maryka?'1erine · 2019-05-21 · 4.1 dr. liu presented an application for a license to...

IN THE MATTER OF:

STATE OF TENNESSEE DEPARTMENT OF HEAL TH

BEFORE THE TENNESSEE ) ) ) ) ) ) ) ) )

BOARD OF MEDICAL EXAMINERS XIANGXIA LIU, M.D. PETITIONER

GERMANTOWN, TN

PETITION FOR DECLARATORY ORDER

DOCKET NO.: 17.18- 158175A

NOTICE OF FILING

The State of Tennessee, by and through the Office of General Counsel, hereby files the

attached Petition for Declaratory Order which was intended as Exhibit A to the previousl~led (_/ ) C';:)

rc1 -·-C) -..t:>

Notice of Hearing, but inadvertently omitted. ::::o ::?:: 1 ! , =~ ~~ :;:,- N (";) ::n O r·-i-; --<

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Respectfully submitted this the;;((::,~ day of May, 2019. c.:-_,

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MaryKa?'1erine Bratton, BPR # 030083 Chief Deputy General Counsel Tennessee Department of Hea lth Office of General Counsel 665 Mainstream Drive Second Floor Nashville, Tennessee 37243 (615) 741-1611

.... __ ..

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of this document has been

served upon Respondent, Xiangxia Liu, M.D. , through Respondent's counsel, James C. Bradshaw,

III, Wyatt, Tarrant & Combs, LLP, 333 Commerce Street, Suite 1400, Nashville, TN 37201 by

delivering the same 111 the United States Mail, Certified Number

101(q~Q()QCOC)(o%11o]d- , return receipt requested , and United States First Class Postage

Pre-Paid Mail, with sufficient postage thereon to reach its destination.

~ This ~ \ day of ~ , 201l.

Maryl(herine Bratton Chief Deputy General Counsel Tennessee Department of Health

BEFORE THE TENNESSEE BOARD OF MRDTCAL EXAMINERS

IN THE MATTER OF: ) ) ) ) ) )

XTANGXTA UU, M.D., Case No: ______ _

1.

2.

3.

Petitioner.

PETITION FOR DECLARATORY ORDER

Petitioner's Name: Address:

Telephone Number: Email:

Petitioner's Attorney's Name: Address:

Telephone Number: Email:

Xiangxia Liu, M.D. 7950 Farnifold Dr., Apt 3 Germantown, TN 38138 (901) 448-1350 [email protected]

James C. Bradshaw III Wyatt, Tarrant & Combs, LLP 333 Commerce Street, Suite 1400 Nashville, TN 37201 (615) 244-0020 / (615) 251-6683 direct j [email protected]

Organization, if any, that Petitioner Represents:

None/Not Applicable

4. Statement of Facts:

4.1 Dr. Liu presented an application for a license to practice medicine in the State of

Tennessee to the Tennessee Board of Medical Examiners ('TBME" or the "Board") in January

of 2019. (See attached Exhibit A.)

4.2 By letter dated February 11, 2019, the Board responded to Dr. Liu's application

with a request for a personal interview on March 19, 2019. (See attached Exhibit B).

4.3 The letter states that the interview is a prerequisite for licensure because Dr. Liu

has "no ACGME residency training and [is] not ABMS Board Certified". (Id.)

61819536.2

4.4 On March 19, 2019, Dr. Liu appeared before the Board for a personal interview,

at which time the Board tabled his application to allow him to file a Petition for Declaratory

Order requesting that the Board find his fellowship program to be an equivalent to the training

required under T.C.A. §63-7-207(a)(2)(F).

4.5 Dr. Liu has applied for a Tennessee medical license under T.C.A. § 63-6-

207(a)(2) and the provisions of TBME Rule 0880-02-.04, which detail the medical licensure

process for international medical school graduates. Dr. Liu has provided all information required

to meet each element of the statute and regulatory rule. In particular, Rule 0880-02-.04(5)

requires that the applicant "submit evidence satisfactory to the Board of successful completion of

a three (3) year residency program approved by the American Medical Association or its extant

accreditation program for medical education or its successor," to include "a notarized certificate

of completion and a letter attesting to satisfactory completion issued by the director of the

program which shows that the residency was completed in one (1) discipline."

