07-000675MPI Agency For Health Care Administration vs. Constance Bence
 Status: Closed
Recommended Order on Tuesday, March 2, 2010.


View Dockets  
Summary: Respondent failed to properly document time spent with patients. Petitioner is entitled to seek reimbursement for Medicaid overpayment.

1STATE OF FLORIDA

4DIVISION OF ADMINISTRATIVE HEARINGS

8AGENCY FOR HEALTH CARE )

13ADMINISTRATION, )

15)

16Petitioner, )

18)

19vs. ) Case No. 07-0675MPI

24)

25CONSTANCE BENCE, )

28)

29Respondent. )

31)

32RECOMMENDED ORDER

34A final hearing was held before Daniel M. Kilbride,

43Administrative Law Judge (ALJ) of the Division of Administrative

52Hearings (DOAH) on July 19, 2007, in Tampa, Florida.

61APPEARANCES

62For Petitioner: L. William Porter II, Esquire

69Agency for Health Care Administration

742727 Mahan Drive, Building 3

79Tallahassee, Florida 32308-5403

82For Respondent: Constance Bence, pro se

88734 137th Street, Northeast

92Bradenton, Florida 34212

95STATEMENT OF THE ISSUE

99Whether Respondent is liable for overpayment of Medicaid

107claims, for the period of January 1, 2004, through January 1,

1182006, as stated in Petitioner’s Final Audit Report (FAR), dated

128July 19, 2006, due to Respondent’s failure to properly document

138for services billed and collected, in violation of Section

147409.913, Florida Statutes (2006), 1 and, if so, in what amount.

158PRELIMINARY STATEMENT

160By FAR, dated July 19, 2006, the Agency for Health Care

171Administration (Petitioner) notified Constance Bence

176(Respondent) that she was liable for overpayment of Medicaid

185claims in the amount of $12,500.70 for the audit period.

196Petitioner was also seeking to impose a fine of $1,500.00.

207Respondent disputed being liable for reimbursement to Petitioner

215for overpayment and requested a formal administrative hearing.

223A Petition for Formal Administrative Hearing was filed on

232February 9, 2007. Following discovery, a final hearing in this

242matter was held on July 19, 2007.

249At the final hearing, the Petitioner offered two witnesses:

258James Edgar, M.D., and Gary Mosier, Registered Nurse Consultant,

267and Medical Healthcare Program Analyst for AHCA in the Bureau of

278Medicaid Program Integrity. Petitioner offered 26 exhibits,

285which were admitted into evidence. The exhibits included 2004

294through 2006 versions of Sections 409.905, 409.906, 409.907,

302409.908, 409.913, 409.9131 and 414.41, Florida Statutes; Florida

310Administrative Code Chapters 59G-4 and 59G-5; and Advanced

318Registered Nurse Practitioner Services Coverage and Limitations

325Handbook , January 2004 edition, p. 2-45; Physician Services

333Coverage and Limitations Handbook , January 2007 update,

340p. 2-106; Current Procedural Terminology (CPT), American Medical

348Association (2004) pps 332-335; CPT (2005), pps 347-349; CPT

357(2006), pps 364-366.

360Respondent testified in her own behalf and entered no

369exhibits into evidence. A Transcript of the hearing was

378prepared and filed on August 1, 2007.

385Following the closing of evidence and before the filing of

395proposed recommended orders were due, Respondent asked for this

404matter to be placed in abeyance, due to her personal medical

415issues. Petitioner did not object and the case was placed in

426abeyance. The case continued to remain in abeyance until early

4362009, when Respondent had recovered sufficiently to proceed.

444She then requested an extension of time to file her proposed

455findings of fact and conclusions of law. The request was

465granted. Both parties timely filed their proposed findings of

474fact and conclusions of law, which have been carefully

483considered in the preparation of this Recommended Order. In the

493preparation of this Recommended Order, the ALJ thoroughly

501reviewed the complete file, Transcript and exhibits in this

510matter.

511FINDINGS OF FACT

5141. Petitioner is the single state agency under federal

523law, charged with administration of the Medicaid Program in

532Florida, and is charged with recovering overpayments to

540providers.

5412. Petitioner’s Bureau of Medicaid Integrity (MPI) has the

550primary responsibility to audit medical service providers who

558participate in the Medicaid program. MPI is a Bureau under the

569AHCA Inspector General.

