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BEFORE THE MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation Against:

RA VINDER SINGH KAHLON, M.D.

Physician's and Surgeon's Certificate No. A 125871

Respondent

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Case No. 06-2013-235523

DECISION

The attached Stipulated Settlement and Disciplinary Order is hereby adopted as the Decision and Order of the Medical Board of California, Department of Consumer Affairs, State of California.

This Decision shall become effective at 5:00 p.m. on February 17, 2017.

IT IS SO ORDERED: January 19, 2017.

MEDICAL BOARD OF CALIFORNIA

KAMALA D. HARRIS 1 Attorney General of California

ALEXANDRA M. ALVAREZ 2 Supervising Deputy Attorney General

MICHAEL C. BRUMMEL 3 Deputy Attorney General

State BarNo. 236116 4 California Department of Justice

2550 Mariposa Mall, Room 5090 5 Fresno, CA 93721

Telephone: (559) 477-1679 6 Facsimile: (559) 445-5106

E-mail: Michael.Brummel@doj .ca.gov 7

8 Attorneys for Complainant

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10 BEFORE THE

11 MEDICAL BOARD OF CALIFORNIA


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RA VINDER SINGH KAHLON, M.D. 4860 Y Street, Suite 0200 Sacramento, CA 95817

Case No. 06-2013-235523

STIPULATED SETTLEMENT AND DISCIPLINARY ORDER

16 Physician's and Surgeon's Certificate No.

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A 125871

Respondent.

IT IS HEREBY STIPULATED AND AGREED by and between the parties to the above-

entitled proceedings that the following matters are true:

PARTIES

1. Kimberly Kirchmeyer (Complainant) is the Executive Director of the Medical Board

23 of California (Board). She brought this action solely in her official capacity and is represented in

24 this matter by Kamala D. Harris, Attorney General of the State of California, by Michael C.

25 Brummel, Deputy Attorney General.

26 2. Respondent Ravinder Singh Kahlon, M.D. (Respondent) is represented in this

27 proceeding by attorney Donald H. Heller, Esq. whose address is: 3638 American River Drive

28 Sacramento, CA 95864.

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STIPULATED SETTLEMENT AND DISCIPLINARY ORDER (06-2013-235523)

1 3. On or about May 22, 2013, the Board issued Physician's and Surgeon's Certificate

2 No. A 125871 to Ravinder Singh Kahlon, M.D. (Respondent). The Physician's and Surgeon's

3 Certificate was in full force and effect at all times relevant to the charges brought in Accusation

4 No. 06-2013-235523, and will expire on October 31, 2018, unless renewed.

5 JURISDICTION

6 4. Accusation No. 06-2013-235523 was filed before the Board, and is currently pending

7 against Respondent. The Accusation and all other statutorily required documents were properly

8 served on Respondent on August 23, 2016. Respondent timely filed his Notice of Defense

9 contesting the Accusation.

10 5. A copy of Accusation No. 06-2013-235523 is attached as Exhibit A and incorporated

11 herein by reference.

12 ADVISEMENT AND WAIVERS

13 6. Respondent has carefully read, fully discussed with counsel, and understands the

14 charges and allegations in Accusation No. 06-2013-235523. Respondent has also carefully read,

15 fully discussed with counsel, and understands the effects of this Stipulated Settlement and

16 Disciplinary Order.

17 7. Respondent is fully aware of his legal rights in this matter, including the right to a

18 hearing on the charges and allegations in the Accusation; the right to confront and cross-examine

19 the witnesses against him; the right to present evidence and to testify on his own behalf; the right

20 to the issuance of subpoenas to compel the attendance of witnesses and the production of

21 documents; the right to reconsideration and court review of an adverse decision; and all other

22 rights accorded by the California Administrative Procedure Act and other applicable laws.

23 8. Respondent voluntarily, knowingly, and intelligently waives and gives up each and

24 every right set forth above.

25 CULPABILITY

26 9. Respondent admits the truth of each and every charge and allegation in Accusation

27 No. 06-2013-235523.

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1 10. Respondent agrees that his Physician's and Surgeon's Certificate is subject to

2 discipline and he agrees to be bound by the Board's probationary terms as set forth in the

3 Disciplinary Order below.

4 CONTINGENCY

5 11. This stipulation shall be subject to approval by the Medical Board of California.

6 Respondent understands and agrees that counsel for Complainant and the staff of the Medical

7 Board of California may communicate directly with the Board regarding this stipulation and

8 settlement, without notice to or participation by Respondent or his counsel. By signing the

9 stipulation, Respondent understands and agrees that he may not withdraw his agreement or seek

10 to rescind the stipulation prior to the time the Board considers and acts upon it. If the Board fails

11 to adopt this stipulation as its Decision and Order, the Stipulated Settlement and Disciplinary

12 Order shall be of no force or effect, except for this paragraph, it shall be inadmissible in any legal

13 action between the parties, and the Board shall not be disqualified from further action by having

14 considered this matter.

15 12. The parties understand and agree that Portable Document Format (PDF) and facsimile

16 copies of this Stipulated Settlement and Disciplinary Order, including PDF and facsimile

17 signatures thereto, shall have the same force and effect as the originals.

