Armando B. Figueroa, M.D.; Revocation of Registration, 40380-40382 [E8-15922]
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characterized by his criminal behavior
in issuing numerous fraudulent
prescriptions for such highly abused
controlled substances as oxycodone and
Percocet. While the record contains no
information as to whether under Utah
law and regulations, a physician can
ever lawfully prescribe a controlled
substance to a family member or
himself, it is clear that Respondent
issued numerous fraudulent
prescriptions because the prescriptions
were written in the names of persons
who had no medical need for the
controlled substance, and who were,
after filling the prescription, to turn the
drugs over to him.
Moreover, the stories that Respondent
told to induce others to assist him were
so implausible (e.g., that no doctor
would write a prescription for, or
perform surgery on, his wife) or were
consistent with classic scams engaged in
by persons who seek controlled
substances for illicit purposes (e.g., that
his wife’s prescription had been stolen
or lost down the drain), that it is clear
that the prescriptions were written with
fraudulent intent. See Randi M.
Germaine, 72 FR 51665, 61666 (2007)
(noting expert testimony regarding use
of scams by drug abusers seeking
additional drugs such as early refill
attempts and claiming that one’s drugs
have been stolen).
This conduct violated Federal law.
See 21 U.S.C. 843(a)(3) (rendering it
‘‘unlawful for any person knowingly or
intentionally * * * to acquire or obtain
possession of a controlled substance by
misrepresentation, fraud, forgery,
deception, or subterfuge’’); id. § 844(a)
(‘‘It shall be unlawful for any person
knowingly or intentionally to possess a
controlled substance unless such
substance was obtained directly, or
pursuant to a valid prescription or order
from a practitioner, while acting in the
course of his professional practice, or
except as otherwise authorized by this
subchapter * * *.’’). Indeed, it is
particularly disturbing that Respondent
was aided in his schemes by several
health care professionals.
There is also substantial evidence that
Respondent was personally abusing the
drugs he obtained through his various
schemes. The urinalysis results
indicated that Respondent was using
both hydrocodone and oxycodone.
Moreover, when one of the PA students
commented about his seeking
oxycodone, Respondent told her to
‘‘chill out,’’ because it was Percocet
with Tylenol. Moreover, when the
student commented about the strength
of the pills, Respondent stated that
‘‘you’d think if you double the strength
you get double effect, but that isn’t the
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case,’’ and also said that the 120 pills
‘‘would last him all year.’’ It is thus
clear that Respondent was once again
abusing controlled substances.
Respondent’s experience in
dispensing controlled substances and
his record of non-compliance with
Federal controlled substance laws is
thus characterized by his issuance of
numerous fraudulent prescriptions and
his personal abuse of controlled
substances. These findings amply
demonstrate that Respondent cannot be
entrusted with a new registration and
that granting his application would be
‘‘inconsistent with the public interest.’’
21 U.S.C. 823(f).
Order
Pursuant to the authority vested in me
by 21 U.S.C. 823(f), as well as 28 CFR
0.100(b) & 0.104, I order that the
application of Randall Relyea, D.O., for
a DEA Certificate of Registration as a
practitioner be, and it hereby is, denied.
This order is effective August 13, 2008.
Dated: June 27, 2008.
Michele M. Leonhart,
Deputy Administrator.
[FR Doc. E8–15923 Filed 7–11–08; 8:45 am]
BILLING CODE 4410–09–P
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
Armando B. Figueroa, M.D.;
Revocation of Registration
On November 14, 2007, I, the Deputy
Administrator of the Drug Enforcement
Administration, issued an Order to
Show Cause and Immediate Suspension
of Registration to Armando B. Figueroa,
M.D. (Respondent), of Washington, DC.
The Order immediately suspended and
proposed the revocation of
Respondent’s DEA Certificate of
Registration, BF0128810, as a
practitioner, on the grounds that his
continued registration was ‘‘inconsistent
with the public interest’’ and
‘‘constitute[d] an imminent danger to
public health and safety.’’ Show Cause
Order at 1 (citing 21 U.S.C. 823(f) &
824(a)(4)).
The Show Cause Order alleged that
Respondent had ‘‘repeatedly issued
controlled substance prescriptions to
[two individuals, S.S. and G.R.] for
other than a legitimate medical purpose
or while acting outside the usual course
of professional practice in violation of
21 CFR 1306.04(a).’’ Show Cause Order
at 1. More specifically, the Show Cause
Order alleged that on October 17, 2007,
law enforcement authorities had
searched a hotel room occupied by S.S.
