STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2013-02281 JOSEPH GRANT SHUFLITOWSKI, M.D. RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, by and through undersigned counsel, files this Administrative Complaint before the Board of Medicine against Respondent, Joseph Grant Shuflitowski, M.D., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of medicine pursuant to Chapters 20.43, Florida Statutes (2012- 2013); Chapter 456, Florida Statutes (2012-2013); and Chapter 458, Florida Statutes (2012-2013). 2. At all times material to this Complaint, Respondent was licensed to practice medicine within the State of Florida, having been issued license number ME 34190. 3. | Respondent’s address of 16900 Front Beach Road, Panama City Beach, Florida 32413. 4. On or about April 12, 2013, Dr. M.H., a neuropsychologist, evaluated Respondent pursuant to a Department-issued Order Compelling an Examination. Dr. M.H. determined that Respondent suffered from impairments in attention, concentration and information processing. 5. On or about April 22, 2013, Dr. J.I., a forensic psychiatrist specializing in addiction medicine, evaluated Respondent pursuant to a Department-issued Order Compelling an Examination. Dr. J.I. considered the findings of Dr. M.H. prior to rendering an opinion. 6. Dr. J.I. diagnosed Respondent with cognitive disorder, not otherwise specified and depressive disorder, not otherwise specified, in remission. 7. Dr. J.I. opined that Respondent was unable to practice medicine with reasonable skill and safety to patients. 8. Section 458.331(1)(s), Florida Statutes (2012-2013), subjects a physician to discipline for being unable to practice medicine with reasonable skill and safety to patients by reason of illness or use of alcohol, DOH v. Joseph Shuflitowski, M.D. 2 DOH Case Number 2013-02281 drugs, narcotics or chemicals or any other type of material or as a result of any mental or physical condition. 9. Respondent violated Section 458.331(1)(s), Florida Statutes (2012-2013), by being unable to practice medicine with reasonable skill and safety to patients due to his mental condition of impaired cognitive functioning. 10. Based on the foregoing, Respondent violated Section 458.331(1)(s), Florida Statutes (2012-2013), by being unable to practice medicine with reasonable skill and safety to patients by reason of illness or as a result of his mental or physical condition. 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 Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. DOH v. Joseph Shuflitowski, M.D. 3 DOH Case Number 2013-02281 th SIGNED this _/ 8 day of April, 2014. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health \ Louise Wilhite-St Laurent Assistant General Counsel DEPARTMENT OF HEALTH DOH Prosecution Services Unit DEPUTY CLERK 4052 Bald Cypress Way, Bin C-65 cuERK: rrolyi tte Tallahassee, FL 32399-3265 ; Florida Bar Number 0091244 pate__APR 18 204 Phone (850) 245-4444 x 8331 Fax (850) 245-4662 Louise.StLaurent@flhealth.gov PCP: April 18, 2014 PCP Members: Faud Ashkar, M.D., Zachariah P. Zachariah, M.D., & Nina Di Pietro DOH v. Joseph Shuflitowski, M.D. 4 DOH Case Number 2013-02281 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. Joseph Shuflitowski, M.D. 5 DOH Case Number 2013-02281

Docket for Case No: 16-003564PL