4.6 As demonstrated by the documentation provided in Collective Exhibit C and D,

attached hereto, Dr. Liu has met and exceeded this requirement. See Collective Exhibits C and

D, which includes: (I) certified copy of a Certificate of Faithful and Satisfactory Completion of a

fellowship as a Fellow in Pediatric Craniofacial Surgery from The University of Tennessee

Health Science Center College of Medicine, from July l, 2016 to June 30, 2017; (2) ce1iified

copy of a Certificate of Fellowship Training as a Fellow in the Burn Surgery Program from The

University of Tennessee Health Science Center College of Medicine, from July 1, 2017 to June

30, 2018 (Collective Exhibit C); and (3) a letter of recommendation from Dr. Robe1i Wallace,

Professor and Chair of the Department of Plastic Surgery at the University of Tennessee Health

Science Center College of Medicine evidencing Dr. Liu's current participation in and anticipated

2

successful completion of a one (I) year fellowship in Microsurgery at the University of

Tennessee Health Science Center College of Medicine in June of2019 (Collective Exhibit D).

4. 7 Rule 0880-02-.04(5) also provides that an applicant who holds a specialty board

certification may be deemed to have satisfied the aforementioned residency requirement "if the

specialty board is recognized and is a member of the American Board of Medical Specialties."

There is no specialty board certification available to Dr. Liu in his chosen specialty of plastic

surgery, rendering the "deeming" language of Rule 0880-02- .04(5) not applicable to this

Petition. The Board's rules do not require specialty board certifica_tion, although Dr. Liu was

certified as a master of plastic and reconstructive surgery in China, his country of origin, in July

of 2003.

5. Requested Relief. Dr. Liu respectfully requests that the Board grant this Petition,

convene a contested case hearing and, upon presentation of evidence and testimony from Dr. Liu

and his witnesses, find that Dr. Liu has met the criteria under its Rule 0880-02-.04, and

accordingly, issue Dr. Liu a license to practice medicine in the State of Tennessee.

6. Citation to Statute, Rule, or Order That is the Subject of this Petition.

6.1 Board Ruic 0880-02-.07(4) provides: "Any applicant who has successfully

complied with all requirements of the rules governing the licensure ... process for the type of

licensure ... applied for shall be issued a license ... to practice medicine in Tennessee," with

certain exceptions.

6.2 The Board has requested more information in support of Dr. Liu's application for

a Tennessee medical license because he has "no residency training." (Exhibit B).

6.3 The Policies and Procedures of The Accreditation Council for Graduate Medical

Education (ACGME) apply to the broad continuum of education and training programs available

3

to physicians following undergraduate medical education and embraces residencies and

fellowships. (ACGME Policies and Procedures, February 6, 2016). The ACGME defines

"graduate medical education" as a "period . of didactic and clinical education in a medical

specialty following undergraduate medical education and which prepares physicians for the

independent practice of medicine in that specialty." (ACGME Glossary of Terms, July 1, 2013).

A "Residency" is defined as "a program accredited to provide a structured educational

experience designed to conform to the Program Requirements of a particular specialty." (Id.) A

"Resident" is defined as "any physician in an accredited graduate medical education program,

including interns, residents and fellows." (Id.) The ACGME defines "Fellowship"

interchangeably with "Subspccialty Program" and "Fellow" interchangeably with "Subspecialty

Resident." (Id.)

6.4 Since successfully completing medical school, becoming licensed to practice

medicine and obtaining a specialty certification in plastic and reconstructive surgery in China,

Dr. Liu has engaged in a significant course of subspecialty training in plastic surgery in the

United States, including a 12 month fellowship in Craniofacial Surgery, a 12 month fellowship in

Burn Surgery, and a 12 month fellowship in Microvascular Surgery, all from the Department of

Plastic Surgery at the University of Tennessee Health Science Center College of Medicine.

6.5 Dr. Liu respectfully submits that his post-graduate education and training in U.S .

ACGME accredited programs meets or exceeds the educational and training criteria under the

statute and the Board's Rules. Dr. Liu, therefore, respectfully petitions the Board under Rule

0880-02-.11 (7) and Division of Health Related Boards Rule 1200-10-01-.11 for a Declaratory

Order finding compliance with all requirements and granting his application for a Tennessee

Medical License.