18 13. In consideration of the foregoing admissions and stipulations, the parties agree that

19 the Board may, without further notice or formal proceeding, issue and enter the following

20 Disciplinary Order:

21 DISCIPLINARY ORDER

22 IT IS HEREBY ORDERED that Physician's and Surgeon's Certificate No. A 125871

23 issued to Respondent Ravinder Singh Kahlon, M.D. is revoked. However, the revocation is

24 stayed and Respondent is placed on probation for five (5) years from the effective date of the

25 Decision on the following terms and conditions.

26 1. CONTROLLED SUBSTANCES -ABSTAIN FROM USE. Respondent shall abstain

27 completely from the personal use or possession of controlled substances as defined in the

28 California Uniform Controlled Substances Act, dangerous drugs as defined by Business and

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1 Professions Code section 4022, and any drugs requiring a prescription. This prohibition does not

2 apply to medications lawfully prescribed to Respondent by another practitioner for a bona fide

3 illness or condition.

4 Within 15 calendar days of receiving any lawfully prescribed medications, Respondent

5 shall notify the Board or its designee of the: issuing practitioner's name, address, and telephone

6 number; medication name, strength, and quantity; and issuing pharmacy name, address, and

7 telephone number.

8 If Respondent has a confirmed positive biological fluid test for any substance (whether or

9 not legally prescribed) and has not reported the use to the Board or its designee, Respondent

10 shall receive a notification from the Board or its designee to immediately cease the practice of

11 medicine. The Respondent shall not resume the practice of medicine until final decision on an

12 accusation and/or a petition to revoke probation. An accusation and/or petition to revoke

13 probation shall be filed by the Board within 15 days of the notification to cease practice. Ifthe

14 Respondent requests a hearing on the accusation and/or petition to revoke probation, the Board

15 shall provide the Respondent with a hearing within 30 days of the request, unless the Respondent

16 stipulates to a later hearing. A decision shall be received from the Administrative Law Judge or

17 the Board within 15 days unless good cause can be shown for the delay. The cessation of practice

18 shall not apply to the reduction of the probationary time period.

19 If the Board does not file an accusation or petition to revoke probation within 15 days of the

20 issuance of the notification to cease practice or does not provide Respondent with a hearing

21 within 30 days of a such a request, the notification of cease practice shall be dissolved.

22 2. ALCOHOL- ABSTAIN FROM USE. Respondent shall abstain completely from the

23 use of products or beverages containing alcohol.

24 If Respondent has a confirmed positive biological fluid test for alcohol, Respondent shall

25 receive a notification from the Board or its designee to immediately cease the practice of

26 medicine. The Respondent shall not resume the practice of medicine until final decision on an

27 accusation and/or a petition to revoke probation. An accusation and/or petition to revoke

28 probation shall be filed by the Board within 15 days of the notification to cease practice. If the

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Respondent requests a hearing on the accusation and/or petition to revoke probation, the Board

shall provide the Respondent with a hearing within 30 days of the request, unless the Respondent

stipulates to a later hearing. A decision shall be received from the Administrative Law Judge or

the Board within 15 days unless good cause can be shown for the delay. The cessation of practice

shall not apply to the reduction of the probationary time period.

If the Board does not file an accusation or petition to revoke probation within 15 days of the

issuance of the notification to cease practice or does not provide Respondent with a hearing

within 30 days of a such a request, the notification of cease practice shall be dissolved.

3. EDUCATION COURSE. Within 60 calendar days of the effective date of this

Decision, and on an annual basis thereafter, Respondent shall submit to the Board or its designee

for its prior approval educational program(s) or course(s) which shall not be less than 40 hours

per year, for each year of probation. The educational program(s) or course(s) shall be aimed at

correcting any areas of deficient practice or knowledge and shall be Category I certified. The

educational program(s) or course(s) shall be at Respondent's expense and shall be in addition to

the Continuing Medical Education (CME) requirements for renewal oflicensure. Following the

completion of each course, the Board or its designee may administer an examination to test

Respondent's knowledge of the course. Respondent shall provide proof of attendance for 65

hours of CME of which 40 hours were in satisfaction of this condition.

4. PSYCHIATRIC EVALUATION. Within 30 calendar days of the effective date of

this Decision, and on whatever periodic basis thereafter may be required by the Board or its

designee, Respondent shall undergo and complete a psychiatric evaluation (and psychological

testing, if deemed necessary) by a Board-appointed board certified psychiatrist, who shall

consider any information provided by the Board or designee and any other information the

psychiatrist deems relevant, and shall furnish a written evaluation report to the Board or its

designee. Psychiatric evaluations conducted prior to the effective date of the Decision shall not

be accepted towards the fulfillment of this requirement. Respondent shall pay the cost of all

psychiatric evaluations and psychological testing.

Respondent shall comply with all restrictions or conditions recommended by the evaluating

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STIPULATED SETTLEMENT AND DISCIPLINARY ORDER (06-20 13-235523)

1 psychiatrist within 15 calendar days after being notified by the Board or its designee.

