STATE OF FLORIDA ~ DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2015-27450 FOLORUNSO IBRAHEEM, A.R.N.P., RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health (“Department”), by. and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Folorunso Ibraheem, A.R.N.P., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Administrative Complaint, Respondent was an advanced registered nurse practitioner (ARNP) within the state of Florida, having been issued license number ARNP 9193808. 3. Respondent's address of record is 940 Northeast 142™ Street, North Miami, Florida 33161. 4. Respondent's additional mailing address is 10350 Southwest 6" Street #106, Pembroke Pines, Florida 33025. Facts Relating to Fraudulent Representation 5. At all times material to _this Administrative Complaint, Respondent was the president of Health on Wheel Corporation, an incorporated entity registered with the Florida Department of State Division of Corporations and located in Pembroke Pines, Florida. 6. Respondent refers to himself as “Doctor Folorunso Ibraheem” and lists “MD”, the professional suffix for medical doctor, following his name on his business card for Health on Wheel Corporation. 7. Respondent indicates he is “Medicine-Nursing-Lab qualified” on his business card for Health on Wheel Corporation. _ 8. At all times material to this Administrative Complaint, Respondent was the president of American International World University, Corp., an incorporated entity registered with the Florida Department. of State Division of Corporations and located in Pembroke Pines, Florida. DOH v. Folorunso Ibraheem, A.R.N.P. : 2 DOH Case No. 2015-27450 9, Respondent refers to himself as “Doctor Folorunso Ibraheem” and lists “MD”, the professional suffix for medical doctor, following his name on his business card for American International World University, Corp. 10. Respondent indicates he is “Medicine-Nursing-Lab qualified” on his business card for American International World University, Corp. 11. At all times material to this Administrative Complaint, Respondent was the president of Grassroots Health Care, Inc., an incorporated entity registered with the Florida Department of State Division of Corporations and located in Pembroke Pines, Florida. 12. At all times material to this Administrative Complaint, Respondent maintained a vehicle decal advertisement for “Grassroots Health Care, Inc., Family Clinic’, on which Respondent refers to himself as “Dr. Folorunso Ibraheem, MBBS (MD)".? 13. At all times material to this Administrative Complaint, Respondent was not licensed as a medical doctor within the state of Florida. ' MBBS is an abbreviation for the professional degree of Bachelor of Medicine, Bachelor of Surgery awarded upon graduation from a medical school in countries that follow the tradition of the United Kingdom, DOH v. Folorunso Ibraheem, A.R.N.P. 3 DOH Case No, 2015-27450 Facts Relating to Practicing Beyond Scope 14. At all times material to this Administrative Complaint, Respondent offered “Diagnosis, Treatment & Health Promotion” and an “Annual Medical Check-up in the USA” on his business card for Health on Wheel Corporation. 15. At all times material to this Administrative Complaint, Respondent maintained a vehicle decal advertisement for “Grassroots Health Care, Inc., Family Clinic’, on which Respondent's name and photograph are displayed along with offers for “Diagnosis”, “Treatment”, “Health Promotion’, and “Tourists: Call About Our Annual Medical Check-Up in the USA”. 16. At all times material to this Administrative Complaint, Respondent was the president of World Wide Wellness 1 Corporation, an incorporated entity registered with the Florida Department of State Division of Corporations and located in North Miami Beach, Florida. 17. At all times material to this Administrative Complaint, Respondent offered medical diagnosis, treatment, and services to prospective patients through the website “www.worldwidewellness1.com”. DOH v. Folorunso Ibraheem, A.R.N.P. 4 DOH Case No. 2015-27450 18. At all times material to this Administrative Complaint, Respondent did not have an established protocol between himself and a supervising Florida-licensed medical doctor, osteopathic physician, or dentist filed with the Board of Nursing. COUNT ONE 19. Petitioner realleges and incorporates paragraphs one through eighteen as if fully set forth herein. 20. Section 456.072(1)(m), Florida Statutes (2014-2015), provides that making deceptive, untrue, or fraudulent representations in or related to the practice of a profession or employing a trick or scheme in or related to the practice of a profession constitutes grounds for disciplinary action. 21. Respondent made one or more deceptive, untrue, or fraudulent representations in or related to the practice of the profession of medicine and/or the profession of nursing by holding himself out as a medical doctor when Respondent was not licensed as a medical doctor within the state of Florida. 22. Based on the foregoing, Respondent has violated Section 456.072(1)(m), Florida Statutes (2014-2015). DOH v. Folorunso Ibraheemy A.R.N.P. 5 DOH Case No. 2015-27450 COUNT TWO 23. Petitioner realleges and incorporates paragraphs one through eighteen as if fully set forth herein. 24. Section 456.072(1)(0), Florida Statutes (2014-2015), provides that practicing or offering to ladies beyont the scope permitted by law or accepting and performing professional responsibilities the licensee knows, or has reason to know, the licensee is not competent to perform constitutes grounds for disciplinary action. 25. Rule 64B9-4.010(1), Florida Administrative Code, provides in relevant part that an Advanced Registered Nurse Practitioner shall only perform medical acts of diagnosis, treatment, and operation pursuant to a protocol between the ARNP and a Florida-licensed medical doctor, osteopathic physician, or dentist. 26. Respondent offered to practice beyond the scope of his ARNP license by offering diagnosis and treatment of medical conditions to prospective patients through one or more business cards, advertisements, and/or websites without a protocol Behneen Respondent and a supervising Florida-licensed medical doctor, osteopathic physician, or dentist. DOH vy. Folorunso Ibraheem, A.R.N.P. 6 DOH Case No. 2015-27450 27. Based on the foregoing, Respondent has violated Section 456.072(1)(0), Florida Statutes (2014-2015). WHEREFORE, the Petitioner respectfully requests that the Board of Nursing 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. SIGNED this _! [+h day of Mued, , 2016. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health Sy Fl. Bar $¢ 4877 for RISTOPHER A. JURICH ssistant General Counsel Fla. Bar No. 0099014 DOH Prosecution Services Unit besten ed 4052 Bald Cypress Way, Bin C-65 Deputy Clerk Tallahassee, FL 32399-3265 CLERK ofagel Sanders Telephone: (850) 245-4444 ext. 8174 DATE MAR 1 1 2016 _ _.. Facsimile: (850) 245-4662 Email: christopher.jurich@flhealth.gov PCP Meeting: March 9, 2016 PCP Members: Barbara Kemp, Derrick Glymph DOH v. Folorunso Ybraheem, A.R.N.P. 7 DOH Case No. 2015-27450 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28- 106,.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Please note that mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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. Folorunso Ibraheem, A.R.N.P. 8 DOH Case No, 2015-27450

Docket for Case No: 16-003862PL