4

6.6 Dr. Liu has completed 3 years of post-graduate training in sub-specialty medical

fellowships at the University of Tennessee Health Science Center College of Medicine m

addition to the extensive experience and training he received in China before moving to

Tennessee. Dr. Liu respectfully submits that having met all requirements for issuance of a

medical license, and absent any contrary finding by the Board, the Board should grant his

application and issue him a medical license forthwith under Board Rule 0880-02-.07( 4).

7. Effect on Dr. Liu of Board's Failure to Issue License. Dr. Liu is applying for a

Tennessee medical license because he is under consideration for a position in the Department of

Plastic Surgery at the University of Tennessee Health Science Center College of Medicine,

where he will fill an important role focusing on microsurgery and burns per Dr. Robe1i Wallace,

the Chair of UTHSC's Department of Plastic Surgery (Exhibit D). According to Dr. Wallace,

this is an area of the specialty that is "extremely difficult" to fill at the faculty level and there is a

need for a surgeon of his training and skill at UTHSC. Id. Dr. Liu will be unable to apply for or

fill that position unless and until he is issued a license to practice medicine in the State of

Tennessee.

WHEREFORE, Petitioner Xiangxia Liu, M.D. respectfully requests that the Board grant

this Petition for Declaratory Order and convene a contested case hearing at its May 2019 meeting

for the purpose of hearing proof from Dr. Liu that will establish his compliance with the

requirements for issuance of a medical license in Tennessee.

Respectfully submitted,

Xiangxia. Liu, M.D. March J..!, 2019

5

~-- -· ·-----·-· ···-· ---•··· •···· ·· .. ··· ········ · ···· · ·-·· ··.-- ·.····•·•· .• . ··--· ········- ·· ·· ·• ···· ···· · · ··- .-. . ·. •- ... ..... "' ---~·. ·.· ··• -.·· • · · • .. · • ··- .. · · .. -----

-- . - - ~ 7 --- . - . . . Jar cs C. Bradshaw III, BPR 13170 W ATT, TARRANT & COMBS, LLP 33. Commerce Street, Suite 1400 Na wille, Tennessee 37201 615 44.0020 / Facsimile: 615.256.1726 jbra ,"haw@_wyattfinn.com

Counsel for Petitioner

CERTIFICATE OF SERVICE

I hereby certify that the foregoing document was sent via hand delivery on this the 19th

day of March, 2019 to:

Mary Katherine Bratton Chief Deputy General Counsel Office of General Counsel Tennessee Department of Health 220 Athens Way, Suite 210 Nashville, Tennessee 37243

61819536.2

~ Jam t C. Bradshaw III

6

1/12/19 9:55 AM

Application Detail

License Type:

Application Summary

Medical Doctor

Page 1 of 7

Application: Medical Doctor: Initial International Graduate Application

Application Date: 01/12/2019 (mm/dd/yyyy)

Application Questions

Do you currently have any physical or No psychological limitations or impairments caused by an existing medical condition which are reduced or ameliorated by ongoing treatment or monitoring , or the field of practice, the setting or the manner in which you have chosen to practice?

At any time within the past two years, have No you engaged in the illegal use of illicit or controlled substances?

Are you currently participating in a No supervised rehabilitation program or professional assistance program that monitors you to assure that you do not consume alcohol and/or do not engage in the illegal use of illicit or controlled substances?

Have you ever been diagnosed as having or No have you ever been treated for pedophilia, exhibitionism, voyeurism or other diagnosis of a predatory nature?

Have you ever held or applied for a license, No privilege, registration or certificate to practice medicine in any state, country, or province, that has been or was ever denied, reprimanded, suspended, restricted, revoked, otherwise disciplined, curtailed, or voluntarily surrendered under threat of investigation or disciplinary action?

Have you ever had staff privileges at any No hospital or health care facility that were ever revoked, suspended, curtailed, restricted, limited, otherwise disciplined, or voluntarily surrendered under threat of restriction or disciplinary action?