2 5. PSYCHOTHERAPY. Within 60 calendar days ofthe effective date of this Decision,

3 Respondent shall submit to the Board or its designee for prior approval the name and

4 qualifications of a California-licensed board certified psychiatrist or a licensed psychologist who

5 has a doctoral degree in psychology and at least five years of postgraduate experience in the

6 diagnosis and treatment of emotional and mental disorders. Upon approval, Respondent shall

7 undergo and continue psychotherapy treatment, including any modifications to the frequency of

8 psychotherapy, until the Board or its designee deems that no further psychotherapy is necessary.

9 The psychotherapist shall consider any information provided by the Board or its designee

10 and any other information the psychotherapist deems relevant and shall furnish a written

11 evaluation report to the Board or its designee. Respondent shall cooperate in providing the

12 psychotherapist any information and documents that the psychotherapist may deem pertinent.

13 Respondent shall have the treating psychotherapist submit quarterly status reports to the

14 Board or its designee. The Board or its designee may require Respondent to undergo psychiatric

15 evaluations by a Board-appointed board certified psychiatrist. If, prior to the completion of

16 probation, Respondent is found to be mentally unfit to resume the practice of medicine without

17 restrictions, the Board shall retain continuing jurisdiction over Respondent's license and the

18 period of probation shall be extended until the Board determines that Respondent is mentally fit

19 to resume the practice of medicine without restrictions.

20 Respondent shall pay the cost of all psychotherapy and psychiatric evaluations.

21 6. NOTICE OF EMPLOYER OR SUPERVISOR INFORMATION. Within seven (7)

22 days ofthe effective date of this Decision, Respondent shall provide to the Board the names,

23 physical addresses, mailing addresses, and telephone numbers of any and all employers and

24 supervisors. Respondent shall also provide specific, written consent for the Board, Respondent's

25 worksite monitor, and Respondent's employers and supervisors to communicate regarding

26 Respondent's work status, performance, and monitoring. For purposes of this section,

27 "supervisors" shall include the Chief of Staff and Health or Well Being Committee Chair, or

28 equivalent, if applicable, when Respondent has medical staff privileges.

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7. BIOLOGICAL FLUID TESTING. Respondent shall immediately submit to

biological fluid testing, at Respondent's expense, upon request of the Board or its designee.

"Biological fluid testing" may include, but is not limited to, urine, blood, breathalyzer, hair

follicle testing, or similar drug screening approved by the Board or its designee. Respondent shall

make daily contact with the Board or its designee to determine whether biological fluid testing is

required. Respondent shall be tested on the date of the notification as directed by the Board or its

designee. The Board may order Respondent to undergo a biological fluid test on any day, at any

time, including weekends and holidays. Except when testing on a specific date as ordered by the

Board or its designee, the scheduling of biological fluid testing shall be done on a random basis.

The cost ofbiological fluid testing shall be borne by Respondent.

During the first year of probation, Respondent shall be subject to 52 to 104 random tests.

During the second year of probation and for the duration of the probationary term, up to five ( 5)

years, Respondent shall be subject to 36 to 104 random tests per year. Only if there has been no

positive biological fluid tests in the previous five (5) consecutive years of probation, may testing

be reduced to one (1) time per month. Nothing precludes the Board from increasing the number

of random tests to the first-year level of frequency for any reason.

Prior to practicing medicine, Respondent shall contract with a laboratory or service,

approved in advance by the Board or its designee, that will conduct random, unannounced,

observed, biological fluid testing and meets all the following standards:

A. Its specimen collectors are either certified by the Drug and Alcohol Testing

Industry Association or have completed the training required to serve as a collector for the United

States Department of Transportation.

B. Its specimen collectors conform to the current United States Department of

Transportation Specimen Collection Guidelines.

C. Its testing locations comply with the Urine Specimen Collection Guidelines

published by the United States Department of Transportation without regard to the type oftest

administered.

D. Its specimen collectors observe the collection of testing specimens.

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1 E. Its laboratories are certified and accredited by the United States Department of

2 Health and Human Services.

3 F. Its testing locations shall submit a specimen to a laboratory within one (I) business

4 day of receipt and all specimens collected shall be handled pursuant to chain of custody

5 procedures. The laboratory shall process and analyze the specimens and provide legally

6 defensible test results to the Board within seven (7) business days of receipt of the specimen. The

7 Board will be notified of non-negative results within one (1) business day and will be notified of

8 negative test results within seven (7) business days.

9 G. Its testing locations possess all the materials, equipment, and technical expertise

10 necessary in order to test Respondent on any day of the week.

11 H. Its testing locations are able to scientifically test for mine, blood, and hair

12 specimens for the detection of alcohol and illegal and controlled substances.

13 I. It maintains testing sites located throughout California.

14 J. It maintains an automated 24-hour toll-free telephone system and/or a secure on-

15 line computer database that allows Respondent to check in daily for testing.

16 K. It maintains a secure, HIPAA-compliant website or computer system that allows

17 staff access to drug test results and compliance reporting information that is available 24 hours a

18 day.

19 L. It employs or contracts with toxicologists that are licensed physicians and have

20 knowledge of substance abuse disorders and the appropriate medical training to interpret and

21 evaluate laboratory biological fluid test results, medical histories, and any other information

22 relevant to biomedical information.

