Fil. FD
STATE OF FLORIDA A HCA
AGENCY FOR HEALTH CARE ADMINISTRATION AGENCY CLERl{
zooq JUN 2q P 2: o 1
STATE OF FLORIDA, AGENCY FOR HEALTH CARE ADMINISTRATION,
Petitioner,
CASE NO: 2009002065
DOAH NO: 09-1717
RENDITION NO.: AHCA-09- JJ? -5-OLC
ALL SEASONS HOME CARE, LLC d/b/a ALL SEASONS HOME CARE, LLC,
Respondent. /
FINAL ORDER
Having reviewed the administrative complaint dated March 5, 2009, attached hereto and incorporated herein (Ex. 1), and all other matters of record, the Agency for Health Care Administration ("Agency") has entered into a Settlement Agreement (Ex. 2) with the other party to these proceedings, and being otherwise well-advised in the premises, finds and concludes as follows:
The attached Settlement Agreement is approved and adopted as part of this Final Order, and the parties are directed to comply with the terms of the Settlement Agreement.
Respondent shall pay an administrative fine in the amount of
$5,000.00. The administrative fine is due and payable within thirty (30) days of the date of rendition of this Order.
Filed June 30, 2009 2:08 PM Division of Administrative Hearings.
Checks should be made payable to the "Agency for Health Care Administration." The check, along with a reference to this case number, should be sent directly to:
Agency for Health Care Administration Office of Finance and Accounting Revenue Management Unit
2727 Mahan Drive, MS# 14
Tallahassee, Florida 32308
Unpaid amounts pursuant to this Order will be subject to statutory interest and may be collected by all methods legally available.
Respondent's petition for formal administrative proceedings is hereby dismissed.
Each party shall bear its own costs and attorney's fees.
The above-styled case is hereby closed.
DONE and ORDERED this &day of- ------= - --, 2rx:;[j, in Tallahassee, Leon County, Florida.
, Secretary
ealth Care Administration
A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW WHICH SHALL BE INSTITUTED BY FILING ONE COPY OF A NOTICE OF APPEAL WITH THE AGENCY CLERK OF AHCA, AND A SECOND COPY, ALONG WITH FILING FEE AS PRESCRIBED BY LAW, WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE AGENCY MAINTAINS ITS HEADQUARTERS OR WHERE A PARTY RESIDES. REVIEW OF PROCEEDINGS SHALL BE CONDUCTED IN ACCORDANCE WITH THE FLORIDA APPELLATE RULES. THE NOTICE OF APPEAL MUST BE FILED WITHIN 30 DAYS OF RENDITION OF THE ORDER TO BE REVIEWED.
Copies furnished to:
Jeffrey G. Schneider, Esq. Attorney for Respondent Hogan & Harston LLP
875 Third Avenue . New York, NY 10022 (U. S. Mail)
Finance & Accounting Agency for Health Care Administration
Revenue Management Unit 2727 Mahan Drive, MS #14
Tallahassee, Florida 32308 (Interoffice Mail)
Jan Mills
Agency for Health Care Administration
2727 Mahan Drive, Bldg #3, MS #3
Tallahassee, Florida 32308 (Interoffice Mail)
Nelson E. Rodney Assistant General Counsel
Agency for Health Care Administration 8350 NW 52nd Terrace, Suite 103
Miami, Florida 33166 (Interoffice Mail)
Hon. John C. Van Laningham Administrative Law Judge
Division of Administrative Hearings The DeSoto Building
1230 Apalachee Parkway
Tallahassee, Florida 32399-3060 (U.S. Mail)
Home Care Unit
Agency for Health Care Administration 2727 Mahan Drive, MS #34
Tallahassee, Florida 32308 (Interoffice Mail)
I HEREBY CERTIFY that a true and correct copy of this Final Order was
served on the above-named person(s) and entities by U.S. Mail, or the method designated, on this the y of =: Je-,1'\Q_..- , 20&.
Richard Shoop, Cler
Agency for Health Care Administration 2727 Mahan Drive, Building #3
Tallahassee, Florida 32308-5403
(850) 922-5873
STATE OF FLORIDA
AGENCY FOR HEALTH CARE ADMINISTRATION
AGENCY FOR HEALTH CARE ADMINISTRATION,
Petitioner,
v.
