In 2001, Bruce Frome, M.D., who practices in Beverly Hills, California, settled charges (shown below) negligently and incompetently treated three patients. The settlement agreement required him to pay $14,000 for costs and serve on probation for six years, during which he was required to participate in remedial education and have his practice monitored by another physician. He was also prohibited from administering nerve blocks or any invasive pain-control devices and, with minor exception, barred from using experimental or investigational therapies. One of the charges involved use of an unapproved diagnostic device that was not identified in the complaint.
BILL LOCKYER,
Attorney General of the State of California
JOSEPH P. FURMAN (State Bar No. 130654)
Deputy Attorney General
California Department of Justice
300 South Spring Street, Suite 5212
Los Angeles, California 90013
Telephone: (213) 897-2531
Attorneys for Complainant
BEFORE THE
DIVISION OF MEDICAL QUALITY
MEDICAL BOARD OF CALIFORNIA
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA
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In the Matter of the Accusation Against: BRUCE M. FROME, M.D. Physician and Surgeon’s Certificate No. G 8667,
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Case No. 17-95-48447 SECOND AMENDED ACCUSATION
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Complainant, Ron Joseph, alleges:
PARTIES
1. Complainant, Ron Joseph, is the Executive Director of the Medical Board of California (“Board”) and brings this Second Amended Accusation solely in his official capacity.
2. On or about July 8, 1963, Physician and Surgeon’s Certificate No. G 8667 was issued by the Board to Bruce M. Frome, M.D. (“respondent”), and at all times relevant to the charges brought herein, this license has been in full force and effect. Unless renewed, it will expire on August 31, 2002.
3. An Accusation in Case No. 17-95-48447 (“original Accusation”) was brought by Complainant in his official capacity as the Executive Director of the Board and, together with all statutorily required documents, was duly served on respondent on or about December 12, 1996. On or about September 7, 1999, an Amended Accusation, together with all statutorily required documents, was duly served on respondent. The Amended Accusation retained all the causes for license discipline alleged in the original Accusation filed in this matter, but also set forth additional causes for license discipline. The Amended Accusation therefore superseded and replaced the original Accusation on file in this matter. The Amended Accusation currently remains pending against respondent. Likewise, this Second Amended Accusation retains all the causes for license discipline alleged in both the original Accusation and the Amended Accusation filed in this matter, but also sets forth additional causes for license discipline. Accordingly, just as the Amended Accusation superseded and replaced the original Accusation on file in this matter, this Second Amended Accusation supersedes and replaces the Amended Accusation on file in this matter.
JURISDICTION
4. This Second Amended Accusation is brought before the Board’s Division of Medical Quality (“Division”), under the authority of the following sections of the California Business and Professions Code (“Code”):
A. Section 2220 provides, in pertinent part, that the Division may take action against all persons guilty of violating the Medical Practice Act.
B. Section 2227 provides that the Board may revoke, suspend for a period not to exceed one year, or place on probation and require the licensee to pay the costs of probation monitoring, the license of any licensee who has been found guilty under the Medical Practice Act.
C. Section 2234 provides, in pertinent part, that the Division shall take action against any licensee who is charged with unprofessional conduct, including “gross negligence,” “repeated negligent acts,” and “incompetence.”
D. Section 125.3, subdivision (a), provides, in pertinent part, that “the board may request the administrative law judge to direct a licentiate found to have committed a violation or violations of the licensing ad to pay a sum not to exceed the reasonable costs of the investigation and enforcement of the case.”
E. Section 14124.12 of the Welfare and Institutions Code provides, in pertinent part:
(a) Upon receipt of written notice from the Medical Board of California … that a licensee’s license has been placed on probation as a result of a disciplinary action, the department may not reimburse any Medi-Cal claim for the type of surgical service or invasive procedure that gave rise to the probation … that was performed by the licensee on or after the effective date of probation and until the termination of all probationary terms and conditions or until the probationary period has ended, whichever occurs first. This section shall apply except in any case in which [the Board] determines that compelling circumstances warrant the continued reimbursement during the probationary period of any Medi-Cal claim. . .. In such a case, the department shall continue to reimburse the licensee for all procedures, except for those invasive or surgical procedures for which the licensee was placed on probation.