5723. MPI conducts audits to review provider’s compliance

580with applicable statutes, rules, and policies regarding billing

588Medicaid for services rendered.

5924. An MPI audit is separate and distinct from an annual or

604other licensure survey or inspection conducted by Petitioner.

612The MPI audit is a compliance audit not a licensure one.

6235. MPI is mandated to review for provider fraud and abuse

634to ensure that the recipients are receiving the service for

644which Medicaid is paying.

6486. Respondent is a Florida licensed Advanced Registered

656Nurse Practitioner (ARNP) and provided medical services,

663including psychological counseling to Medicaid recipients,

669pursuant to a contract with Petitioner under her Provider number

679302123800.

6807. Respondent participated in the Medicaid program at

688least from July 1, 2001, and continuously through December 31,

6982005 (end of the Audit Period). Petitioner was paid for the

709services rendered.

7118. The audit period for Respondent was determined to be

721from January 1, 2004, through December 31, 2005. Claims for

731services were reviewed for a standard two-year audit period, and

741were audited for coding, records and visits.

7489. Thirty recipients were picked as a sample of recipients

758to examine during the two-year audit period. The selection was

768random and computer generated.

77210. Respondent was notified that Petitioner was conducting

780an audit. Respondent provided the charts on the 30 recipients

790to be examined and each of their claims during the audit period,

802which comprised all of her medical records.

80911. Gary Mosier is a Registered Nurse (RN), and holds a

820master’s degree in health care administration. Mosier is

828employed by the AHCA Inspector General, MPI, and is a nurse

839consultant and investigator. He was lead analyst and

847investigator in this matter.

85112. James Edgar, M.D., a psychiatrist with 35 years of

861experience, was retained by Petitioner as a peer review expert

871to review the charts and give a coding opinion.

88013. Billing codes are five-digit numbers. There are

888general guidelines for establishing the degree of difficulty

896which are set forth in documents such as Documentation

905Guidelines for Evaluation and Management Services , published by

913the American Medical Association. However, the correct coding

921can only be established through expert testimony, which is based

931upon established and identified criteria.

93614. With respect to each of the services reviewed,

945Petitioner relied upon the opinion of its expert, Dr. Edgar, as

956to whether or not Respondent billed Medicaid correctly.

964Dr. Edgar based his opinion on a review of documents regarding

975each service which were provided to him by Petitioner.

98415. In each instance where the Billing Code 90807,

993Individual Psychotherapy, Insight Orientation, appeared on

999Respondents charts for all 30 patients, Dr. Edgar down-coded the

1009charts to Code 90862, medical management. He did not disallow

1019payment, he adjusted each of them. His opinion was that,

1029without the time spent with the patient being delineated on the

1040medical chart, then the visit must be down-coded, or it could be

1052denied completely. Dr. Edgar’s testimony was credible and

1060persuasive.

106116. A Preliminary Audit Report (PAR) was sent to

1070Respondent on September 12, 2006. The PAR informed Respondent

1079of an alleged overpayment and explained her options prior to the

1090completion of a FAR. It also put Respondent on notice of

1101possible sanctions for lack of response to Petitioner.

110917. AHCA pays for mental health counseling when the face-

1119to-face time spent with the recipient is documented. The

1128medical records resulting from these services are required by

1137law to be maintained for five years following the dates of

1148service. These records must be made available when requested by

1158Petitioner.

115918. Respondent was requested to produce office appointment

1167sheets or calendars in order to document her face-to-face time

1177with patients.

117919. Respondent sent non-contemporaneous time listings,

1185rather than chart materials or office materials to verify and

1195document time spent. There existed no charted or office records

1205of the time spent with patients. Although Respondent testified

1214that these time listings were implied because of the code that

1225she submitted to Petitioner, this testimony is not persuasive in

1235proving a material fact in dispute.

124120. The FAR was sent to Respondent on November 7, 2006,

1252with the spreadsheet attachment. As with the PAR, it informed

1262Respondent of the issues involved with the audit and the

1272overpayment calculations and sought to levy a sanction, if one

1282applied.

128321. There was no documentation in the charts of the time

1294expended in the patient encounter, as required under the law.