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and found 500 dosage units of
oxycodone, 630 dosage units of
OxyContin, 400 dosage units of
methadone, 180 dosage units of
diazepam, and 30 dosage units of
phentermine. Id. at 2. The Order also
alleged that S.S. had in her possession
eleven undated prescriptions for
OxyContin and three prescriptions for
methadone which Respondent had
issued in the names of S.S. and G.R.,
two additional prescriptions for
Oxycontin issued by Respondent on
October 15, 2007 to S.S. and G.R., and
‘‘$7,475.00 in cash.’’ Id. Finally, the
Order alleged that S.S. told law
enforcement officers that she paid
Respondent $100 for each prescription
he issued and that Respondent had not
physically examined her in years. Id.
Based on the above, I found that
Respondent had ‘‘repeatedly issued
controlled substance prescriptions
outside the usual course of professional
practice, and for other than a legitimate
medical purpose, [and was] thereby
facilitating the diversion of controlled
substances.’’ Id. Accordingly, I further
found that Respondent’s ‘‘continued
registration during the pendency of
these proceedings would constitute an
imminent danger to public health and
safety,’’ and ordered the immediate
suspension of his registration. Id. (citing
21 U.S.C. 824(d)).
On November 14, 2007, DEA
Investigators served the Order to Show
Cause and Immediate Suspension 1 by
leaving it at Respondent’s office and
registered location. Later that same day,
Respondent telephoned a DEA
Investigator to complain about the
suspension of his registration.
Subsequently, DEA Investigators
learned that on the days that
Respondent worked at his Washington
office, Respondent stayed at his
daughter’s house. Accordingly, on
November 29, 2007, DEA Investigators
also delivered a copy of the Order to
Show Cause and Immediate Suspension
to Respondent’s daughter at her
residence.
Since the service of the Order to Show
Cause and Immediate Suspension,
neither Respondent, nor any one
purporting to represent him, has
requested a hearing. Because (1) more
than thirty days have passed since the
Order was served, and (2) no request for
a hearing has been received, I conclude
that Respondent has waived his right to
a hearing. See 21 CFR 1301.43(d). I
1 The Order also fully explained that Respondent
had a right to a hearing, the scheduled date of the
hearing, the procedures for requesting a hearing,
and that his failure to timely request a hearing
would be deemed a waiver of his right. Show Cause
Order at 2–3.
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therefore enter this Final Order without
a hearing based on relevant material
contained in the investigative file, see
id. 1301.43(e), and make the following
findings.
Findings
Respondent is the holder of DEA
Certificate of Registration, BF0128810,
which authorized him (before I
suspended the registration) to handle
controlled substances in schedules II
through V as a practitioner at his
registered location in Washington, DC.
Respondent’s registration does not
expire until September 30, 2010.
During 2007, a DEA Investigator (DI)
acquired physician prescribing profiles
from several Washington, DC area
pharmacies. The profiles showed that
Respondent was prescribing large
quantities of schedule II narcotic
controlled substances including
Percocet and OxyContin (80 mg), both of
which contain oxycodone. 21 CFR
1308.12(b)(1).2 Several pharmacists
advised that a large number of young
and seemingly healthy individuals were
presenting the prescriptions, that these
persons always paid cash for the
prescriptions, and that they were
traveling large distances to fill the
prescriptions.
In April 2007, an Inspector with the
South Carolina Bureau of Drug Control
notified the DI that G.R. and S.S., who
were residents of Conway, South
Carolina and who lived together, were
presenting to local pharmacies a large
number of prescriptions for OxyContin
and Percocet that were issued by
Respondent. The Inspector related that
when local pharmacists called
Respondent to verify the prescription,
Respondent would tell them to fill the
prescription without even waiting to
hear the patient’s name or the drug that
was prescribed. Moreover, most of the
prescriptions were paid for with cash.
The Inspector further advised that she
had obtained from area pharmacies
approximately 100 OxyContin
prescriptions which Respondent had
issued to S.S. between December 2005
and September 2006.
The DEA Investigator further
determined that S.S. and G.R. had
previously lived in La Plata, Maryland,
but had moved to South Carolina in
2001. S.S. would nonetheless make the
twelve-hour round trip from South
Carolina to Washington periodically to
obtain prescriptions from Respondent.
The investigation further showed that
while unemployment taxes had not
been paid on either S.S. or G.R. since
2 These drugs are typically prescribed to persons
in severe pain but are also highly abused.
