STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, Vv. DOH Case No. 2015-30459 VIDYA SAGAR RAO MORISETTY, M.D., Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, the Florida Department of Health (hereinafter “Petitioner”), files this Administrative Complaint before the Florida Board of Medicine (hereinafter the “Florida Board”) against Respondent, Vidya Sagar Rao Morisetty, M.D. (hereinafter “Respondent”), and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of medicine pursuant to Section 20.43, Florida Statutes, and Chapters 456 and 458, Florida Statutes. 2. Atall times material hereto, Respondent was a licensed physician within the state of Florida, having been issued license number ME 77390. 3. Respondent's address of record is 195 Raptor Court, Forsyth, Illinois 62535. 4. Atall times material hereto, Respondent was a licensed physician within the state of Illinois, having been issued license number 036-084779. 5. _ The licensing authority regulating the practice of medicine in the state of Illinois is the Division of Professional Regulation, located within the Illinois Department of Financial and Professional Regulation (hereinafter the “Illinois Department’). 6. Onor about October 23, 2015, the Illinois Department approved a Consent Order agreed to by Respondent in the case styled and numbered Department of Financial and Professional Regulation v. Vidya Sagar Rao Morisetty, Case Number 2014-0985 (hereinafter the “disciplinary proceeding”). 7. The Consent Order was agreed to by Respondent in order to resolve the disciplinary proceeding. 8. | The Consent Order reprimanded Respondent's license to practice medicine in the state of Illinois. 9. The Consent Order constitutes action by the Illinois Department against Respondent's license or authority to practice medicine in the state of Illinois. DOH v. Vidya Sagar Rao Morisetty, M.D., DOH Case Number 2015-30459 Administrative Complaint 2 10. Section 458.331(1)(b), Florida Statutes (2015), subjects a licensee to discipline for 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 any jurisdiction, including its agencies or subdivisions. The licensing authority's acceptance of a physician's relinquishment of a license, stipulation, consent order, or other settlement, offered in response to or in anticipation of the filing of administrative charges against the physician's license, shall be construed as action against the physician's license. 11. Based on the foregoing, Respondent violated Section 458.331(1)(b), Florida Statutes (2015), by having his Illinois medical license acted against by the licensing authority of the state of Illinois, WHEREFORE, Petitioner respectfully requests the Florida Board 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 the Florida Board deems appropriate. DOH v. Vidya Sagar Rao Morisetty, M.D., DOH Case Number 2015-30459 Administrative Complaint 3 SIGNED this fifteenth day of July, 2016. Celeste Philip, M.D., M.P.H. Surgeon General and Secretary Geoffrey M. Christian, Esq. Assistant General Counsel Florida Bar No. 0010325 Department of Health FILED Prosecution Services Unit DEPARTMENT OF HEALTH 4052 Bald Cypress Way, Bin C-65 DEPUTY CLERK Tallahassee, Florida 32399-3265 Telephone (850) 245-4640, ext. 4661 ania Facsimile (850) 245-4684 - 7- |x /@ E-mail Geoffrey.Christian@flhealth.gov Attorney for Petitioner PCP: July 15, 2016 PCP Members: G. El-Bahri, M.D.; S. Rosenberg, M.D., Mr. Nicholas Romanello DOH v. Vidya Sagar Rao Morisetty, M.D., DOH Case Number 2015-30459 Administrative Complaint 4 DOH V. VIDYA SAGAR RAO MORISETTY, M.D. DOH CASE NUMBER 2015-30459 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 of Health within 21 days from the day Respondent received this 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 this Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. 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 of Medicine shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on Respondent in addition to any other discipline imposed. DOH v. Vidya Sagar Rao Morlsetty, M.D., DOH Case Number 2015-30459 Administrative Complaint 5 Fe ee em

Docket for Case No: 16-005190PL