ALL SEASONS HOME CARE LLC d/b/a
ALL SEASONS HOME CARE LLC,
Respondent.
/
AHCA No.: 2009002065
Return Receipt Requested:
7008 0500 0002 0764 9770
7008 0500 0002 0764 9787
ADMINISTRATIVE COMPLAINT
COMES NOW the Agency for Health Care Administration ("AHCA"), by and through the undersigned counsel, and files this Administrative Complaint against All Seasons Home Care LLC d/b/a All Seasons Home Care LLC (hereinafter "All Seasons Home Care LLC"), pursuant to Chapter 400, Part III, and Section 120.60, Florida Statutes, {2008), and alleges:
NATURE OF THE ACTION
This is an action to revoke the license and impose a
$5,000 fine, pursuant to Section 408.474(2)(d), Florida Statutes
{2008), and Chapter 59A-8, Florida Administrative Code for the protection of the public health, safety and welfare.
JURISDICTION AND VENUE
This Court has jurisdiction pursuant to Sections
120.569 and 120.57, Florida Statutes, and 28-106, Florida Administrative Code.
EXHIBIT
Venue lies in Palm Beach County, pursuant to Section 120.57, Fla. Stat. and Rule 28-106.207, Florida Administrative Code.
PARTIES
AHCA is the regulatory authority responsible for licensure and enforcement of all applicable statutes and rules governing home health agencies, pursuant to Chapter 400, Part III,· Florida Statutes (2008), Chapter 408, Florida Statutes (2008) and Chapter 59A-8, Florida Administrative Code.
All Seasons Home Care LLC operates a home health agency located at 5130 Linton Boulevard, Suite B-5, Delray Beach, Florida 33484. All Seasons Home Care LLC is licensed as a home health agency, license number 299991655, with an expiration date of November 15, 2010. All Seasons Home Care LLC was at all times material hereto a licensed facility under the licensing authority of AHCA and was required to comply with all applicable rules and statutes.
COUNT I
ALL SEASONS HOME CARE LLC MAINTAINED FRAUDULENT RECORDS FOR THREE SAMPLED PATIENTS
Section 408.474(2)(d), Florida Statutes (2008) (FRAUDULENT PATIENT RECORDS
UNCLASSIFIED VIOLATION
AHCA re-alleges and incorporates paragraphs (1) through
(5) as if fully set forth herein.
During a complaint investigation conducted on October 3, 2008 and based on observation, interview and record review, it was determined that the Home Health Agency {HHA) maintained fraudulent records for 3 of 3 sampled patients (patient #1, #2 and #3) as evidenced by portions of the Comprehensive Assessments including OASIS (Outcome and Assessment Information Set) data completed by personnel other than the Registered Nurse performing the assessment {Patient #1, #2 and #3), documentation of homebound status for a patient no longer homebound (Patient #2), and continuing services beyond the date such service is required
{Patient #3).
Patient #1 was admitted to the HHA with a start of care date of 10/15/2007 with diagnoses including Anxiety State and Atrial Fibrillation. Observation of the initial Comprehensive Assessment including OASIS data revealed distinctively different handwriting in the diagnoses section of. the assessment. Record review of the Comprehensive Assessment including OASIS data for the initial certification period of 10/15/2007 to 12/13/2007 listed no primary diagnosis and secondary diagnoses of Atrial Fibrillation. The original intake form for the physician's referral ·listed the diagnoses as Anxiety and Cardiac Arrhythmia. The initial Plan of Care sheet listed the primary diagnosis as Abnormality of Gait with secondary diagnoses of Hypothyroidism, Atrial Fibrillation and Other Abnormality of Urination.
In an interview with the HHA's staff coder on
10/02/2008 at 2:40 PM she stated that the HHA has assigned the
duty of prioritizing diagnosis on the assessment to her. The primary diagnosis is decided on the basis of the most frequently rendered service. The Director of Nursing stated in an interview on 01/03/2008 at 2:55 PM that the HHA1 s procedure for completing the diagnosis section of the Comprehensive Assessment with OASIS data is to have the Registered Nurse (RN) performing the assessment list the pertinent diagnosis on a "sticky note" and return the assessment to the office. The coder will ·then "put them in order." This procedure was also verified in an interview with a HHA Registered Nurse responsible for performing the Comprehensive Assessment with OASIS data on 10/03/2008 at 8:45 AM.