EXHIBIT A

~/12/199:55AM Page2of7

Have you ever applied for or held a state or No federal controlled substance certificate that was ever denied, revoked, suspended, restricted, voluntarily surrendered or otherwise disciplined or surrendered under threat of restriction or disciplinary action?

Have you ever been convicted (including a No nolo contendere plea or guilty plea) of a felony or misdemeanor (other than a minor traffic offense) whether or not sentence was imposed or suspended?

Have you ever been rejected or censured by No a professional association or society?

In relation to the performance of your No professional services in any profession: Have you ever had a final judgment rendered against you?

In relation to the performance of your No professional services in any profession: Have you ever entered into any settlement of any legal action?

In relation to the performance of your No professional services in any profession: Are there any legal actions pending against you or to which you are a party?

Have you ever held a license, registration, No privilege or certificate in any profession that has ever been reprimanded, suspended, restricted, revoked, otherwise disciplined, curtailed, or voluntarily surrendered under threat of investigation or disciplinary action in any jurisdiction?

My name has been placed on the registry of No persons who have abused, neglected or misappropriated the property of vulnerable individuals (Tennessee abuse registry or an abuse registry in another state)?

Personal Detail

First Name:

Last Name:

Professional Qualifier:

Birth date:

XIANGXIA

LIU

MD

08/04/1978 (mm/dd/yyyy)

1/12/19 9:55 AM

Gender:

Race:

Social Security Number:

Addresses

Mailing Address Address:

Phone Number:

Extension:

E-mail Address:

License Attributes Selected

Specialty

General Information

Male

Asian/P.I.

*********

7950 Farnifold Dr. APT3

SHELBY

Germantown, TN

38138

us

650-469-2155

[email protected]

Plastic Surgery

Have you been known by any other names? No

Are you a U. S. Citizen? No

Are you entitled to live or work in the US? Yes

Are you a member of the U.S. armed forces No who has, within the preceding 180 days, retired from the armed forces, received any discharge other than a dishonorable discharge from the armed forces, or been released from active duty to a reserve component of the armed forces? (If yes, please provide proof of status.)

Are you the spouse of a member of the No armed forces who has been transferred by the military to Tennessee or who has, within the preceding 180 days, retired from the armed forces, received a discharge other than a dishonorable discharge from the armed forces or been released from active

Page 3 of 7

:1/12/19 9:55 AM

duty to a reserve component? (If yes, please provide proof of same.)

Type of intended primary specialty practice in Tennessee:

Have you previously applied for a medical license in Tennessee?

Educational Information

Name of educational institution attended:

City:

State:

Other, please specify:

Degree/certificate earned:

Program Major:

Start date of education program:

Completion date of education program:

Graduation date of education program:

Postgraduate Training History 1

Educational Institution where you completed your postgraduate training:

City where the postgraduate training was completed:

State or Country were the postgraduate training was completed:

Date Started:

Date Ended:

Specify the total number of years you have spent in postgraduate medical training:





Page 4 of 7

Plastic Surgery

No

Sun Yat-sen Uni of Medical Sci

Guangzhou

Other, please specify

Guangdong, China

BM

Clinical Medicine

09/04/1996 (mm/dd/yyyy)

07/04/2001 (mm/dd/yyyy)

07/04/2001 (mm/dd/yyyy)

University of Tennessee Health Science Center, Department of Plastic Surgery

Memphis

Tennessee

07/01/2016 (mm/dd/yyyy)

06/30/2019 (mm/dd/yyyy)

1


Memphis

Tennessee

,1/12/19 9:55 AM


Date Started:

Date Ended:


07/01/2017 (mm/dd/yyyy)

06/30/2018 (mm/dd/yyyy)

1

Page 5 of 7






Date Started:

Date Ended:


Employment Information

Memphis

Tennessee

07/01/2018 (mm/dd/yyyy)

06/30/2019 (mm/dd/yyyy)

1

Have you ever been employed in healthcare Yes in any position?

Company/Employer: First Affiliated Hospital, Sun Yat-sen University

City and state/country/province where you Guangzhou, Guangdong, China last practiced:

Position: Physician

Duties: Provide plastic surgery service to the patients. Teach plastic surgery related medical knowledges to the medical students.Carry out basic science and clinical research related to plastic surgery

From Date: 07/01/2003

ToD~: n~

Exam History

National Boards (NBME)? No

FLEX examination? No

.1 /12/19 9:55 AM Page 6 of 7

Licensure by the Medical Council of Canada No (LMCC)?