1304Although Petitioner agreed that the use of the Code 90807

1314implied that there was one hour of face-to-face contact with a

1325patient, CPT policy requires both medication management and

1333therapy, not just medication management. There was no time of

1343service, time spent, and no start or stop times noted in the

1355medical records. These notations are specifically required

1362under Medicaid policy. A record must reflect the time spent

1372face-to-face with a patient.

137622. The final overpayment calculation and final audit

1384reports document that the overpayment to be recouped, and which

1394Petitioner seeks, is $12,500.70, with an added sanction of

1404$1,500.00.

140623. The preponderance of evidence has shown that

1414Respondent was overpaid in the amount of $12,500.70, and that

1425Petitioner is authorized to impose a penalty of $1,500.00.

1435CONCLUSIONS OF LAW

143824. DOAH has jurisdiction over the parties and the subject

1448matter of this proceeding pursuant to Section 120.569 and

1457Subsection 120.57(1), Florida Statutes. As such, this matter is

1466a de novo proceeding, and not merely a review of (proposed)

1477agency action. Florida Department of Transportation v. J.W.C.

1485Company , 396 So. 2d 778, 786-787 (Fla. 1st DCA 1981).

149525. Petitioner is charged with the administration of the

1504Medicaid program in Florida. § 409.902 Fla. Stat. As one of

1515its duties, Petitioner must recover “overpayments . . . as

1525to mean “any amount that is not authorized to be paid by the

1538Medicaid program whether paid as a result of inaccurate or

1548improper cost reporting, improper claiming, unacceptable

1554practices, fraud, abuse, or mistake.” § 409.913(1)(e), Fla.

1562Stat.

156326. Since Petitioner is the party asserting the

1571affirmative, Petitioner has the burden of establishing an

1579alleged Medicaid overpayment by a preponderance of the evidence.

1588§ 120.57(1)(j), Fla. Stat. South Medical Services, Inc. v.

1597Agency for Health Care Administration , 653 So. 2d 440, 441 (Fla.

16083d DCA 1995); Southpointe Pharmacy v. Department of Health and

1618Rehabilitative Services , 596 So. 2d 106, 109 (Fla. 1st DCA

16281992); Fla. DOT v. J.W.C. Company , supra . See also Haines v.

1640Department of Children and Families , 983 So. 2d 602, 606-608,

1650(Fla. 5th DCA 2008).

165427. The statutes, rules, Florida Medicaid Physician

1661Services Coverage and Limitations Handbook, and Florida Medicaid

1669Provider General Handbook in effect during the period for which

1679the services were provided govern the outcome of the dispute.

1689See Toma v. Agency for Health Care Administration , Case

1698No. 95-2419 (DOAH 1996) (as incorporated in Toma v. Agency for

1709Health Care Administration , 18 FALR 4735 (DOAH 1996)).

171728. Section 409.913, Florida Statutes, reads in pertinent

1725part as follows:

1728Oversight of the integrity of the Medicaid

1735program. -- The agency shall operate a

1742program to oversee the activities of Florida

1749Medicaid recipients, and providers and their

1755representatives, to ensure that fraudulent

1760and abusive behavior and neglect of

1766recipients occur to the minimum extent

1772possible, and to recover overpayments and

1778impose sanctions as appropriate.

1782* * *

1785(1) For the purposes of this section, the

1793term:

1794* * *

1797(e) “Overpayment” includes any amount that

1803is not authorized to be paid by the Medicaid

1812program whether paid as a result of

1819inaccurate or improper cost reporting,

1824improper claiming, unacceptable practices,

1828fraud, abuse, or mistake.

1832* * *

1835(7) When presenting a claim for payment

1842under the Medicaid program, a provider has

1849an affirmative duty to . . . present a claim

1859that is true and accurate and that is for

1868goods and services that:

1872* * *

1875(f) Are documented by records made at the

1883time the goods or services were provided,

1890demonstrating the medical necessity for the

1896goods or services rendered. Medicaid goods

1902or services are excessive or not medically

1909necessary unless both the medical basis and

1916the specific need for them are fully and

1924properly documented in the recipient’s

1929medical record.

1931The agency may deny payment or require

1938repayment for goods or services that are not

1946presented as required in this subsection.

1952* * *

1955(21) When making a determination that an

1962overpayment has occurred, the agency shall

1968prepare and issue an audit report to the

1976provider showing the calculation of

1981overpayments.

1982(22) The audit report, supported by agency

1989work papers, showing an overpayment to a

1996provider constitutes evidence of the

2001overpayment. . . .