23 M. It will not consider a toxicology screen to be negative if a positive result is

24 obtained while practicing, even if Respondent holds a valid prescription for the substance.

25 Prior to changing testing locations for any reason, including during vacation or other

26 travel, alternative testing locations must be approved by the Board and meet the requirements

27 above.

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1 The contract shall require that the laboratory directly notify the Board or its designee of

2 nonnegative results within one (1) business day and negative test results within seven (7) business

3 days of the results becoming available. Respondent shall maintain this laboratory or service

4 contract during the period of probation.

5 A certified copy of any laboratory test result may be received in evidence in any

6 proceedings between the Board and Respondent.

7 If a biological fluid test result indicates Respondent has used, consumed, ingested, or

8 administered to himself a prohibited substance, the Board shall order Respondent to

9 cease practice and instruct Respondent to leave any place of work where Respondent is practicing

10 medicine or providing medical services. The Board shall immediately notify all of Respondent's

11 employers, supervisors and work monitors, if any, that Respondent may not practice medicine or

12 provide medical services while the cease-practice order is in effect.

13 A biological fluid test will not be considered negative if a positive result is obtained while

14 practicing, even if the practitioner holds a valid prescription for the substance. If no prohibited

15 substance use exists, the Board shall lift the cease-practice order within one (1) business day.

16 After the issuance of a cease-practice order, the Board shall determine whether the

17 positive biological fluid test is in fact evidence of prohibited substance use by consulting with the

18 specimen collector and the laboratory, communicating with the licensee, his treating

19 physician(s), other health care provider, or group facilitator, as applicable.

20 For purposes of this condition, the terms "biological fluid testing" and "testing" mean the

21 acquisition and chemical analysis of Respondent's urine, blood, breath, or hair.

22 For purposes of this condition, the term "prohibited substance" means an illegal drug, a

23 lawful drug not prescribed or ordered by an appropriately licensed health care provider for use by

24 Respondent and approved by the Board, alcohol, or any other substance Respondent has been

25 instructed by the Board not to use, consume, ingest, or administer to himself

26 If the Board confirms that a positive biological fluid test is evidence of use of a prohibited

27 substance, Respondent has committed a major violation, as defined in section 1361.52( a), and the

28 Board shall impose any or all of the consequences set forth in section 1361.52(b), in addition to

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any other terms or conditions the Board determines are necessary for public protection or to

enhance Respondent's rehabilitation.

8. SUBSTANCE ABUSE SUPPORT GROUP MEETINGS. Within thirty (30) days of

the effective date of this Decision, Respondent shall submit to the Board or its designee, for its

prior approval, the name of a substance abuse support group which he shall attend for the duration

of probation. Respondent shall attend substance abuse support group meetings at least once per

week, or as ordered by the Board or its designee.

Respondent shall pay all substance abuse support group meeting costs.

The facilitator of the substance abuse support group meeting shall have a minimum of

three (3) years' experience in the treatment and rehabilitation of substance abuse, and shall be

licensed or certified by the state or nationally certified organizations. The facilitator shall not

have a current or former financial, personal, or business relationship with Respondent within the

last five (5) years. Respondent's previous participation in a substance abuse group support

meeting led by the same facilitator does not constitute a prohibited current or former financial,

personal, or business relationship.

The facilitator shall provide a signed document to the Board or its designee showing

Respondent's name, the group name, the date and location of the meeting, Respondent's

attendance, and Respondent's level of participation and progress. The facilitator shall report any

unexcused absence by Respondent from any substance abuse support group meeting to the Board,

or its designee, within twenty-four (24) hours of the unexcused absence.

9. WORKSITE MONITOR FOR SUBSTANCE-ABUSING LICENSEE. Within thirty

(30) calendar days of the effective date of this Decision, Respondent shall submit to the Board or

its designee for prior approval as a worksite monitor, the name and qualifications of one or more

licensed physician and surgeon, other licensed health care professional if no physician and

surgeon is available, or, as approved by the Board or its designee, a person in a position of

authority who is capable of monitoring Respondent at work.

The worksite monitor shall not have a current or former financial, personal, or familial

relationship with Respondent, or any other relationship that could reasonably be expected to

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1 compromise the ability of the monitor to render impartial and unbiased reports to the Board or its

2 designee. If it is impractical for anyone but Respondent's employer to serve as the worksite

3 monitor, this requirement may be waived by the Board or its designee, however, under no

4 circumstances shall Respondent's worksite monitor be an employee or supervisee of the licensee.

5 The worksite monitor shall have an active unrestricted license with no disciplinary action within

6 the last five (5) years, and shall sign an affirmation that he has reviewed the terms and

7 conditions of Respondent's disciplinary order and agrees to monitor Respondent as set forth by

8 the Board or its designee.

9 Respondent shall pay all worksite monitoring costs.

10 The worksite monitor shall have face-to-face contact with Respondent in the work

11 environment on as frequent a basis as determined by the Board or its designee, but not less than

12 once per week; interview other staff in the office regarding Respondent's behavior, if requested

13 by the Board or its designee; and review Respondent's work attendance.