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2001, between January 17 and October
16, 2007, S.S. and G.R. had paid a total
of more than $42,000 in cash to various
pharmacies in South Carolina and
Maryland to obtain oxycodone (80 mg),
OxyContin (80 mg), oxycodone/
acetaminophen (5/325 mg) and
methadone (40 mg), based on
prescriptions issued by Respondent.
The record further establishes that
OxyContin (80 mg) has a street value of
$70 to $80 a pill and that the total street
value of the OxyContin prescribed by
Respondent to S.S. and G.R. during this
period was between $352,800 and
$403,200.
On October 16, 2007, a Waldorf,
Maryland pharmacy contacted the DI
and informed her that S.S. had
presented a prescription for ninety
tablets of OxyContin (80 mg) issued by
Respondent. The DI asked the
pharmacist not to fill the prescription
and to tell S.S. to come back later.
The DI then contacted three other
Waldorf pharmacies which S.S. and
G.R. had previously used. At each of the
pharmacies, the DI was told that S.S.
had presented a prescription issued by
Respondent for 90 tablets of OxyContin
(80 mg). At two of the pharmacies, S.S.
had also told the pharmacists that she
would pay cash, notwithstanding that
the cost of the prescription was in
excess of $1,000, and would pick up the
prescription the following day. At the
third pharmacy, S.S. had already picked
up the prescription for which she paid
$1,134 in cash.
Thereafter, the DI requested the
assistance of narcotics officers with the
Charles County Sheriff’s Office to
conduct surveillance of S.S. The
Detectives agreed and went to one of the
pharmacies. There, they observed S.S.
arrive in a vehicle with South Carolina
license plates and enter the pharmacy.
The Detectives observed S.S. as she
picked up the prescription and paid for
it with $985.70 in cash. The Detectives
then followed S.S. to a local hotel,
which she entered. The Detectives
contacted the hotel and determined that
S.S. was scheduled to depart on October
19. The Detectives were also told that
S.S. had paid cash for her room.
The next day, the Detectives obtained
warrants to search S.S.’s hotel room and
vehicle, as well as to arrest her on state
charges of possession of Oxycontin with
intent to distribute and possession of a
control dangerous substance. Shortly
thereafter, the Detectives executed the
search warrants and arrested S.S.
The Detectives found that S.S had in
her possession $7,475 in cash, 500
dosage units of oxycodone/
acetaminophen (5/325 mg), 630 dosage
units of OxyContin (80 mg), 180 dosage
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40381
units of diazepam (10 mg), 30 dosage
units of phentermine (37.5 mg), six
dosage units of phentermine (30 mg),
and 400 dosage units of methadone.
Moreover, S.S. had in her possession
seventeen prescriptions from
Respondent, including fifteen which
were undated. Nine of the prescriptions
were in S.S.’s name; the other eight
were written in G.R.’s name.
Seven of S.S.’s prescriptions
(including six of the undated ones) were
for 90 tablets of OxyContin (80 mg); the
other two were for 120 tablets of
methadone (40 mg). Five of G.R.’s
prescriptions (including four of the
undated ones) were for 90 tablets of
OxyContin (80 mg), another prescription
was for 180 tablets of OxyContin (80
mg), and one was for 90 tablets of
methadone (40 mg).3
During the search, the Detectives
found in the trash numerous
prescription labels which had been torn
off the bottles. They also found a piece
of paper which according to S.S., was a
shopping list of the prescriptions that
she had sought from Respondent.
During a post-arrest interview, S.S.
stated that Respondent charges $100
cash for each prescription, that she had
purchased as many as twenty
prescriptions from him at a time, that
the prescriptions were not dated, and
that Respondent had not physically
examined her in years. She also stated
that she could not remember the last
time Respondent was examined by
Respondent and that G.R. rarely traveled
to Washington, DC. S.S. further stated
that she would call Respondent to order
the prescriptions and that she would
pay Respondent’s assistant; S.S. did not,
however, obtain a receipt. S.S. also
stated that Respondent was giving her
methadone because she was trying to
wean herself off of OxyContin.
Discussion
Section 304(a) of the Controlled
Substances Act provides that a
registration to ‘‘dispense a controlled
substance * * * may be suspended or
revoked by the Attorney General upon
a finding that the registrant * * * has
committed such acts as would render
his registration under section 823 of this
title inconsistent with the public
interest as determined under such
section.’’ 21 U.S.C. 824(a)(4). In making
the public interest determination, the
Act requires the consideration of the
following factors:
(1) The recommendation of the appropriate
State licensing board or professional
disciplinary authority.