Patient #2 was admitted to the HHA with a start of care date of 4/07/2008 and diagnosis as per the Plan of Care including Osteoarthritis of the Arm, Osteoporosis, Spinal Stenosis, Hypertension, and Long Term Anticoagulant Therapy. Observation of the initial Comprehensive Assessment with OASIS data revealed distinctively different handwriting in the diagnoses section of the assessment. Record review of the Comprehensive Assessment with OASIS data for the initial certification period of 4/07/2008 to 6/05/2008 revealed a primary diagnosis of Pain with secondary diagnosis of Gait Dysfunction, Arthritis, Hypertension, and Hypercholesteremia. The initial referral intake-sheet, list the primary diagnosis as Pain and secondary diagnosis of Hypertension and Arthritis The re-certification assessment for 6/06/2008 to
8/04/2008 listed a primary diagnosis of Dehydration with
secondary diagnosis of Hypertension, Long Term Anticoagulant Therapy, Hypercholesteremia, Depression, and Gait Dysfunction. The Comprehensive Assessment with OASIS data listed the primary diagnosis as Physical Therapy with secondary diagnosis of Long Term Anticoagulant Therapy, Hypertension, Osteoarthritis, and Lumbar Stenosis. The Plan of Care for the re-certification period reflects the diagnosis as listed on the Comprehensive Assessment.
In an interview with the HHA's staff coder on 10/02/2008 at 2:40 PM she stated that the HHA has assigned the duty of prioritizing diagnosis on the assessment to her. The primary diagnosis is decided on the basis of the most frequently rendered service. The Director of Nursing stated in an interview on 01/03/2008 at 2:55 PM that the HHA's procedure for completing the diagnosis section of the comprehensive assessment with OASIS data is to have the Registered Nurse (RN) performing the assessment, list the pertinent diagnosis on a "sticky note" and return the assessment to the office. The coder will then "put them in order." This procedure was also verified in an interview with a HHA Registered Nurse responsible for performing the Comprehensive Assessment including OASIS data on 10/03/2008 at 8:45 AM.
Patient #2 was interviewed by phone on 10/03/2008 at 1:15 PM. The present orders are for Skilled Nursing once a week for 9 weeks, Physical Therapy twice a week for 4 weeks and then once a week for one week, and Occupational Therapy twice a week
for 6 weeks. The patient stated that the Physical Therapy had
been stopped for the present time because his/her Medicare benefits ran out but would be restarted in January. The nurse continues to visit once a week for B12 shots that were just initiated. In response to the surveyor's inquiry as to his/her current level of activity he/she stated that he/she regularly goes out to church, attends community meetings, goes on day trips, and is planning to go out this evening to do laundry and go out to dinner. He/she stated sometimes friends will accompany him/her but often he/she is alone. This information refutes the documentation in the clinical record stating the patient is homebound and eligible for home health care.
Patient #3 was admitted to the HHA with a start of care
date of 3/22/2008 and a primary diagnosis listed on referral intake sheet as Bruises, Contusions, and Hematoma from a fall at home on 3/21/2008 and secondary diagnosis of Hypertension and Arthritis. Observation of the initial Comprehensive Assessment including OASIS data revealed distinctively different handwriting in the diagnosis section of the assessment. The Comprehensive Assessment with OASIS data for the initial certification period of 8/22/2008 to 5/20/2008 listed the primary diagnosis as Gait Dysfunction and secondary diagnoses of Hypertension and Arthritis. The Plan of Care for the initial certification period listed the primary diagnosis of Sprain Lumbosacral and secondary diagnosis listed as General Muscle Weakness, Difficulty Walking, and Multiple Contusions.
In an interview with the HHA's staff coder on 10/02/2008 at 2:40 PM she stated that the HHA has assigned the duty of prioritizing diagnosis on the assessment to her. The primary diagnosis is decided on the basis of the most frequently rendered service. The Director of Nursing stated in an interview on 01/03/2008 at 2:55 PM that the HHA's procedure for completing the diagnosis section of the comprehensive assessment with OASIS data is to have the Registered Nurse (RN) performing the assessment list the pertinent diagnosis on a "sticky note" and return the assessment to the office. The coder will then "put them in order." This procedure was also verified in an interview with a HHA Registered Nurse responsible for performing the comprehensive assessment . with OASIS data on 10/03/2008 at 8:45 AM.