200529. During the Audit Period, the applicable statutes,

2013laws, rules, and policy guidelines in effect required Respondent

2022to maintain all “Medicaid-related records” and information that

2030supported any and all Medicaid invoices or claims made by

2040Respondent during the Audit Period. Respondent was required, at

2049Petitioner’s request, to provide Petitioner with all Medicaid-

2057related records and other information that supported all the

2066Medicaid-related invoices or claims that Respondent made during

2074the Audit Period.

207730. Subsection 409.907(3)(c), Florida Statutes, dealing

2083with Medicaid provider agreements, required Petitioner to

2090maintain “all medical and Medicaid-related records for a period

2099of 5 years.” The stated purpose behind the five-year document-

2109retention requirement is so that Respondent “can satisfy all

2118necessary inquiries by Petitioner.”

212231. Subsection 409.907(3)(e), Florida Statutes, required

2128Respondent to allow Petitioner access to “all Medicaid-related

2136information which may be in the form of records, logs,

2146documents, or computer files, and other information pertaining

2154to the services or goods billed to the Medicaid program,

2164including access to all patient records. . . .”

217332. Subsection 409.913(7), Florida Statutes, imposed an

2180affirmative duty on Respondent to comply with all the

2189requirements set forth in its subparagraphs (a) through (f).

219833. Subsection 409.913(7)(f), Florida Statutes, imposed an

2205affirmative duty on Respondent to made sure that any claim for

2216goods and services are “documented by records made at the time

2227the goods and services were provided. . . .” This subsection

2238also imposed an affirmative duty on Respondent to make sure that

2249any and all records documenting Medicaid goods and services

2258demonstrate the “medical necessity for the goods and services

2267rendered.” This subsection further authorized Petitioner to

2274investigate, review, or analyze the records, including Medicaid-

2282related records, that Respondent was required to retain.

229034. The audit process that led to the claim for

2300overpayment was properly initiated by Petitioner in accordance

2308with Subsections 409.913(2), (20) and (21), Florida Statutes.

231635. A provider participating in the Medicaid program has

2325an affirmative duty to supervise and be responsible for the

2335preparation and submission of accurate claims for payment from

2344the program. It is the provider’s duty to ensure that all

2355claims “[a]re provided in accord with applicable provisions of

2364all Medicaid rules, regulations, handbooks, and policies.”

2371§ 409.913(7)(e), Fla. Stat.

237536. The Florida Administrative Code, as promulgated and

2383amended over the times material to this audit, specifically made

2393it a matter of law that the Florida Medicaid Physician Services

2404Coverage and Limitations Handbook and Florida Medicaid Provider

2412General Handbook are part of the Code governing all medical

2422service providers. Fla. Admin. Code R. 59G-4.001.

242937. Petitioner alleges improper and insufficient record-

2436keeping by a Medicaid mental health counseling provider. Where

2445records are insufficient to document the treatment billed, the

2454claims cannot be paid. Proper documentation of mental health

2463counseling visits, by law, must include a record of the time

2474spent with the patient, face-to-face.

247938. To be reimbursed for psychiatric counseling services,

2487Respondent, an ARNP, must keep a full medical record that

2497includes the time spent with the patient, pursuant to the

2507Florida Physician Services Coverage Handbook, January 2001.

251439. Respondent did not keep her records according to

2523Medicaid policy. She did not keep time records of patient

2533interactions in the patient chart as required by law.

254240. Medicaid providers must comply with all laws and rules

2552that pertain to the Medicaid Program and retain all medical and

2563Medicaid-related records for five years. These provisions are a

2572matter of both law and contract. § 409.907, Fla. Stat.

258241. Respondent, during the audit period, submitted claims

2590and was paid for mental health counseling visits, where there

2600was no indication of time spent face-to-face with the patient.

261042. The requirement to have the medical record set forth

2620the time spent with the patient is set forth in the ARNP

2632Services & Coverage Handbook. This is also required by CPT

26422004, 2005 and 2006. Medicaid handbooks are incorporated by

2651reference in Florida Administrative Code Rule 59G-4.010.