3 The remaining prescription issued to G.R. was
for a non-controlled drug.
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(2) The applicant’s experience in
dispensing * * * controlled substances.
(3) The applicant’s conviction record under
Federal or State laws relating to the
manufacture, distribution, or dispensing of
controlled substances.
(4) Compliance with applicable State,
Federal, or local laws relating to controlled
substances.
(5) Such other conduct which may threaten
the public health and safety.
Id.
‘‘[T]hese factors are * * * considered
in the disjunctive.’’ Robert A. Leslie,
M.D., 68 FR 15227, 15230 (2003). I ‘‘may
rely on any one or a combination of
factors, and may give each factor the
weight [I] deem[] appropriate in
determining whether a registration
should be revoked.’’ Id. Moreover, I am
‘‘not required to make findings as to all
of the factors.’’ Hoxie v. DEA, 419 F.3d
477, 482 (6th Cir. 2005); see also Morall
v. DEA, 412 F.3d 165, 173–74 (D.C. Cir.
2005).4
Having considered all of the factors, I
conclude that the evidence under
factors two and four is dispositive and
establishes that Respondent has
committed acts which render his
continued registration ‘‘inconsistent
with the public interest.’’ 21 U.S.C.
824(a)(4). Accordingly, Respondent’s
registration will be revoked.
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Factors Two and Four—Respondent’s
Experience in Dispensing Controlled
Substances and Record of Compliance
With Applicable Laws
Under DEA regulations, a prescription
for a controlled substance is not
‘‘effective’’ unless it is ‘‘issued for a
legitimate medical purpose by an
individual practitioner acting in the
usual course of his professional
practice.’’ 21 CFR 1306.04(a). This
regulation further provides that ‘‘an
order purporting to be a prescription
issued not in the usual course of
professional treatment * * * is not a
prescription within the meaning and
intent of [21 U.S.C. 829] and * * * the
person issuing it, shall be subject to the
penalties provided for violations of the
provisions of law related to controlled
substances.’’ Id. As the Supreme Court
recently explained, ‘‘the prescription
requirement * * * ensures patients use
controlled substances under the
supervision of a doctor so as to prevent
addiction and recreational abuse. As a
corollary, [it] also bars doctors from
peddling to patients who crave the
drugs for those prohibited uses.’’
4 Under section 304(d), the ‘‘[t]he Attorney
General may, in his discretion, suspend any
registration simultaneously with the institution of
proceedings under this section, in cases where he
finds that there is an imminent danger to the public
health or safety.’’ 21 U.S.C. 824(d).
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Gonzales v. Oregon, 126 S.Ct. 904, 925
(2006) (citing Moore, 423 U.S. 122, 135
(1975)).
The evidence in this case
overwhelmingly demonstrates that
Respondent used his prescribing
authority to engage in the criminal
distribution of controlled substances in
violation of 21 U.S.C. 841. The
statements of S.S. and the evidence
uncovered in the course of the
investigation make plain that
Respondent was engaged in out-and-out
drug pushing and not the legitimate
practice of medicine.5
More specifically, at a single visit,
Respondent issued multiple
prescriptions for highly abused
schedule II controlled substances,
which were undated and thus in
violation of DEA regulations for this
reason as well. See 21 CFR 1306.05.6
Respondent did not examine S.S.; he
also issued multiple prescriptions in the
name of G.R., without even seeing him.
Finally, S.S. would purchase from
Respondent as many as twenty
prescriptions at a time and pay cash for
which no receipt was provided. In short,
Respondent’s conduct was not remotely
consistent with the legitimate practice
of medicine. Rather, it was drug
pushing.
I thus conclude that Respondent’s
experience in dispensing controlled
substances and his record of repeatedly
violating Federal law and regulations
make clear that his continued
registration ‘‘is inconsistent with the
public interest.’’ 21 U.S.C. 823(f).
Finally, for the same reasons which led
me to find that Respondent posed ‘‘an
imminent danger to the public health or
safety,’’ id. § 824(d), I conclude that the
public interest requires that his
registration be revoked effective
immediately and that any pending
applications be denied. See 21 CFR
1316.67.
Order
Pursuant to the authority vested in me
by 21 U.S.C. 823(f) & 824(a), as well as
28 CFR 0.100(b) & 0.104, I hereby order
that DEA Certificate Registration,
BF0128810, issued to Armando B.