14 The worksite monitor shall verbally report any suspected substance abuse to the Board

15 and Respondent's employer or supervisor within one (1) business day of occurrence. If the

16 suspected substance abuse does not occur during the Board's normal business hours, the verbal

17 report shall be made to the Board or its designee within one (1) hour of the next business day. A

18 written report that includes the date, time, and location of the suspected abuse; Respondent's

19 actions; and any other information deemed important by the worksite monitor shall be submitted

20 to the Board or its designee within 48 hours of the occurrence.

21 The worksite monitor shall complete and submit a written report monthly or as directed by

22 the Board or its designee which shall include the following: ( 1) Respondent's name and

23 Physician's and Surgeon's Certificate number; (2) the worksite monitor's name and signature; (3)

24 the worksite monitor's license number, if applicable; (4) the location or location(s) ofthe

25 worksite; (5) the dates Respondent had face-to-face contact with the worksite monitor; (6) the

26 names of worksite staff interviewed, if applicable; (7) a report of Respondent's work attendance;

27 (8) any change in Respondent's behavior and/or personal habits; and (9) any indicators that can

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1 lead to suspected substance abuse by Respondent. Respondent shall complete any required

2 consent forms and execute agreements with the approved worksite monitor and the Board, or its

3 designee, authorizing the Board, or its designee, and worksite monitor to exchange information.

4 If the worksite monitor resigns or is no longer available, Respondent shall, within five (5)

5 calendar days of such resignation or unavailability, submit to the Board or its designee, for prior

6 approval, the name and qualifications of a replacement monitor who will be assuming that

7 responsibility within fifteen ( 15) calendar days. If Respondent fails to obtain approval of a

8 replacement monitor within sixty (60) calendar days of the resignation or unavailability of the

9 monitor, Respondent shall receive a notification from the Board or its designee to cease the

10 practice of medicine within three (3) calendar days after being so notified. Respondent shall

11 cease the practice of medicine until a replacement monitor is approved and assumes monitoring

12 responsibility.

13 10. VIOLATION OF PROBATION CONDITION FOR SUBSTANCE-ABUSING

14 LICENSEES. Failure to fully comply with any term or condition of probation is a violation of

15 probation.

16 A. If Respondent commits a major violation of probation as defined by section

17 1361.52, subdivision (a), ofTitle 16 of the California Code of Regulations, the Board shall take

18 one or more of the following actions:

19 (1) Issue an immediate cease-practice order and order Respondent to undergo a

20 clinical diagnostic evaluation to be conducted in accordance with section 1361.5,

21 subdivision (c)(l), ofTitle 16 of the California Code ofRegulations, at

22 Respondent's expense. The cease-practice order issued by the Board or its

23 designee shall state that Respondent must test negative for at least a month of

24 continuous biological fluid testing before being allowed to resume practice. For

25 purposes ofthe determining the length of time Respondent must test negative

26 while undergoing continuous biological fluid testing following issuance of a cease-

27 practice order, a month is defined as thirty calendar (30) days. Respondent may

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1 not resume the practice of medicine until notified in writing by the Board or its

2 designee that he may do so.

3 (2) Increase the frequency of biological fluid testing.

4 (3) Refer Respondent for further disciplinary action, such as suspension,

5 revocation, or other action as determined by the Board or its designee. (Cal. Code

6 Regs., tit. 16, § 1361.52, subd. (b).)

7 B. If Respondent commits a minor violation of probation as defined by section

8 1361.52, subdivision (c), ofTitle 16 of the California Code of Regulations, the Board shall take

9 one or more of the following actions:

10 (1) Issue a cease-practice order;

11 (2) Order practice limitations;

12 (3) Order or increase supervision of Respondent;

13 ( 4) Order increased documentation;

14 (5) Issue a citation and fine, or a warning letter;

15 (6) Order Respondent to undergo a clinical diagnostic evaluation to be

16 conducted in accordance with section 1361.5, subdivision (c)(l), ofTitle 16 ofthe

17 California Code of Regulations, at Respondent's expense;

18 (7) Take any other action as determined by the Board or its designee. (Cal.

19 Code Regs., tit. 16, § 1361.52, subd. (d).)

20 C. Nothing in this Decision shall be considered a limitation on the Board's authority

21 to revoke Respondent's probation if he has violated any term or condition of probation. (See Cal.

22 Code Regs., tit. 16, § 1361.52, subd. (e).) IfRespondent violates probation in any respect, the

23 Board, after giving Respondent notice and the opportunity to be heard, may revoke probation and

24 carry out the disciplinary order that was stayed. If an Accusation, or Petition to Revoke

25 Probation, or an Interim Suspension Order is filed against Respondent during probation, the

26 Board shall have continuing jurisdiction until the matter is final, and the period of probation shall

27 be extended until the matter is final.

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1 11. NOTIFICATION. Within seven (7) days ofthe effective date of this Decision, the

2 Respondent shall provide a true copy of this Decision and Accusation to the Chief of Staff or the

3 Chief Executive Officer at every hospital where privileges or membership are extended to

4 Respondent, at any other facility where Respondent engages in the practice of medicine,

5 including all physician and locum tenens registries or other similar agencies, and to the Chief

6 Executive Officer at every insurance carrier which extends malpractice insurance coverage to

7 Respondent. Respondent shall submit proof of compliance to the Board or its designee within 15

8 calendar days.