P'atient #3 has orders for the current certification period (9/18/2008 to 11/16/2008) that include Skilled Nursing once a week for one week and Physical Therapy for once a week for one week, three times a week for 4 weeks, and once a week for one week. In an interview with the patient's live-in caregiver on 10/3/2008 at 1:30 PM, he/she stated that he/she is with the patient 7 days a week 24 hours a day. The patient seldom goes out of his/her own choice but does occasionally accompany the. caregiver to do some shopping. In an interview with the physician on 10/03/2008 at 1:40 PM he stated that the Physical Therapy was initiated in March to stabilize the patient's gait after a fall
at home. He stated he was not aware that the patient was still
receiving home Physical Therapy and thought that the HHA was only checking on the patient periodically until a full time caregiver could be hired. The patient has been in the office for regular
appointments. The physician further stated that the patient is
.
frail but otherwise doing very well and has probably met his/her full potential for rehabilitation from Physical Therapy. He stated that he always reads the Plan of Care before signing them and does not remember the re-certification for this patient. A review of the clinical record revealed that the Plan of Care for certification period 7/20/2008 to 9/17/2008 and 9/18/2008 to 11/16/2008 have not been-signed by the physician.
Based on the foregoing, All Seasons Home Care LLC violated 408.474(2)(d), Florida Statutes (2008), which carries, in this case, a revocation of license.
PRAYER FOR RELIEF
WHEREFORE, the Petitioner, State of Florida Agency for Health Care Administration requests the following relief:
Make factual and legal findings in favor of the
Agency on Count I.
Revoke the· Respondent's license and impose a
$5,000.00 fine, pursuant to Section 408.474(2)(d), Florida Statutes (2008).
Grant such other relief as this Court deems is
just and proper.
Respondent is notified that it has a right to request an administrative hearing pursuant to Sections 120.569 and 120.57, Florida Statutes (2008). Specific options for administrative action are set out in the attached Election of Rights Form. All requests for hearing shall be made to the Agency for Health Care Administration, and delivered to the Agency £or Health Care
Administrationr 2727 Mahan Driver Ma.i1 Stop #3r Tallahasseer Fl.orida 3230Br attention Agency C1erkr te1ephone (850) 922-5873. RESPONDENT IS FURTHER NOTIFIED THAT THE FAILURE TO RECEIVE A REQUEST FOR A HEARING WITHIN 21 DAYS OF RECEIPT OF THIS COMPLAINT
WILL RESULT IN AN ADMISSION OF THE FACTS ALLEGED IN THE COMPLAINT AND THE ENTRY OF A FINAL ORDER BY THE AGENCY.
IF YOU WANT TO HIRE AN ATTORNEY, YOU HAVE THE RIGHT TO BE REPRESENTED BY AN ATTORNEY IN THIS MATTER.
n E. Rodney Assistant General Agency for Health Care Administration
8350 N. W. 52 Terrace
Suite 103
Miami, Florida 33166
Copies furnished to: Field Office Manager
Agency for Health Care Administration
5150 Linton Boulevard, Suite 500 Delray Beach, Florida 33484 (Inter-office mail)
Home Care Unit Program
Agency for Health Care Administration
2727 Mahan Drive
Tallahassee, Florida 32308 (Interoffice Mail)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Certified Mail Return Receipt Requested to Michael Downs, Administrator, All Seasons Home Care LLC, 5130 Linton Boulevard, Suite B-5, Delray Beach, Florida 33484, and to Patricia Heuberger, Registered Agent, 8951
. 34t h Street,
--- _...,Q/\>=....>.-=-> "'-->- ..c_..
Cooper City, Florida 33024, on
, 200 .