Figueroa, M.D., be, and it hereby is,
revoked. I further order that any
pending application for renewal or
5 Given the evidence, this is not a case which
requires either expert testimony to support findings
regarding whether Respondent prescribed pursuant
to a valid doctor-patient relationship or an analysis
of state standards pertaining to the practice of
medicine. In short, Respondent’s conduct does not
remotely resemble the legitimate practice of
medicine.
6 The 80 mg strength is the second strongest
dosage unit of Oxycodone and typically has a street
value of $80 per tablet.
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modification of the registration be, and
it hereby is, denied. This order is
effective immediately.
Dated: July 2, 2008.
Michele M. Leonhart,
Deputy Administrator.
[FR Doc. E8–15922 Filed 7–11–08; 8:45 am]
BILLING CODE 4410–09–P
DEPARTMENT OF JUSTICE
Drug Enforcement Administration
[Docket No. 08–8]
Michael Chait, M.D.; Revocation of
Registration
On October 1, 2007, the Deputy
Assistant Administrator, Office of
Diversion Control, Drug Enforcement
Administration, issued an Order to
Show Cause to Michael Chait, M.D.
(Respondent), of Amagansett, New York.
The Show Cause Order proposed the
revocation of Respondent’s DEA
Certificate of Registration, BC2825151,
as a practitioner, and the denial of any
pending applications to renew or
modify his registration, on the ground
that Respondent is ‘‘not authorized to
handle controlled substances in New
York.’’ Show Cause Order at 1.
More specifically, the Show Cause
Order alleged that effective on May 25,
2007, the New York State Department of
Health, State Board for Professional
Medical Conduct, had, pursuant to an
interim non-disciplinary order of
conditions, prohibited Respondent from
the practice of medicine in the State of
New York. Id. The Show Cause Order
thus alleged that Respondent is ‘‘no
longer authorized to handle controlled
substances in New York, the state in
which’’ he maintains his DEA
registration. Id. The Show Cause Order
further alleged that Respondent ‘‘failed
to surrender [his] DEA Certificate of
Registration as required’’ under the
terms of the State Board’s order. Id.
Respondent requested a hearing on
the allegations and the matter was
assigned to Administrative Law Judge
(ALJ) Gail Randall. Thereafter, the
Government moved for summary
disposition on the ground that under the
terms of the State Board’s order,
Respondent was prohibited from
practicing medicine and thus could not
prescribe a drug. Gov. Mot. at 1–2. The
Government therefore argued that there
was no dispute that Respondent is not
authorized to handle controlled
substance in New York, the jurisdiction
in which he maintains his DEA
registration and that under Federal law,
‘‘DEA cannot register a practitioner to
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[Federal Register Volume 73, Number 135 (Monday, July 14, 2008)]
[Notices]
[Pages 40380-40382]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-15922]
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DEPARTMENT OF JUSTICE
Drug Enforcement Administration
Armando B. Figueroa, M.D.; Revocation of Registration
On November 14, 2007, I, the Deputy Administrator of the Drug
Enforcement Administration, issued an Order to Show Cause and Immediate
Suspension of Registration to Armando B. Figueroa, M.D. (Respondent),
of Washington, DC. The Order immediately suspended and proposed the
revocation of Respondent's DEA Certificate of Registration, BF0128810,
as a practitioner, on the grounds that his continued registration was
``inconsistent with the public interest'' and ``constitute[d] an
imminent danger to public health and safety.'' Show Cause Order at 1
(citing 21 U.S.C. 823(f) & 824(a)(4)).
The Show Cause Order alleged that Respondent had ``repeatedly
issued controlled substance prescriptions to [two individuals, S.S. and
G.R.] for other than a legitimate medical purpose or while acting
outside the usual course of professional practice in violation of 21
CFR 1306.04(a).'' Show Cause Order at 1. More specifically, the Show
Cause Order alleged that on October 17, 2007, law enforcement
authorities had searched a hotel room occupied by S.S. and found 500
dosage units of oxycodone, 630 dosage units of OxyContin, 400 dosage
units of methadone, 180 dosage units of diazepam, and 30 dosage units
of phentermine. Id. at 2. The Order also alleged that S.S. had in her
possession eleven undated prescriptions for OxyContin and three
prescriptions for methadone which Respondent had issued in the names of
S.S. and G.R., two additional prescriptions for Oxycontin issued by
Respondent on October 15, 2007 to S.S. and G.R., and ``$7,475.00 in
cash.'' Id. Finally, the Order alleged that S.S. told law enforcement
officers that she paid Respondent $100 for each prescription he issued
and that Respondent had not physically examined her in years. Id.