FIRST CAUSE FOR DISCIPLINE
(Gross Negligence)
5. Respondent is subject to disciplinary action under Code section 2234, subdivision (b), in that he committed gross negligence in his care and treatment of patient D.CY The circumstances are as follows:
A. On or about July 8, 1994, patient D.C., accompanied by her husband, went to see respondent for the first time. D.C.1 appeared nervous and depressed. She complained of sores on her scalp, headaches, and fatigue. She and her husband informed respondent that she felt “sick all the time,” had lost weight, and had been to a number of other physicians who were unable to diagnose or treat her condition.
1To protect patient privacy, the patients will be referenced herein only by their initials. The full names of the patients will be disclosed to respondent upon his timely written request for discovery pursuant to Government Code section 11507.6.
B. During the July 8, 1994 office visit, respondent diagnosed D.C. as having hyperthyroidism. He based his diagnosis of hyperthyroidism on D.C.’s reported 20 pound weight loss, her nervousness, weakness, excessive sweating, and what he perceived as a “questionable enlargement of the thyroid gland on the right.” He requested no laboratory tests because he believed that D.C. had undergone extensive testing ordered by her previous physicians, which he assumed resulted in normal thyroid studies. He believed that D.C. did not want to undergo any further testing. Respondent then directed D.C. to take a “short-term course” of oral Iodine and Lysine Homeopathy “on a therapeutic trial basis” and to return in a week.
C. D.C. did not return to respondent’s office until she showed up without a scheduled appointment late in the day on August 16, 1994. When respondent entered the examination room, D.C. was curled up in the fetal position. Her husband was with her. D.C. was hyperventilating, and her pulse seemed irregular and rapid. D.C. indicated that she was depressed, unable to work, and experiencing marital difficulties. Based in part on the irregularity of D.C.’s pulse and the fact that she appeared short of breath and acutely ill, respondent diagnosed “subacute bacterial endocarditis and atrial fibrillation.” Respondent also hooked up the patient to a computer in his office, and the “computer results were in accordance with [his] personal diagnosis” of “subacute bacterial endocarditis and atrial fibrillation.”
D. Because it was after normal office hours and his staff had left or was just about to leave when respondent diagnosed “subacute bacterial endocarditis and atrial fibrillation” on August 16, 1994, respondent advised D.C. and her husband that the most prudent course of action would be to take D.C. to an emergency room to be fully examined. After D.C. or her husband indicated that D.C. was known to emergency room staff at Little Company of Mary Hospital, respondent telephoned a physician there to convey his impressions of D.C.’s condition, including his opinion that she was experiencing a cardiac arrhythmia, had a rapid, irregular pulse, and appeared to be weak and in some degree of distress. D.C.’s husband then drove her to the emergency room at Little Company of Mary Hospital.
E. After an examination by a cardiologist at the emergency room at Little Company of Mary Hospital and after further cardiological testing the following day, no cardiac abnormalities were found. Subsequent endocrinological testing revealed no thyroid abnormalities. D.C. was then referred for psychiatric and psychological evaluation, which resulted in diagnoses of, and treatment for, anxiety and depression.
F. Respondent is guilty of conduct constituting gross negligence in his care of D.C. in that:
(1) Respondent misdiagnosed the patient as having hyperthyroidism.
(2) Respondent failed to obtain or to use appropriate laboratory tests and laboratory data prior to diagnosing,·and commencing drug treatment for, hyperthyroidism.
(3) Respondent failed to evaluate fully and follow up adequately on his finding of a possible thyroid gland enlargement or nodule.
(4) Respondent misdiagnosed the patient as having subacute bacterial endocarditis and atrial fibrillation.
(5) Respondent failed to obtain or to use appropriate tests and data prior to diagnosing subacute bacterial endocarditis and atrial fibrillation.
(6) Respondent “hooked-up” the patient to an unproved and unapproved medical diagnostic “computer” device to assist him in making his diagnoses.
SECOND CAUSE FOR DISCIPLINE
(Gross Negligence)
6. Respondent is subject to disciplinary action under Code section 2234, subdivision (b), in that he committed gross negligence in his care and treatment of patient G.CH. The circumstances are as follows:
A. On or about September 22, 1993, patient G.C-H., then a 42 year old female, first saw respondent for treatment of her chronic pain. Respondent’s pain management practice at the time included implantation of spinal cord devices for treating chronic pain. G.C-H. sought respondent’s treatment for pain related to her diagnosis of Eosinophilia-Myalgia syndrome. Respondent diagnosed her condition as widespread and general polyneuropathy with a sympathetically maintained pain syndrome. G.C-H. received treatments consisting primarily of nerve blocks, including unilateral and bilateral stellate ganglion blocks, caudal nerve blocks, bilateral lumbar sympathetic blocks, and bilateral suprascapular nerve blocks.