9 This condition shall apply to any change(s) in hospitals, other facilities or insurance carrier.

10 12. SUPERVISION OF PHYSICIAN ASSISTANTS. During probation, Respondent is

11 prohibited from supervising physician assistants.

12 13. OBEY ALL LAWS. Respondent shall obey all federal, state and local laws, all rules

13 governing the practice of medicine in California and remain in full compliance with any court

14 ordered criminal probation, payments, and other orders.

15 14. QUARTERLY DECLARATIONS. Respondent shall submit quarterly declarations

16 under penalty of perjury on forms provided by the Board, stating whether there has been

17 compliance with all the conditions of probation.

18 Respondent shall submit quarterly declarations not later than 10 calendar days after the end

19 of the preceding quarter.

20 15. GENERAL PROBATION REQUIREMENTS.

21 Compliance with Probation Unit

22 Respondent shall comply with the Board's probation unit and all terms and conditions of

23 this Decision.

24 Address Changes

25 Respondent shall, at all times, keep the Board informed of Respondent's business and

26 residence addresses, email address (if available), and telephone number. Changes of such

27 addresses shall be immediately communicated in writing to the Board or its designee. Under no

28 circumstances shall a post office box serve as an address of record, except as allowed by Business

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1 and Professions Code section 2021 (b).

2 Place of Practice

3 Respondent shall not engage in the practice of medicine in Respondent's or patient's place

4 of residence, unless the patient resides in a skilled nursing facility or other similar licensed

5 facility.

6 License Renewal

7 Respondent shall maintain a current and renewed California physician's and surgeon's

8 license.

9 Travel or Residence Outside California

10 Respondent shall immediately inform the Board or its designee, in writing, of travel to any

11 areas outside the jurisdiction of California which lasts, or is contemplated to last, more than thirty

12 (30) calendar days.

13 In the event Respondent should leave the State of California to reside or to practice

14 Respondent shall notify the Board or its designee in writing 30 calendar days prior to the dates of

15 departure and return.

16 16. INTERVIEW WITH THE BOARD OR ITS DESIGNEE. Respondent shall be

17 available in person upon request for interviews either at Respondent's place of business or at the

18 probation unit office, with or without prior notice throughout the term of probation.

19 17. NON-PRACTICE WHILE ON PROBATION. Respondent shall notify the Board or

20 its designee in writing within 15 calendar days of any periods of non-practice lasting more than

21 30 calendar days and within 15 calendar days of Respondent's return to practice. Non-practice is

22 defined as any period of time Respondent is not practicing medicine in California as defined in

23 Business and Professions Code sections 2051 and 2052 for at least 40 hours in a calendar month

24 in direct patient care, clinical activity or teaching, or other activity as approved by the Board. All

25 time spent in an intensive training program which has been approved by the Board or its designee

26 shall not be considered non-practice. Practicing medicine in another state of the United States or

27 Federal jurisdiction while on probation with the medical licensing authority of that state or

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1 jurisdiction shall not be considered non-practice. A Board-ordered suspension of practice shall

2 not be considered as a period of non-practice.

3 In the event Respondent's period of non-practice while on probation exceeds 18 calendar

4 months, Respondent shall successfully complete a clinical training program that meets the criteria

5 of Condition 18 ofthe current version ofthe Board's "Manual of Model Disciplinary Orders and

6 Disciplinary Guidelines" prior to resuming the practice of medicine.

7 Respondent's period of non-practice while on probation shall not exceed two (2) years.

8 Periods of non-practice will not apply to the reduction of the probationary term.

9 Periods of non-practice will relieve Respondent of the responsibility to comply with the

10 probationary terms and conditions with the exception of this condition and the following terms

11 and conditions of probation: Obey All Laws; and General Probation Requirements.

12 18. COMPLETION OF PROBATION. Respondent shall comply with all financial

13 obligations (e.g., restitution, probation costs) not later than 120 calendar days prior to the

14 completion of probation. Upon successful completion of probation, Respondent's certificate shall

15 be fully restored.

16 19. VIOLATION OF PROBATION. Failure to fully comply with any term or condition

17 of probation is a violation of probation. If Respondent violates probation in any respect, the

18 Board, after giving Respondent notice and the opportunity to be heard, may revoke probation and

19 carry out the disciplinary order that was stayed. If an Accusation, or Petition to Revoke Probation,

20 or an Interim Suspension Order is filed against Respondent during probation, the Board shall have

21 continuing jurisdiction until the matter is final, and the period of probation shall be extended until

22 the matter is final.

23 20. LICENSE SURRENDER. Following the effective date of this Decision, if

24 Respondent ceases practicing due to retirement or health reasons or is otherwise unable to satisfy

25 the terms and conditions of probation, Respondent may request to surrender his or her license.

26 The Board reserves the right to evaluate Respondent's request and to exercise its discretion in

27 determining whether or not to grant the request, or to take any other action deemed appropriate

28 and reasonable under the circumstances. Upon formal acceptance of the surrender, Respondent

16


1 shall within 15 calendar days deliver Respondent's wallet and wall certificate to the Board or its

2 designee and Respondent shall no longer practice medicine. Respondent will no longer be subject

3 to the terms and conditions of probation. If Respondent re-applies for a medical license, the

4 application shall be treated as a petition for reinstatement of a revoked certificate.

