/9 fa) ETELEOTICE a POOTILUS = OOZES a TZUASHILS8 d SOOT = POOZANET wz ZObGIVLOZR d PUOTTIZ —- PROUT 5 069845094 4. pOOUSIS «= pOOT/EUS t GOPLEESOLL d POOTIGIL POOUIL L/D v SZ7RROCIORL é POULT POOTTU/T 0 LLpolZtose d pOOT876 PWT /B rl TELSSOLELL d pOOzPl i> = FOOT E/E 3 PZOCLSSTIZ d POOLS PORT67/P 6 ZSSIPEGEEL d POOZEI/OI — FONTE7OT Zl 19ZL3Q0THL d poozmeas FOTUr US 6 LIVLPPLOIS d POOTISTIE = PONTO uu 98919118 d PODTTTOL §—- PONT/SI01 tird 9891921118 d HO02/R/6 0076 1/8 st 6709880961 d soozss/l ooze 7c1 u LEORZZ6CEL a wOOwOUZ = HO Z/OE sheg qa Asemyig (Q) 77H 40 ed aed uapY HSS root BAX PEP (4) EMT, a3ayong SWOT S07 eheg 2191807 Prerpaiy fendsopy vommarqrqay IseOD P| a0 Wg Awspey wessorg #99 WD PIEDIPIA) WS 34 Joporg aacoipesy HLNOSHIN PFOA wey Ayr PAGE 14 COM 13:44 858-322-6964 89/21/2087 LOGLG'SISE OO RHI OVS TO L668 6S, CLE99'R1$ SO SOB ES Bb Zet ZS ro eres SEO LST LOLI ZLF BS Log Zs BS LLG bs OL GaL's$ owdae ees TS6sH 12 Be eaL ETS POLES RES OZ FS5'OL$ Le bGR'OLS OR S673 wemed oounss moat opens weZEu BUMPERS EHR E KS S56 HDLZ PBL COGS COS HLL LPGUSLOL ‘Shee eS UBat OPEWELE OPS LEE Z95NDS ZaoosZa®ZaannzZnunaE oc 6m FOOCI potest t PODZIEL IES POUT FOuzIHrES yonziptst POUCH ODT IE yO0CrOL8 FOOTE PODCARLLL vOnzieTG BOUT BOOZ ZI Qazi I booze wt POOLeres woome POLE buozAet woot raozsit BAA ea Ones pOdzAasS PaO ZS FOOZAL COMPLETE THIS SECTION ON DELIVERY SENDER: COMPLETE THIS SECTION A. Signature ™ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. @ Print your name and address on the reverse $o that we can return the card to you. # Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: 2007008058 ; Administra tor Yoaltp Sout, Emerald Coast Rebabs lite fen Mesprte! (847 Florids Avenve am CO Fler; d« Pan 4 4, y 32405 3. Service Type DC Certified Mall (J Express Mail O Registered {0 Return Receipt for Merchandise OO Insured Mall —_(C C.0.D. 4, Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service labe 7006 2150 0004 5471 lice PS Form 3811, February 2004 Domestic Return Recelpt 402595-02-M-1540 Unirep States Postat SERVICE First-Class Mail Postage & Fees Paid USPS Permit No. G-10 * Sender: Please print your name, address, and ZIP+4 in this box * : Mary Daley Jacobs, Senior Attorney Agency for Health Care Administration Office of the General Counsel 2295 Victoria Avenue, Room 346C Fort Myers, Florida 33901 Huthadhdbidbdbsllbsbbsbibillbsbdeolbd

Docket for Case No: 07-005487