B. Between approximately September 22, 1993, and October 12, 1993, respondent performed a total of approximately sixteen nerve blocks on G.H-C., either individually or in combination with other blocks.
C. On or about October 15, 1993, G.H-C. underwent a lumbar epidural catheter (DuPen catheter) implantation procedure for medication infusion. G.HC. appeared to experience improvement following both the nerve blocks and epidural medication infusion.
D. On or about November 8, 1993, G.H-C. was diagnosed as having a “tunnel” infection of the catheter. The catheter was removed on November 21, 1993.
E. On or about December 22, 1993, respondent performed a trial dorsal column stimulation on G.H-C., with reportedly good results.
F. On December 30, 1993, respondent performed a permanent spinal cord stimulator electrode and generator implantation procedure on G.H-C. Shortly following the procedure, G.H-C. developed paralysis, sensory deficit, and became febrile. A CT demonstrated an epidural abscess that required cervical and thoracic decompression laminectomies for evacuation and drainage on January 4, 1994.
G. Respondent is guilty of conduct constituting gross negligence in his care of G.H-C. in that:
(1) Respondent failed to maintain complete and adequate documentation of care, particularly with respect to the patient’s evaluation and diagnosis, the objective findings following nerve blocks, the treatment of the infection, and the details of patient’s trial spinal cord stimulation.
(2) Respondent failed to maintain complete and adequate documentation to support the use of multiple nerve blocks, epidural medications, and dorsal column stimulation.
(3) In light of respondent’s finding of “whole body polyneuropathy, fibromyalgia and sympathetically mediated pain” and the fact that a single-lead dorsal column stimulator at C7 to T2 level would be unlikely to provide relief to more than a single limb, let alone the entire body, respondent unreasonably subjected the patient to a procedure to implant a dorsal column stimulator because such an implanted stimulator had very little chance of improving the patient’s overall long-term prospects.
(4) Respondent failed to recognize or properly and fully eradicate an infection prior to proceeding with an implantation procedure into the infected site.
THIRD CAUSE FOR DISCIPLINE
(Gross Negligence)
7. Respondent is subject to disciplinary action under Code section 2234, subdivision (b), in that he committed gross negligence in his care and treatment of patient D.A. The circumstances are as follows:
A. Prior to her seeing respondent for the [lIst time in April 1993 for treatment of pain, patient D.A., then a 32 year old female, had the following medical history: D.A.’ s primary pain related medical condition apparently originated in August 1986, when, while running, her right heel and foot landed into a sprinkler recess. D.A. was initially evaluated at an emergency room and was informed that she sustained a fracture of the calcaneus. She was treated with casting and told to receive follow-up with an orthopedic surgeon in six weeks. Six weeks after the injury, D.A. received follow-up with an orthopedic surgeon. She was then informed that she did not suffer a fracture but was suffering from plantar fasciitis. D.A. was treated with conservative measures for four to five months. However, she did not improve. She was then referred to Philip Kwong, M.D., an orthopedic surgeon. D.A. underwent her first surgery which was a partial plantar fascial release in June 1987. Her pain did not improve. She was subsequently referred to Glen Almquist, M.D. She underwent additional surgery by Dr. Almquist in 1988. Despite rehabilitation, her pain did not improve. She then required crutches for ambulation. D.A. underwent repeat surgery for release of an apparently entrapped nerve in March 1989. There was also exploration for removal of retained sutures. However, D.A.’s condition did not improve. D.A. subsequently received additional surgery from Irwin Bliss, M.D., including removal of neuroma and tarsal tunnel releases. In all, D.A. underwent seven surgeries. Despite the surgeries, D.A. continued to complain of severe pain, swelling, and sensitivity of the right foot. D.A. also received an evaluation by a physician at the UCLA Medical Center for neck and shoulder pain. That physician found that D.A. was suffering from cervical disc disease at C2-3, but recommended conservative treatment. D.A. was then referred to Louis Kwong, M.D. Dr. Kwong recommended additional conservative treatments including physical therapy.