SENDER: COMPLETE THIS SECTION
Item 4 If Restricted Delivery Is desired. so that we can return the card to you. . or on the front If space permits. | ery 0, la delivery address different from Item 1? Yes If YES, enter dellvery address below: □ No |
3. Service 'lype □El-Certified Mall □Express Mall Registered .£1..RGfum Receipt for Merchandise □Insured Mall □c,o.o. | |
4. Restricted Delivery? (Ext/a Fee) □Yes |
Complete Items 1, 2, and ;3. Also complete
Print your name and address. on the reverse
Attach this card to the back of the mailpiece,
! PS Form 3811, February 2004
I
Domestic Return Receipt 102595-02-M-1540 t
.l
SENDER: COMPLETE THIS SECTION
Item 4 If Restricted Delivery Is desired. so that we can return the card to you. or on the front If space permits. | D. ls delivery address different from item 1? If YES, enter delivery address below: |
s. Servlge Type □113'6rtlllad Mall. 0 Express Mall Regl8tered k3-'lfeturn Receipt for Merchandise □Insured Mail □ C.O.D. | |
4. Restricted Dellvery? (Extra Fee) □ Yes |
Complete Items 1, 2, and 3. Also complete
Print your name and address on the reverse
Attach this card to the back of the mallpleca,
2, ArtlcleNumber 7008 □5 00 0002 0764 9770
(Transfer from service la
PS Form 3811, February 2004 Domestic Return Receipt 102595-02•M•1540
STATE OF FLORIDA
AGENCY FOR HEALTH CARE ADMINISTRATION
STATE OF FLORIDA, AGENCY FOR HEALTH CARE ADMINISTRATION,
vs.
Petitioner,
AHCA No. 2009002065
DOAHNo. 09-1717
ALL SEASONS HOME CARE, LLC, d/b/a ALL SEASONS HOME CARE, LLC. ,
Respondent.
./
Petitioner, State of Florida, Agency for Health Care Administration (hereinafter the "Agency"), through its undersigned representatives, and Respondent, All Seasons Home Care, LLC, d/b/a All Seasons Home Care, LLC (hereinafter "Respondent"), pursuant to Section 120.57(4), Florida Statutes, each individually, a "party," collectively as "parties," hereby enter into this Settlement Agreement (''Agreement") and agree as follows:
WHEREAS, Respondent is a Home Health Agency licensed pursuant to Chapters 400, Part III, and 408, Part II, Florida Statutes, Section 20.42, Florida Statutes, and Chapter 59A-8, Florida Administrative Code; and
WHEREAS, the Agency has jurisdiction by virtue of being the regulatory and licensing authority over Respondent, pursuant to Chapter 400, Part III, Florida Statutes; and
WHEREAS, the Agency served Respondent with an administrative complaint on or about March 6, 2009, notifying the Respondent of its intent to impose administrative fines in the amount of$5,000,00 and revocation of License; and
EXHIBIT
WHEREAS, Respondent requested a formal administrative proceeding by selecting Option 3 on the Election of Rights form; and
WHEREAS, the parties have negotiated and agreed that the best interest of all the parties will be served by a settlement of this proceeding; and
NOW THEREFORE, in consideration of the mutual promises and recitals herein, the parties intending to be legally bound, agree as follows:
All recitals herein are true and correct and are expressly incorporated herein.
Both parties agree that the "whereas" clauses incorporated herein are binding findings of the parties.
Upon full execution of this Agreement, Respondent agrees to waive any and all appeals and proceedings to which it may be entitled including, but not limited to, an informal proceeding under Subsection 120.57(2), Florida Statutes, a formal proceeding under Subsection 120.57(1), Florida Statutes, appeals under Section 120.68, Florida Statutes; and declaratory and all writs of relief in any court or quasi-court of competent jurisdiction; and agrees to waive compliance with the form of the Final Order (findings of fact and conclusions oflaw) to which it may be entitled, provided, however, that no agreement herein shall be deemed a waiver by either party of its right to judicial enforcement of this Agreement.
Upon full execution of this Agreement, Respondent agrees to pay $5,000.00 in
administrative fines to the Agency within thirty (30) days of the entry of the Final Order.
Venue for any action brought to enforce the terms of this Agreement or the Final Order entered pursuant hereto shall lie in Circuit Court in Leon County, Florida.
By executing this Agreement, Respondent neither admits nor denies, and the Agency asserts the validity of the allegations raised in the administrative complaint referenced
herein. However, no agreement made herein shall preclude the Agency from imposing a penalty against Respondent for any deficiency/violation of statute or rule identified in a future survey of Respondent, which constitutes a "repeat" deficiency from surveys identified in the administrative complaint. The parties agree that in such a "repeat" case, the factual deficiencies from the surveys identified in the administrative complaint shall be deemed found without further proof.