5 21. PROBATION MONITORING COSTS. Respondent shall pay the costs associated

6 with probation monitoring each and every year of probation, as designated by the Board, which

7 may be adjusted on an annual basis. Such costs shall be payable to the Medical Board of

8 California and delivered to the Board or its designee no later than January 31 of each calendar

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year.

Ill

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"t0'd lldlOl

ACCEPTANCE

2 I have carefully read the above Stipulated Settlement and Disciplinary Order and have fully

3 discussed it with my attorney, Donald H. Heller, Esq. I understand the stipulation and the effect it

4 will have on my Physician's and Surgeon's Certificate. I enter into this Stipulated Settlement and

5 Disciplinary Order voluntarily, knowingly, a~d intelligently, and agree to be bound by the

6 Decision and Order of the Medical Board ofCalifomia.

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RAViNDERSINGH KAHLON, M.D. Respondent

I have read and fully discussed with Respondent Ravinder Singh Kahlon, M.D. the terms

and conditions and other matters contained in the above Stipulated Settlement and Disciplinary

Order. 1 approve its form and content.

DATED: DONALD H. HELLER, ESQ. Attorney for Respondent

17 ENDORSEMENT

l8 The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully

19 submitted for consideration by the Medical Board of California.

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Dated:

SA2016301423 28 95204070.doc

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Respectfully submitted,

KAMALA D. HARRIS Attorney General of California ALEXANDRA M. ALVAREZ Supervising Deputy Attorney General

MICHAEL C. BRUMMEL Deputy Attorney General Attorneys for Complainant

STIPULATED SET1'LEMENT AND DISCIPLINARY ORDER. {06-2013-235523)

OHJ3 '& 8>13 l..Z:60 9l0c-£t-J3a l0/l0'd 60v0v£l..9"t6

ACCEPTANCE




5 Disciplinary Order voluntarily, knowingly, and intelligently, and agree to be bound by the

6 Decision and Order of the Medical Board of California.

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DATED: RA VINDER SINGH KAHLON, M.D. Respondent

11 I have read and fully discussed with Respondent Ravinder Singh Kahlon, M.D. the tenns

12 and conditions and other matters contained in the above Stipulated Settlement and Disciplinary

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Order. I approve its form and content. ~

DATED: 12...-\lf-~otb _l_)~ \--\ · DONALD H. HELLER, ESQ. Attorney for Respondent

17 ENDORSEMENT

I 8 The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully


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Dated:

SA2016301423 28 95204070.doc

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MICIIAEL C. BRUMMEL Deputy Attorney General Attorneys for Complainant

STIPULATED SElTLEMENT AND DISCIPLINARY ORDER (06-20 13-235523)

1 ACCEPTANCE




5 Disciplinary Order voluntarily, knowingly, and intelligently, and agree to be bound by the

6 Decision and Order of the Medical Board of California.

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DATED:

RA VINDER SINGH KAHLON, M.D. Respondent

I have read and fully discussed with Respondent Ravinder Singh Kahlon, M.D. the terms

and conditions and other matters contained in the above Stipulated Settlement and Disciplinary

Order. I approve its form and content.

DATED: DONALD H. HELLER, ESQ. Attorney for Respondent ,,

17 ENDORSEMENT

18 The foregoing Stipulated Settlement and Disciplinary Order is hereby respectfully


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Dated: 12/15)2010

SA20 16301423 28 95204070.doc

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~~ MICHAEL C. BRUMMEL Deputy Attorney General Attorneys for Complainant


Exhibit A

Accusation No. 06-2013-235523

KAMALA D. HARRIS Attorney General of California

2 VLADIMIR SHALKEVICII FILED Acting Supervising Deputy Attorney General

3 MICHAEL C. BRUMMEL Deputy Attorney General

STATE OF CALIFORNIA MEDICAL BOARD O~AUFORNIA

SA~R~M~~~~ rl.3. 20..l.k_ BY.~, it\. ANALYST 4 State Bar No. 2361 16

California Department of Justice ) ;-..

5 2550 Mariposa Mall, Room 5090 Fresno, CA 93721

6 Telephone: (559) 477-1679 Facsimile: (559) 445-5106

7 E-mail: [email protected]

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Altorneys for Complainant

BEFORE THE MEDICAL BOARD OF CALIFORNIA



Ravinder Singh Kahlon, M.D. 4860 Y Street, Suite 0200 Sacramento, CA 95817

Physician's and Surgeon's Certificate No. A 125871,

Case No. 06-2013-235523

ACCUSATION

Respondent.

Complainant alleges:

PARTIES

1. Kimberly Kirchmeyer (Complainant) brings this Accusation solely in her official

capacity as the Executive Director ofthe Medical Board of California, Department ofConsumer

Affairs (Board)1•

2. On or about May 22, 2013, the Board issued Physician's and Surgeon's Certificate

Number A 125871 to Ravinder Singh Kahlon, M.D. (Respondent). The Physician's and

1 The term "Board" means the Medical Board of California. "Division of Medical Quality" shall also be deemed to refer to the Board.