USM LE? Yes

State board examination administered prior No to 1972?

Are you ABMS Board certified? No

Fitness and Competency Questions

Do you currently use any chemical No substances which in any way impair or limit your ability to practice your profession with reasonable skill and safety?

Other Licensure

Are you or have you ever been licensed in this profession in another state/country/province?

License number:

State/country/province where you held the license:

If chose other, please specify:

Status of the license:

Name used when licensed:

Are you or have you ever been licensed in any other profession in Tennessee or another state/country/province?

Additional Information

Yes

200344110362101780804061

Other please specify

Guangdong, China

Licensed

XIANGXIA LIU

No

If you have an NPI number, please provide: 1427403278

Do you intend to perform Level II Office No Based Surgery which is integral to a planned treatment regiment and not performed on an urgent or emergent basis? If you intend to perform Level Ill Office Based Surgery, you must apply for and obtain a permit prior to engaging in such practice.

Do you have a DEA number? No

Fees State Regulatory Fee $10.00

Initial Application Fee $400.00

:1/12/19 9:55 AM

Total Amount Due:

Attestation

Page7of7

$410.00

I, being duly sworn and identified as the person referred to in this application, attest to the truth of each statement made in said application. I further swear that I have read and understand the law and the Rules and Regulations regarding the practice of my profession, which are posted on the Board's Internet site and/or were provided to me by the Board office, and agree lo abide by them in the practice as a medical doctor in the State of Tennessee. I HEREBY: SIGNIFY my willingness to appear to answer such questions as the Board may find necessary, which may include a full Board interview. RELEASE to the Board, its staff, and their representatives, any and all documentation necessary now and in the future to establish my physical and mental capabilities to safely practice as a medical doctor. AUTHORIZE the Board, its staff, and their representatives to consult with my prior and current associates and others who may have information bearing on my professional competence, character, health status, ethical qualifications, ability to work cooperatively with others, and other qualifications. RELEASE from liability the Board, its staff, and all their representatives and any and all organizations which provide information for their acts performed and statements made in good faith and without malice concerning my competence, ethics, character, and/or other qualifications, for certification. ACKNOWLEDGE that I, as an applicant for licensure, have the burden of producing adequate information for a proper evaluation of my professional, ethical, and other qualifications, and for resolving any doubts about such qualifications. AUTHORIZE release, use and disclosure of otherwise HIPAA protected health information to the limited extent necessary for my application to receive full consideration up to and including discussion in a public forum should that become necessary. This certifies that the information submitted by me in this application is true and complete to the best of my knowledge and belief.

STATE or TENNESSEE DEPARTMENT OF HEALTH

Bureau of Health Licensure and Regulation Division of Health Related Boards

665 Mainstream Drive Nashville, TN 37243

BILL HASLAM GOVERNOR

JOHN J. DREYZEI-INER, MD, MPH, FACOEM COMMISSIONER

BOARD OF MEDICAL EXAM INERS

February 11, 2019

Xiangxia Liu MD 7950 Farnifold Dr. Apt 3 Germantown, TN 38138

Re: Your Application for a Tennessee Medical License

Dear Dr. Liu:

Your application for a Tennessee medical license has been received in the Board's administrative office and reviewed by the Board's consultant, Rene Saunders, M.D. As a result of Dr. Saunder's review, she has asked that you appear for an interview when the Board meets next on March 19, 2019 at 8:30 a.m. central standard time at 665 Mainstream Drive, Metro Center, Nashville, Tennessee 37243. The interv iew is a prerequisite for licensure for the following reason(s):

• No ACGME residency training and not ABMS Board Certified.

Please contact Ms. Courtney Lewis by e-mail at [email protected] or Fax 615-253-4484 to confirm whether you will appear before the Board. If you are unable to attend the meeting mentioned above, the next scheduled meeting will be May 28, 2019 at the same location. Should you fail to appear or notify this office of your intention to withdraw your application, the Board can and will take whatever action it deems necessary (which could include denying your application) based on the content of your application alone. Notice is hereby given to you that should the Board deny your application, adverse consequences may result which include, but are not limited to, reporting the denial to the National Practitioner Data Bank.