B. In addition to the above medical history, D.A. was also under the care of internist Ronald Sue, M.D., between April 1991 and September 1993. Dr. Sue’s records indicate that D.A. had additional medical problems including gastric reflux with subsequent reflux esophagitis, a history of chronic bronchitis,. and a history of vocal cord abnormalities. D.A. also had a history of high medication requirements, including oral Vicodin, episodes of mixing medications including Vicodin, benzodiazepines, and alcohol. D.A. also underwent a hospitalized detoxification in 1989.
C. On or about April 12, 1993, patient D.A. first saw respondent for treatment of pain primarily involving the right foot, but also involving the right knee, the right hip, the left foot, as well as bilateral neck and shoulder pain. Respondent’s pain management practice at the time included implantation of spinal cord devices for treating chronic pain. Respondent’s initial evaluation relied on D.A. ‘ s previous medical records, including an initial orthopedic evaluation from Louis Kwong, M.D., dated April 7, 1993, MRI reports of the cervical spine, right knee, and lumbar spine, as well as information reported by D.A. Respondent’s initial evaluation was reflex sympathetic dystrophy involving all limbs and stage 4 fibromyalgia.
D. During respondent’s care of D.A, she was administered a variety of treatment modalities including physical therapy, intravenous medications, oral medication including narcotics and non-narcotic analgesic adjunctive medication, physical manipulation of the involved extremities, transcutaneous electrical stimulation, and extensive invasive treatments including nerve injections. Respondent saw D.A. sometimes daily and most often on an every other day basis. During these treatment sessions, D.A. received numerous nerve blockade type of treatments, including caudal epidurals, lumbar sympathetic ganglion blocks, cervical epidurals, stellate ganglion blocks, and facet injections. At times, D.A. would receive multiple injections during the same visit, including bilateral sympathetic ganglion blocks, lumber sympathetic blocks, and lumbar epidural blocks. D.A. received at least one or a combination of injections at intervals ranging from daily to three times a week. D.A. reported short term relief after each treatment.
E. On or about May 24, 1993, respondent placed an epidural catheter for the purpose of intermittent lumbar sympathetic block. The patient received at least three epidural blocks. The catheter was removed on May 28, 1993.
F. On or about August 4, 1993, respondent placed an in-dwelling DuPen catheter in D.A. While the DuPen catheter was in, D.A. was given injections of epidural narcotic and anesthetic medications. Respondent also prescribed these same medications for home injection. D.A. was neither given instruction on sterile technique, nor was she supervised by professional health care personnel during these home injections.
G. On or about August 31, 1993, the catheter appeared curled following an epidurogram. Respondent decided to remove the catheter on September 2, 1993. During the course of attempting to remove the catheter, the catheter apparently became fixed. The catheter was cut and sutured in place to prevent further migration. A second thoracic DuPen catheter was placed. D.A. continued to receive treatment through this second catheter until the second catheter was removed at D.A. ‘ s request on or about September 24, 1993 because she reported no pain relief. D.A. then discontinued her treatment with respondent. She reported experiencing severe exacerbation of her back pain as a result of the retained epidural DuPen catheter.
H. Respondent is guilty of conduct constituting gross negligence in his care of D.A. in that:
(1) Following respondent’s placement of an in-dwelling DuPen catheter on August 4, 1993, respondent’s administration of medical treatment represented an extreme departure from the standard of care. Specifically, the number of multiple nerve injections was excessive. Sympathetic blockade of one extremity should be performed on a weekly basis and at most twice weekly in the case of early reflex sympathetic dystrophy or rapidly progressive reflex sympathetic dystrophy. Furthermore, multiple nerve injections including bilateral sympathetic ganglion blocks combined with epidural steroid injections and lumbar sympathetic ganglion blocks performed in combination with lumbar epidural blocks represents an extreme departure from the standard of care in light of the potential complications of bilateral stellate ganglion blocks. Performing bilateral stellate ganglion injections is extremely risky because of the severe potential complications, which include bilateral laryngeal nerve paralysis or paralysis of swallowing mechanisms causing possible aspiration pneumonia. In the case of D.A., this complication was exacerbated by a co-existing condition of reflux esophagitis. Respondent’s notes indicate that D.A. could have been experiencing aspiration pneumonitis, yet he persisted in performing bilateral stellate ganglion blocks with the possibility of temporary laryngeal nerve paralysis. In addition, bilateral sympathetic ganglion blocks could result in bilateral phrenic and vagal nerve paralysis, causing partial heart block with severe hypotension and even bilateral diaphragmatic paralysis causing difficulty breathing. Respondent failed to perform the bilateral stellate ganglion blocks on a staggered basis with the treatment separated by one to two hours to ensure that the first treatment did not cause either phrenic nerve or laryngeal nerve paralysis. Given D.A.’s history of gastroesophageal reflux, the performance of repeated bilateral sympathetic ganglion blocks represents an extreme departure from the standard of care.