Based on the above, I found that Respondent had ``repeatedly issued
controlled substance prescriptions outside the usual course of
professional practice, and for other than a legitimate medical purpose,
[and was] thereby facilitating the diversion of controlled
substances.'' Id. Accordingly, I further found that Respondent's
``continued registration during the pendency of these proceedings would
constitute an imminent danger to public health and safety,'' and
ordered the immediate suspension of his registration. Id. (citing 21
U.S.C. 824(d)).
On November 14, 2007, DEA Investigators served the Order to Show
Cause and Immediate Suspension \1\ by leaving it at Respondent's office
and registered location. Later that same day, Respondent telephoned a
DEA Investigator to complain about the suspension of his registration.
Subsequently, DEA Investigators learned that on the days that
Respondent worked at his Washington office, Respondent stayed at his
daughter's house. Accordingly, on November 29, 2007, DEA Investigators
also delivered a copy of the Order to Show Cause and Immediate
Suspension to Respondent's daughter at her residence.
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\1\ The Order also fully explained that Respondent had a right
to a hearing, the scheduled date of the hearing, the procedures for
requesting a hearing, and that his failure to timely request a
hearing would be deemed a waiver of his right. Show Cause Order at
2-3.
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Since the service of the Order to Show Cause and Immediate
Suspension, neither Respondent, nor any one purporting to represent
him, has requested a hearing. Because (1) more than thirty days have
passed since the Order was served, and (2) no request for a hearing has
been received, I conclude that Respondent has waived his right to a
hearing. See 21 CFR 1301.43(d). I
[[Page 40381]]
therefore enter this Final Order without a hearing based on relevant
material contained in the investigative file, see id. 1301.43(e), and
make the following findings.
Findings
Respondent is the holder of DEA Certificate of Registration,
BF0128810, which authorized him (before I suspended the registration)
to handle controlled substances in schedules II through V as a
practitioner at his registered location in Washington, DC. Respondent's
registration does not expire until September 30, 2010.
During 2007, a DEA Investigator (DI) acquired physician prescribing
profiles from several Washington, DC area pharmacies. The profiles
showed that Respondent was prescribing large quantities of schedule II
narcotic controlled substances including Percocet and OxyContin (80
mg), both of which contain oxycodone. 21 CFR 1308.12(b)(1).\2\ Several
pharmacists advised that a large number of young and seemingly healthy
individuals were presenting the prescriptions, that these persons
always paid cash for the prescriptions, and that they were traveling
large distances to fill the prescriptions.
---------------------------------------------------------------------------
\2\ These drugs are typically prescribed to persons in severe
pain but are also highly abused.
---------------------------------------------------------------------------
In April 2007, an Inspector with the South Carolina Bureau of Drug
Control notified the DI that G.R. and S.S., who were residents of
Conway, South Carolina and who lived together, were presenting to local
pharmacies a large number of prescriptions for OxyContin and Percocet
that were issued by Respondent. The Inspector related that when local
pharmacists called Respondent to verify the prescription, Respondent
would tell them to fill the prescription without even waiting to hear
the patient's name or the drug that was prescribed. Moreover, most of
the prescriptions were paid for with cash. The Inspector further
advised that she had obtained from area pharmacies approximately 100
OxyContin prescriptions which Respondent had issued to S.S. between
December 2005 and September 2006.
The DEA Investigator further determined that S.S. and G.R. had
previously lived in La Plata, Maryland, but had moved to South Carolina
in 2001. S.S. would nonetheless make the twelve-hour round trip from
South Carolina to Washington periodically to obtain prescriptions from
Respondent. The investigation further showed that while unemployment
taxes had not been paid on either S.S. or G.R. since 2001, between
January 17 and October 16, 2007, S.S. and G.R. had paid a total of more
than $42,000 in cash to various pharmacies in South Carolina and
Maryland to obtain oxycodone (80 mg), OxyContin (80 mg), oxycodone/
acetaminophen (5/325 mg) and methadone (40 mg), based on prescriptions
issued by Respondent. The record further establishes that OxyContin (80
mg) has a street value of $70 to $80 a pill and that the total street
value of the OxyContin prescribed by Respondent to S.S. and G.R. during
this period was between $352,800 and $403,200.