Sincerely,

Courtney Lewis, Administrator Board of Medical Examiners

Cc: Licensure file

EXHIBIT B

I•---. __ . ~ .. -

THE UNIVERSITY of TENNESSEE" HEALTH SCIENCE CENTER

,•; n

COLLEGE OF MEDICINE

To All to 'vVhom These Presents Shall Come, Greetings

Be it knov.'n that

Xiang~a Liu, :MJD., <Pli.<D. Is hereby granted this certificate for having performed his duties

faithfully a.nd satisfactorily in the capacity of

Pe{[ow in <Pediatric Craniofacia[ Surgery Ju{y 1, 2016-June 30: 2017 In \\litness \Vhereof v{e have hereunto set

our hands this JOtfi dav of /11i11~ 2011 •• • . ,I .. . ... •

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. ·. THE UNIVERSITY of TENNESSEE:

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HEALTH SCIENCE CENTER COLLEGE OF MEDICINE

To All to Vv'hom These Presents Shall Come, Greetings

Be it known that

Xiangzja Liu, <JvL <D., <Pli. <D. Is hereby granted this certificate for having performed his duties

faithfully and satisfactorily in the capacity of

Pe[fow in <Bum Surgery Ju{y 1, 2017-June 30, 2018

In Witness \Vhereof we have hereunto set our hands this 30tfi clay of 'June, 2018

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0£1~~i;"!'J{'~~~ ;,~1,f::;,.._-.;,~._ .. .,,.~&.A,:.;~"0~\ ~:·ii~~::;·- ; :1;,~-;l:,.;.1~~i~~~:-~~~A~::a.1·~~-~-~•:. ~,,:.~:-&-~ .. :-:~:;:.,;:,~~;;~,.• ... :/!,;.;;,~if; :~.,_~JL 4 . .-;

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THE UNIVERSITY OF

Department of Plastic Surgery !JlO J•lfad1son Avenue. Suite ~lie Memphis, TN :$8163

Memphis

Knoxville

Chattanooga

Nashville

TENNESSEE T : 901 ) 44 /3-1350 IIEALTH SCIENCE CENTER F (901 ) 4487306 ··-· .... ····--· ..

COLLEGE of MF.DICINE

March 18, 2019

Tennessee Board of Medical Examiners 665 Mainstream Drive, Second Floor Nashville, TN 37243

RE: Xiangxia Liu, MD, PhD

To Whom It May Concern:

I am writing this letter in strong support of Dr, Xiangxia Liu's application for a medical license in the State of Tennessee, I have known Dr. Liu over the past three years as he has served under my supervision as a Fellow in the Department of Plastic Surgery at the University of Tennessee Health Science Center Memphis. He has completed a Craniofacial Fellowship, Burn Surgery Fellowship and is currently our Microvascular Fellow. Dr. Liu has performed in an outstanding manner. I have been impressed with Dr. Liu's intellect, attention to detail, ability to effectively discuss scientific topics and devotion to the care of his patients, He possesses a high level of integrity and a profound work ethic. He has a deep interest in burn and microvascular surgery and these are areas of critical need in our Department of Plastic Surgery,

As you may be aware, Memphis is an underserved area and we have difficulty in recruiting subspecialtytrained plastic surgeons in both of these areas. We currently have a position open and f have discussed with Dr. Liu the possibility of him filling that position should he be successful in obtaining licensure in the State of Tennessee. He would make a fine addition to our academic department as evidenced by his productivity documented on his curriculum vitae.

In summary, I give my highest recommendation for your consideration of Dr. Liu. I would be happy to answer any questions or concerns and please do not hesitate to contact me.

Sincerely,

() Q K-~i.r..--v•'·t fl . l,../'l,.L~_,f.~- _,{{ j) Robert D. Wallace, MD Professor and Chairman Department of Plastic Surgery University of Tennessee Health Science Center

RDW/es

EXHIBIT D

maryka?'1erine · 2019-05-21 · 4.1 dr. liu presented an application for a license to...

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