STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, | PETITIONER, v. CASE NO. 2012-06284 MAHESH PARIKH, M.D., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, files this Administrative Complaint before the Board of Medicine against Respondent, Mahesh Parikh, M.D., and 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, having been issued license number ME 111812. 3. Respondent's address of record is 11 Boland Drive, Barrington, Illinois 60010. A- 04 4. Respondent is not board certified in any specialty areas recognized by the Florida Board of Medicine. 5. The Illinois Department of Financial and Professional Regulation, Division of Professional Regulation (“Illinois Department”) is the licensing authority regulating the practice of medicine in the State of Illinois. 6. On or about March 26, 2012, the Director of the Division of Professional Regulation of the Department of Financial and Professional Regulation of the State of Illinois took disciplinary action against Respondent's Illinois medical license by issuing an Order (Case No. 2009- 10646) Indefinitely Suspending Respondent’s license for engaging in dishonorable, unethical, or unprofessional conduct of a character likely to deceive, defraud or harm the public (225 ILCS 60/22(A)(5)), and for immoral conduct in the commission of any act but not limited to commission of an act of sexual misconduct related to the licensee's practice (225 ILCS 60/22(A)(20)). 7. Respondent failed to report to the Board, in writing, within 30 days of the action taken against Respondent's license by the Illinois Department. DOH v. Mahesh Parikh, M.D.; 2012-06284 2 8. Respondent failed to update his profile or timely submit information to the Department regarding the disciplinary action taken against the Respondent's license by the Illinois Department. COUNTI 9. Petitioner re-alleges and incorporates paragraphs one (1) through eight (8), as if fully set forth herein within this paragraph. 10. Section 458.331(1)(b), Florida Statutes (2011), provides that having a license or the authority to practice medicine revoked, suspended, or otherwise acted against, including the denial of licensure, by the licensing authority of another jurisdiction constitutes grounds for disciplinary action by the Board of Medicine. 11. The Illinois Department acted against Respondent's Illinois medical license by issuing an Order, effective March 26, 2012, indefinitely suspending Respondent. 12. Based on the foregoing, Respondent violated Section 458.331(1)(b), Florida Statutes (2011), by having his medical license acted against and suspended by the licensing authority of Illinois. COUNT IT 13. Petitioner re-alleges and incorporates paragraphs one (1) through eight (8), as if fully set forth herein within this paragraph. DOH v. Mahesh Parikh, M.D.; 2012-06284 3 14. Section 458.331(1)(kk), Florida Statutes, (2011), provides that failing to report to the board, in writing, within 30 days if action as defined in paragraph (b) has been taken against one’s license to practice medicine in another state, territory, or country, constitutes grounds for disciplinary action by the Board of Medicine. 15. Respondent failed to report to the Board, in writing, within 30 days of the effective date of the Order of the Illinois Department suspending the Respondent's license. 16. Based on the foregoing, Respondent violated Section 458,331(1)(kk), Florida Statutes, (2011), by failing to report to the Board, in writing, within 30 days if action as defined in paragraph (b) has been taken against one's license to practice medicine in another state, territory, or country. COUNT Tit 17. Petitioner re-alleges and incorporates paragraphs one (1) through eight (8), as if fully set forth herein within this paragraph. 18. Section 456.072(1)(w), Florida Statutes, (2011), provides that failing to comply with the requirements for profiling and credentialing, including, but not limited to, failing to provide initial information, failing to timely provide updated information, or making misleading, untrue, DOH v. Mahesh Parikh, M.D.; 2012-06284 4 deceptive, or fraudulent representations on a profile, credentialing, or initial or renewal licensure application, constitutes grounds for disciplinary action by the Board of Medicine. 19. Respondent failed to update his profile or timely submit information to the Department regarding the disciplinary action taken against Respondent's license by the Illinois Department. 20. Based on the foregoing, Respondent violated Section 456.072(1)(w), Florida Statutes, (2011), by failing to comply with the requirements for profiling, by failing to timely provide updated information to the Department regarding the action taken against Respondent by the Illinois Department. | WHEREFORE, the 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 Board deems appropriate. [signature appears on the following page| DOH v. Mahesh Parikh, M.D.; 2012-06284 5 qth ; SIGNED this day of Nov enabere 2012. John H. Armstrong, MD Surgeon General and Secretary of Health André Outso Assistant General Counsel Fla. Bar No. 0091570 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Telephone: (850) 245-4640 Facsimile: (850) 245-4681 Email: Andre_Ourso@doh.state.fl.us FILED DEPARTMENT OF HEALTH . DEPUTY CLERK CLERK Angel Sanders DATE NOV 14 2012 ACO/ PCP: 11/9/2012 PCP Members: Dr. Avila, Dr. Orr, Mr. Levine DOH v, Mahesh Parikh, M.D.; 2012-06284 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. DOH v, Mahesh Parikh, M.D.; 2012-06284 7

Docket for Case No: 13-002430PL