On October 16, 2007, a Waldorf, Maryland pharmacy contacted the DI
and informed her that S.S. had presented a prescription for ninety
tablets of OxyContin (80 mg) issued by Respondent. The DI asked the
pharmacist not to fill the prescription and to tell S.S. to come back
later.
The DI then contacted three other Waldorf pharmacies which S.S. and
G.R. had previously used. At each of the pharmacies, the DI was told
that S.S. had presented a prescription issued by Respondent for 90
tablets of OxyContin (80 mg). At two of the pharmacies, S.S. had also
told the pharmacists that she would pay cash, notwithstanding that the
cost of the prescription was in excess of $1,000, and would pick up the
prescription the following day. At the third pharmacy, S.S. had already
picked up the prescription for which she paid $1,134 in cash.
Thereafter, the DI requested the assistance of narcotics officers
with the Charles County Sheriff's Office to conduct surveillance of
S.S. The Detectives agreed and went to one of the pharmacies. There,
they observed S.S. arrive in a vehicle with South Carolina license
plates and enter the pharmacy. The Detectives observed S.S. as she
picked up the prescription and paid for it with $985.70 in cash. The
Detectives then followed S.S. to a local hotel, which she entered. The
Detectives contacted the hotel and determined that S.S. was scheduled
to depart on October 19. The Detectives were also told that S.S. had
paid cash for her room.
The next day, the Detectives obtained warrants to search S.S.'s
hotel room and vehicle, as well as to arrest her on state charges of
possession of Oxycontin with intent to distribute and possession of a
control dangerous substance. Shortly thereafter, the Detectives
executed the search warrants and arrested S.S.
The Detectives found that S.S had in her possession $7,475 in cash,
500 dosage units of oxycodone/acetaminophen (5/325 mg), 630 dosage
units of OxyContin (80 mg), 180 dosage units of diazepam (10 mg), 30
dosage units of phentermine (37.5 mg), six dosage units of phentermine
(30 mg), and 400 dosage units of methadone. Moreover, S.S. had in her
possession seventeen prescriptions from Respondent, including fifteen
which were undated. Nine of the prescriptions were in S.S.'s name; the
other eight were written in G.R.'s name.
Seven of S.S.'s prescriptions (including six of the undated ones)
were for 90 tablets of OxyContin (80 mg); the other two were for 120
tablets of methadone (40 mg). Five of G.R.'s prescriptions (including
four of the undated ones) were for 90 tablets of OxyContin (80 mg),
another prescription was for 180 tablets of OxyContin (80 mg), and one
was for 90 tablets of methadone (40 mg).\3\
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\3\ The remaining prescription issued to G.R. was for a non-
controlled drug.
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During the search, the Detectives found in the trash numerous
prescription labels which had been torn off the bottles. They also
found a piece of paper which according to S.S., was a shopping list of
the prescriptions that she had sought from Respondent.
During a post-arrest interview, S.S. stated that Respondent charges
$100 cash for each prescription, that she had purchased as many as
twenty prescriptions from him at a time, that the prescriptions were
not dated, and that Respondent had not physically examined her in
years. She also stated that she could not remember the last time
Respondent was examined by Respondent and that G.R. rarely traveled to
Washington, DC. S.S. further stated that she would call Respondent to
order the prescriptions and that she would pay Respondent's assistant;
S.S. did not, however, obtain a receipt. S.S. also stated that
Respondent was giving her methadone because she was trying to wean
herself off of OxyContin.
Discussion
Section 304(a) of the Controlled Substances Act provides that a
registration to ``dispense a controlled substance * * * may be
suspended or revoked by the Attorney General upon a finding that the
registrant * * * has committed such acts as would render his
registration under section 823 of this title inconsistent with the
public interest as determined under such section.'' 21 U.S.C.
824(a)(4). In making the public interest determination, the Act
requires the consideration of the following factors:
(1) The recommendation of the appropriate State licensing board
or professional disciplinary authority.
[[Page 40382]]
(2) The applicant's experience in dispensing * * * controlled
substances.
(3) The applicant's conviction record under Federal or State
laws relating to the manufacture, distribution, or dispensing of
controlled substances.
(4) Compliance with applicable State, Federal, or local laws
relating to controlled substances.
(5) Such other conduct which may threaten the public health and
safety.
Id.