Respondent acknowledges and agrees that this Agreement shall not preclude or estop any other federal, state, or local agency or office from pursuing any cause of action or taking any action, even if based on or arising from, in whole or in part, the facts raised in the administrative complaint. This agreement does not prohibit the Agency from taking action regarding Respondent's Medicaid provider status, conditions, requirements or contract.
Upon full execution of this Agreement, the Agency shall enter a Final Order adopting and incorporating the terms of this Agreement and closing the above-styled case.
Each party shall bear its own costs and attorney's fees.
This Agreement shall become effective on the date upon which it is fully executed by all the parties.
Respondent for itself and for its related or resulting organizations, its successors or transferees, attorneys, heirs, and executors or administrators, does hereby discharge the State of Florida, Agency for Health Care Administration, and its agents, representatives, and attorneys of and from all claims, demands, actions, causes of action, suits, damages, losses, and expenses, of any and every nature whatsoever, arising out of or in any way related to this matter and the Agency's actions, including, but not limited to, any claims that were or may be asserted in any federal or state court or administrative forum, including any claims arising out of this agreement, by or on behalf of Respondent or related facilities.
This Agreement is binding upon all parties herein and those identified in paragraph eleven (11) of this Agreement.
In the event that Respondent was a Medicaid provider at the subject time of the occurrences alleged in the complaint herein, this settlement does not prevent the Agency from seeking Medicaid overpayments related to the subject issues or from imposing any sanctions pursuant to Rule 59G-9.070, Florida Administrative Code.
Respondent agrees that if any funds to be paid under this agreement to the Agency
are not paid within thirty-one (31) days of entry of the Final Order in this matter, the Agency may deduct the amounts assessed against Respondent in the Final Order, or any portion thereof, owed by Respondent to the Agency from any present or future funds owed to Respondent by the Agency, and that the Agency shall hold a lien against present and future funds owed to Respondent by the Agency for said amounts until paid.
The undersigned have read and understand this Agreement and have the authority to bind their respective principals to it.
This Agreement contains and incorporates the entire understandings and agreements of the parties.
This Agreement supersedes any prior oral or written agreements between the
parties.
This Agreement may not be amended except in writing. Any attempted assignment of this Agreement shall be void.
All parties agree that a facsimile signature suffices for an original signature.
The following representatives hereby acknowledge that they are duly authorized to enter into this Agreeme.nt.
Elizabeth Deputy, retary
Agency for Health Care Administration
2727 Mahan Drive, Bldg #1
Tallahassee, Florida 32308
Ju n Senior, eral Counsel
Agency for Health Care Administration
2727 Mahan Drive, Mail Stop #3
Tallahassee, Florida 32308 DATED: &µsjo9
Jeffr . Schneider, Esq. Hogan & Harston LLP 875 Third Avenue
New York, NY 10022
DATED: S /?..'110'1
A1(&£Sif=
Assistant General Counsel
Agency for Health Care Administration 8350 NW 52nd Terrace, Suite 103
Miami, Florida 33166 DATED: G, /1 IO
I t
| Issue Date | Proceedings |
|---|---|
| Jun. 30, 2009 | Final Order Closing File. |
| May 19, 2009 | Order Closing File. CASE CLOSED. |
| May 15, 2009 | Motion to Relinquish Jurisdiction filed. |
| Apr. 30, 2009 | Notice of Filing Interrogatories, Admissions and Request for Production filed. |
| Apr. 07, 2009 | Order of Pre-hearing Instructions. |
| Apr. 07, 2009 | Notice of Hearing by Video Teleconference (hearing set for May 28, 2009; 9:00 a.m.; West Palm Beach and Tallahassee, FL). |
| Apr. 07, 2009 | Joint Response to Initial Order filed. |
| Apr. 02, 2009 | Initial Order. |
| Apr. 01, 2009 | Administrative Complaint filed. |
| Apr. 01, 2009 | Petition for Formal Administrative Hearing filed. |
| Apr. 01, 2009 | Election of Rights filed. |
| Apr. 01, 2009 | Notice (of Agency referral) filed. |
| Issue Date | Document | Summary |
|---|---|---|
| Jun. 29, 2009 | Agency Final Order |