(2) Following respondent’s placement of an in dwelling DuPen catheter on August 4, 1993, respondent failed to instruct D.A. in the proper care and management of the externalized DuPen epidural catheter. Respondent also failed to instruct regarding the proper sterile technique to be followed during the injection of this catheter. Respondent further failed to ensure that D.A. was supervised by trained health care personnel during the self-administration of medications which are potent and can cause hypotension resulting in death.
Furthermore, non-sterile use of these medications could cause epidural abscess and paralysis. The prescription of narcotic, analgesic,. and potent anesthetic medications for self-administration of intermittent boluses into the epidural space without proper medical supervision or prior training represents an extreme departure from the standard of medical practice.
(3) Respondent failed to maintain complete and adequate documentation of care, particularly with respect to his communication with other treating physicians. Specifically, during the course of his treatment of d.a., respondent failed to document any communications with Dr. Sue or Drs. Kwong, despite the fact that respondent’s treatment was multi-disciplinary and included treatment for other conditions such as esophagitis and chronic bronchitis. Respondent did not document any attempt to obtain any diagnostic information or other treatment information from Dr. Sue. Respondent also did not document conveying other pertinent laboratory information, including abnormal liver functions tests, to Dr. Sue.
(4) Respondent failed to obtain written consent from D.A. to perform the treatments.
FOURTH CAUSE FOR DISCIPLINE
(Repeated Negligent Acts)
8. Respondent is subject to disciplinary action under Code section 2234, subdivision (c), in that he committed repeated negligent acts in his care and treatment of patients D.C., G.C-H, and D.A .. The circumstances are as follows:
A. The facts and allegations set forth above under paragraphs 5, 6, and 7, and all subparagraphs thereunder, are incorporated here by reference.
B. Respondent committed repeated negligent acts in his care and treatment of patients D.C., G.C-H., and D.A. in that respondent committed the acts and omissions enumerated below:
Specifically, in connection with his care and treatment of patient D.C.:
(1) Respondent misdiagnosed the patient as having hyperthyroidism.
(2) Respondent failed to obtain or to use appropriate laboratory
tests and laboratory data prior to diagnosing, and commencing drug treatment for, hyperthyroidism.
(3) Respondent failed to evaluate fully and follow up adequately on his finding of a possible thyroid gland enlargement or nodule.
(4) Respondent misdiagnosed the patient as having subacute bacterial endocarditis and atrial fibrillation.
(5) Respondent failed to obtain or to use appropriate tests and data prior to diagnosing subacute bacterial endocarditis and atrial fibrillation.
(6) Respondent “hooked-up” the patient to an unproved and unapproved medical diagnostic “computer” device to assist him in making his diagnoses.
Specifically, in connection with his care and treatment of patient G.C-H.:
(7) Respondent failed to maintain complete and adequate documentation of care, particularly with respect to the patient’s evaluation and diagnosis, the objective findings following nerve blocks, the treatment of the infection, and the details of patient’s trial spinal cord stimulation.
(8) Respondent failed to maintain complete and adequate documentation to support the use of multiple nerve blocks, epidural medications, and dorsal column stimulation.
(9) In light of respondent’s finding of “whole body polyneuropathy, fibromyalgia and sympathetically mediated pain” and the fact that a single-lead dorsal column stimulator at C7 to T2 level would be unlikely to provide relief to more than a single limb, let alone the entire body, respondent unreasonably subjected the patient to a procedure to implant a dorsal column stimulator because such an implanted stimulator had very little chance of improving the patient’s overall long-term prospects.
(10) Respondent failed to recognize or properly and fully eradicate an infection prior to proceeding with an implantation procedure into the infected site.