265843. Respondent failed to conform to the requirements, as

2667her records did not contain time components. The case analyst,

2677Gary Mosier, asked her to submit any contemporaneous time

2686records she might have, such as office appointment calendars or

2696patient sign-in/out sheets. With such contemporaneous data,

2703Petitioner could have verified and extrapolated the time spent

2712with patients. Respondent did not have them or supply them from

2723archives. Records of time with patients, billed to Medicaid,

2732are Medicaid-related records. All the audited conduct was

2740within this time frame. Respondent did not have the records;

2750instead, Respondent submitted a recently handwritten, non-

2757contemporaneous listing of how long she spent with the patients,

2767which she authored, by her own admissions, after the audit was

2778underway. This was insufficient under the statues and rules.

278744. Dr. Edgar, the expert peer reviewer, testified that

2796these lists were not medical chart materials. They were not

2806patient encounter time records. They did not indicate the

2815amount of time spent with the patient in therapy, recorded at

2826the time of the encounter, in the medical chart. The medical

2837chart data was insufficient under the law, policies or common

2847practice in the community.

285145. The records upon which Respondent based her billings

2860to Medicaid are deficient under law. The laws governing the

2870Medicaid programs required a finding that Respondent was

2878overpaid and that recoupment is an available remedy.

2886RECOMMENDATION

2887Based upon the above Findings of Fact and Conclusions of

2897Law, it is

2900RECOMMENDED that the Agency for Health Care Administration

2908enter a final order instructing Respondent to repay the sum of

2919$12,500.70, and imposing a fine if appropriate.

2927DONE AND ENTERED this 2nd day of March, 2010, in

2937Tallahassee, Leon County, Florida.

2941S

2942DANIEL M. KILBRIDE

2945Administrative Law Judge

2948Division of Administrative Hearings

2952The DeSoto Building

29551230 Apalachee Parkway

2958Tallahassee, Florida 32399-3060

2961(850) 488-9675

2963Fax Filing (850) 921-6847

2967www.doah.state.fl.us

2968Filed with the Clerk of the

2974Division of Administrative Hearings

2978this 2nd day of March, 2010.

2984ENDNOTE

29851/ All references to Florida Statutes are to Florida Statutes

2995(2006), unless otherwise indicated.

2999COPIES FURNISHED :

3002Constance Bence

30042588 West Socrum Loop Road

3009Lakeland, Florida 32810

3012L. William Porter, Esquire

3016Agency for Health Care Administration

30212727 Mahan Drive, Mail Station 3

3027Tallahassee, Florida 32308

3030Thomas W. Arnold, Secretary

3034Agency for Health Care Administration

3039Fort Knox Building, Suite 3116

30442727 Mahan Drive

3047Tallahassee, Florida 32308-5403

3050Justin Senior, General Counsel

3054Agency for Health Care Administration

3059Fort Knox Building, Suite 3431

30642727 Mahan Drive, Mail Stop 3

3070Tallahassee, Florida 32308-5403

3073Richard J. Shoop, Agency Clerk

3078Agency for Health Care Administration

30832727 Mahan Drive, Mail Stop 3

3089Tallahassee, Florida 32308-5403

3092NOTICE OF RIGHT TO SUBMIT EXCEPTIONS

3098All parties have the right to submit written exceptions within

310815 days from the date of this Recommended Order. Any exceptions

3119to this Recommended Order should be filed with the agency that

3130will issue the Final Order in this case.