``[T]hese factors are * * * considered in the disjunctive.'' Robert
A. Leslie, M.D., 68 FR 15227, 15230 (2003). I ``may rely on any one or
a combination of factors, and may give each factor the weight [I]
deem[] appropriate in determining whether a registration should be
revoked.'' Id. Moreover, I am ``not required to make findings as to all
of the factors.'' Hoxie v. DEA, 419 F.3d 477, 482 (6th Cir. 2005); see
also Morall v. DEA, 412 F.3d 165, 173-74 (D.C. Cir. 2005).\4\
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\4\ Under section 304(d), the ``[t]he Attorney General may, in
his discretion, suspend any registration simultaneously with the
institution of proceedings under this section, in cases where he
finds that there is an imminent danger to the public health or
safety.'' 21 U.S.C. 824(d).
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Having considered all of the factors, I conclude that the evidence
under factors two and four is dispositive and establishes that
Respondent has committed acts which render his continued registration
``inconsistent with the public interest.'' 21 U.S.C. 824(a)(4).
Accordingly, Respondent's registration will be revoked.
Factors Two and Four--Respondent's Experience in Dispensing Controlled
Substances and Record of Compliance With Applicable Laws
Under DEA regulations, a prescription for a controlled substance is
not ``effective'' unless it is ``issued for a legitimate medical
purpose by an individual practitioner acting in the usual course of his
professional practice.'' 21 CFR 1306.04(a). This regulation further
provides that ``an order purporting to be a prescription issued not in
the usual course of professional treatment * * * is not a prescription
within the meaning and intent of [21 U.S.C. 829] and * * * the person
issuing it, shall be subject to the penalties provided for violations
of the provisions of law related to controlled substances.'' Id. As the
Supreme Court recently explained, ``the prescription requirement * * *
ensures patients use controlled substances under the supervision of a
doctor so as to prevent addiction and recreational abuse. As a
corollary, [it] also bars doctors from peddling to patients who crave
the drugs for those prohibited uses.'' Gonzales v. Oregon, 126 S.Ct.
904, 925 (2006) (citing Moore, 423 U.S. 122, 135 (1975)).
The evidence in this case overwhelmingly demonstrates that
Respondent used his prescribing authority to engage in the criminal
distribution of controlled substances in violation of 21 U.S.C. 841.
The statements of S.S. and the evidence uncovered in the course of the
investigation make plain that Respondent was engaged in out-and-out
drug pushing and not the legitimate practice of medicine.\5\
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\5\ Given the evidence, this is not a case which requires either
expert testimony to support findings regarding whether Respondent
prescribed pursuant to a valid doctor-patient relationship or an
analysis of state standards pertaining to the practice of medicine.
In short, Respondent's conduct does not remotely resemble the
legitimate practice of medicine.
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More specifically, at a single visit, Respondent issued multiple
prescriptions for highly abused schedule II controlled substances,
which were undated and thus in violation of DEA regulations for this
reason as well. See 21 CFR 1306.05.\6\ Respondent did not examine S.S.;
he also issued multiple prescriptions in the name of G.R., without even
seeing him. Finally, S.S. would purchase from Respondent as many as
twenty prescriptions at a time and pay cash for which no receipt was
provided. In short, Respondent's conduct was not remotely consistent
with the legitimate practice of medicine. Rather, it was drug pushing.
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\6\ The 80 mg strength is the second strongest dosage unit of
Oxycodone and typically has a street value of $80 per tablet.
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I thus conclude that Respondent's experience in dispensing
controlled substances and his record of repeatedly violating Federal
law and regulations make clear that his continued registration ``is
inconsistent with the public interest.'' 21 U.S.C. 823(f). Finally, for
the same reasons which led me to find that Respondent posed ``an
imminent danger to the public health or safety,'' id. Sec. 824(d), I
conclude that the public interest requires that his registration be
revoked effective immediately and that any pending applications be
denied. See 21 CFR 1316.67.
Order
Pursuant to the authority vested in me by 21 U.S.C. 823(f) &
824(a), as well as 28 CFR 0.100(b) & 0.104, I hereby order that DEA
Certificate Registration, BF0128810, issued to Armando B. Figueroa,
M.D., be, and it hereby is, revoked. I further order that any pending
application for renewal or modification of the registration be, and it
hereby is, denied. This order is effective immediately.
Dated: July 2, 2008.
Michele M. Leonhart,
Deputy Administrator.
[FR Doc. E8-15922 Filed 7-11-08; 8:45 am]
BILLING CODE 4410-09-P