Specifically, in connection with his care and treatment of patient D.A.:
(11) Following respondent’s placement of an in-dwelling DuPen catheter on August 4, 1993, respondent’s administration of medical treatment represented an extreme departure from the standard of care. Specifically, the number of multiple nerve injections was excessive. Sympathetic blockade of one extremity should be performed on a weekly basis and at most twice weekly in the case of early reflex sympathetic dystrophy or rapidly progressive reflex sympathetic dystrophy. Furthermore, multiple nerve injections including bilateral sympathetic ganglion blocks combined with epidural steroid injections and lumbar sympathetic ganglion blocks performed in combination with lumbar epidural blocks represents an extreme departure from the standard of care in light of the potential complications of bilateral stellate ganglion blocks. Performing bilateral stellate ganglion injections is extremely risky because of the severe potential complications, which include bilateral laryngeal nerve paralysis or paralysis of swallowing mechanisms causing possible aspiration pneumonia. In the case of D.A., this complication was exacerbated by a co-existing condition of reflux esophagitis. Respondent’s notes indicate that D.A. could have been experiencing aspiration pneumonitis, yet he persisted in performing bilateral stellate ganglion blocks with the possibility of temporary laryngeal nerve paralysis. In addition, bilateral sympathetic ganglion blocks could result in bilateral phrenic and vagal nerve paralysis, causing partial heart block with severe hypotension and even bilateral diaphragmatic paralysis causing difficulty breathing. Respondent failed to perform the bilateral stellate ganglion blocks on a staggered basis with the treatment separated by one to two hours to ensure that the first treatment did not cause either phrenic nerve or laryngeal nerve paralysis. Given D.A.’s history of gastroesophageal reflux, the performance of repeated bilateral sympathetic ganglion blocks represents an extreme departure from the standard of care.
(12) Following respondent’s placement of an in dwelling DuPen catheter on August 4, 1993, respondent failed to instruct D.A. in the proper care and management of the externalized DuPen epidural catheter. Respondent also failed to instruct regarding the proper sterile technique to be followed during the injection of this catheter. Respondent further failed to ensure that D.A. was supervised by trained health care personnel during the self-administration of medications which are potent and can cause hypotension resulting in death. Furthermore, non-sterile use of these medications could cause epidural abscess and paralysis. The prescription of narcotic, analgesic, and potent anesthetic medications for self-administration of intermittent boluses into the epidural space without proper medical supervision or prior training represents an extreme departure from the standard of medical practice.
(13) Respondent failed to maintain complete and adequate documentation of care, particularly with respect to his communication with other treating physicians. Specifically, during the course of his treatment of d.a., respondent failed to document any communications with Dr. Sue or Drs. Kwong, despite the fact that respondent’s treatment was multi-disciplinary and included treatment for other conditions such as esophagitis and chronic bronchitis. Respondent did not document any attempt to obtain any diagnostic information or other treatment information from Dr. Sue. Respondent also did not document conveying other pertinent laboratory information, including abnormal liver functions tests, to Dr. Sue.
(14) Respondent failed to obtain written consent from D.A. to perform the treatments.
FIFTH CAUSE FOR DISCIPLINE
(Incompetence)
9. Respondent is subject to disciplinary action under Code section 2234, subdivision (d), in that he performed incompetently in his care and treatment of patients D.C., G.C-H., and D.A. The circumstances are as follows:
A. The facts and allegations set forth above under paragraphs 5, 6, 7, and 8, and all subparagraphs thereunder, are incorporated here by reference.
B. Respondent is guilty of incompetence in his care and treatment of patients D.C., G.C-H., and D.A. in that respondent committed the acts and omissions enumerated above under paragraph 8, subparagraph B, which acts and omissions are incorporated here by reference.
PRAYER
WHEREFORE, complainant requests that a hearing be held on the matters herein alleged and that, following the hearing, the Division issue a decision:
1. Revoking or suspending Physician and Surgeon’s Certificate Number G 8667, heretofore issued to respondent Bruce M. Frome, M.D.;
2. Revoking, suspending, or denying approval of respondent’s authority to supervise physician’s assistants, pursuant to Business and Professions Code section 3527;
3. Ordering respondent to pay the Division the actual and reasonable costs of the investigation and enforcement of this case, and, if placed on probation, the costs of probation monitoring; and
4. Taking such other and further action as the Division deems necessary and proper.
DATED: August 1, 2000.
____________________________
Ron Joseph
Executive Director
Medical Board of California
Department of Consumer Affairs
State of California
Complainant
This page was posted on March 18, 2008.