Select the PDF icon to view the document.
PDF
Date
Proceedings
PDF:
Date: 10/16/2019
Proceedings: Agency Final Order filed.
PDF:
Date: 04/08/2010
Proceedings: Agency Final Order
PDF:
Date: 03/02/2010
Proceedings: Recommended Order
PDF:
Date: 03/02/2010
Proceedings: Recommended Order (hearing held July 19, 2007). CASE CLOSED.
PDF:
Date: 03/02/2010
Proceedings: Recommended Order cover letter identifying the hearing record referred to the Agency.
PDF:
Date: 07/01/2009
Proceedings: Findings of Fact, Conclusions of Law, Proposed Recommendations filed.
PDF:
Date: 05/06/2009
Proceedings: Undeliverable envelope returned from the Post Office.
PDF:
Date: 04/29/2009
Proceedings: Order Granting Extension of Time (proposed recommended order to be filed by July 1, 2009).
PDF:
Date: 04/28/2009
Proceedings: Respondent`s Unopposed Motion for Enlargement of Time filed.
PDF:
Date: 04/17/2009
Proceedings: State of Florida, Agency for Health Care Administration`s Closing Argument and Proposed Recommended Order filed.
PDF:
Date: 03/02/2009
Proceedings: Undeliverable envelope returned from the Post Office.
PDF:
Date: 02/23/2009
Proceedings: Order Granting Extension of Time (proposed recommended orders to be filed by May 1, 2009).
PDF:
Date: 02/16/2009
Proceedings: Joint Status Report filed.
PDF:
Date: 01/26/2009
Proceedings: Undeliverable envelope returned from the Post Office.
PDF:
Date: 12/19/2008
Proceedings: Order Continuing Case in Abeyance (parties to advise status by February 16, 2009).
PDF:
Date: 12/16/2008
Proceedings: Joint Status Report filed.
PDF:
Date: 07/21/2008
Proceedings: Order Continuing Case in Abeyance (parties to advise status by December 15, 2008).
PDF:
Date: 07/16/2008
Proceedings: Joint Status Report filed.
PDF:
Date: 03/24/2008
Proceedings: Order Continuing Case in Abeyance (parties to advise status by July 15, 2008).
PDF:
Date: 03/17/2008
Proceedings: Joint Status Report filed.
PDF:
Date: 12/06/2007
Proceedings: Order Continuing Case in Abeyance (parties to advise status by March 14, 2008).
PDF:
Date: 12/04/2007
Proceedings: Joint Status Report filed.
PDF:
Date: 11/14/2007
Proceedings: Undeliverable envelope returned from the Post Office.
PDF:
Date: 09/05/2007
Proceedings: Order Placing Case in Abeyance (parties to advise status by December 3, 2007).
PDF:
Date: 08/30/2007
Proceedings: Unopposed Motion to Hold Case in Abeyance filed.
Date: 08/01/2007
Proceedings: Transcript of Proceedings filed.
Date: 07/19/2007
Proceedings: CASE STATUS: Hearing Held.
PDF:
Date: 07/18/2007
Proceedings: Joint Stipulation as to Exhibits filed.
PDF:
Date: 07/17/2007
Proceedings: Petitioner`s Motion to Have Expert Appear at Hearing Telephonically filed.
PDF:
Date: 07/12/2007
Proceedings: Unilateral Pre-hearing Stipulation filed.
PDF:
Date: 07/12/2007
Proceedings: Amended Petitioner`s Witness and Exhibit List filed.
PDF:
Date: 07/11/2007
Proceedings: Respondent`s Witness and Exhibit List filed.
PDF:
Date: 07/09/2007
Proceedings: Amended Notice of Hearing by Video Teleconference (hearing set for July 19, 2007; 9:00 a.m.; Tampa and Tallahassee, FL; amended as to type of hearing).
PDF:
Date: 06/26/2007
Proceedings: Motion to Have Hearing by Video Teleconference filed.
PDF:
Date: 06/19/2007
Proceedings: Notice of Taking Sworn Statement filed.
PDF:
Date: 06/06/2007
Proceedings: Order of Pre-hearing Instructions.
PDF:
Date: 06/06/2007
Proceedings: Notice of Hearing (hearing set for July 19, 2007; 9:00 a.m.; Tallahassee, FL).
PDF:
Date: 03/01/2007
Proceedings: Notice of Service of Interrogatories, Expert Interrogatories, Request for Admissions & Request for Production of Documents filed.
PDF:
Date: 02/23/2007
Proceedings: Joint Response to Initial Order filed.
PDF:
Date: 02/12/2007
Proceedings: Initial Order.
PDF:
Date: 02/09/2007
Proceedings: Final Audit Report filed.
PDF:
Date: 02/09/2007
Proceedings: Request for an Informal Administrative Hearing filed.
PDF:
Date: 02/09/2007
Proceedings: Order Relinquishing Jurisdiction filed.
PDF:
Date: 02/09/2007
Proceedings: Notice (of Agency referral) filed.

Case Information

Judge:
DANIEL M. KILBRIDE
Date Filed:
02/09/2007
Date Assignment:
02/12/2007
Last Docket Entry:
10/16/2019
Location:
Tampa, Florida
District:
Middle
Agency:
Other
Suffix:
MPI
 

Counsels

Related DOAH Cases(s) (2):

Related Florida Statute(s) (8):

Related Florida Rule(s) (2):