(RA VINDER SfNGH KAHLON, M.D.) ACCUSATION NO. 06-2013-235523

Surgeon's Certificate was in full force and effect at all times relevant to the charges brought

2 herein and will expire on October 31, 2016, unless renewed.

3 JURISDICTION

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3. This Accusation is brought before the Board, under the authority of the following

laws. All section references are to the Business and Professions Code unless otherwise indicated.

4. Section 22 ofthe Code states:

"'Board' as used in any provisions of this Code, refers to the board in which the

administration of the provision is vested, and unless otherwise expressly provided, shall include

'bureau,' 'co.mmission,' 'committee,' 'department,' 'division,' 'examining committee,'

'program,' and 'agency."'

5. Section 490 of the Code states:

12 "(a) In addition to any other action that a board is permitted to take against a licensee, a

13 board may suspend or revoke a license on the ground that the licensee has been convicted of a

14 crime, if the crime is substantially related to the qualifications, functions, or duties of the business

15 or profession for which the license was issued.

16 "(b) Notwithstanding any other provision of law, a board may exercise any authority to

17 discipline a licensee for conviction of a crime that is independent of the authority granted under

18 subdivision (a) only if the crime is substantially related to the qualifications, functions, or duties

19 of the business or profession for which the licensee's license was issued.

20 "(c) A conviction within the meaning of this section means a plea or verdict of guilty or a

21 conviction following a plea of nolo contendere. Any action that a board is permitted to take

22 following the establishment of a conviction may be taken when the time for appeal has elapsed, or

23 the judgment of conviction has been affirmed on appeal, or when an order granting probation is

24 made suspending the imposition of sentence, irrespective of a subsequent order under the

25 provisions of Section 1203.4 ofthe Penal Code.

26 "(d) The Legislature hereby finds and declares that the application of this section has been

27 made unclear by the holding in Petropoulos v. Department of Real Estate (2006) 142 Cai.App.4th

28 554, and that the holding in that case has placed a significant number of statutes and regulations

2

(RA VINDER SINGH KAHLON, M.D.) ACCUSATION NO. 06-2013-235523

1 in question, resulting in potential harm to the consumers of California from licensees who have

2 been convicted of crimes. Therefore, the Legislature finds and declares that this section

3 establishes an independent basis for a board to impose discipline upon a licensee, and that the

4 amendments to this section made by Senate Bill 797 of the 2007-08 Regular Session do not

5 constitute a change to, but rather are declaratory of, existing law."

6 6. Section 2227 of the Code states:

7 "(a) A licensee whose matter has been heard by an administrative law judge of the Medical

8 Quality Hearing Panel as designated in Section 11371 ofthe Government Code, or whose default

9 has been entered, and who is found guilty, or who has entered into a stipulation for disciplinary

10 action with the board, may, in accordance with the provisions of this chapter:

11 "(I) Have his or her license revoked upon order of the board.

12 "(2) Have his or her right to practice suspended for a period not to exceed one year upon

13 order of the board.

14 "(3) Be placed on probation and be required to pay the costs of probation monitoring upon

15 order of the board.

16 "(4) Be publicly reprimanded by the board. The public reprimand may include a

17 requirement that the licensee complete relevant educational courses approved by the board.

18 "(5) Have any other action taken in relation to discipline as part of an order of probation, as

19 the board or an administrative law judge may deem proper.

20 "(b) Any matter heard pursuant to subdivision (a), except for warning letters, medical

21 review or advisory conferences, professional competency examinations, continuing education

22 activities, and cost reimbursement associated therewith that are agreed to with the board and

23 successfully completed by the licensee, or other matters made confidential or privileged by

24 existing law, is deemed public, and shall be made available to the public by the board pursuant to

25 Section 803.1."

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7. Section 2234 ofthe Code, states:

2 "The board shall take action against any licensee who is charged with unprofessional

3 conduct. In addition to other provisions of this article, unprofessional conduct includes, but is not

4 limited to, the following:

5 "(a) Violating or attempting to violate, directly or indirectly, assisting in or abetting the

6 violation of, or conspiring to violate any provision of this chapter.

7 "(b) Gross negligence.

8 "(c) Repeated negligent acts. To be repeated, there must be two or more negligent acts or

9 omissions. An initial negligent act or omission followed by a separate and distinct departure from

10 the applicable standard of care shall constitute repeated negligent acts.

11 "(1) An initial negligent diagnosis followed by an act or omission medically appropriate

12 for that negligent diagnosis of the patient shall constitute a single negligent act.

13 "(2) When the standard of care requires a change in the diagnosis, act, or omission that

14 constitutes the negligent act described in paragraph (1), including, but not limited to, a

15 reevaluation of the diagnosis or a change in treatment, and the licensee's conduct departs from the

16 applicable standard of care, each departure constitutes a separate and distinct breach of the

17 standard of care.

18 "(d) Incompetence.

19 "(e) The commission of any act involving dishonesty or corruption which is substantially

20 related to the qualifications, functions, or duties of a physician and surgeon.

21 "(f) Any action or conduct which would have warranted the denial of a certificate.

22 "(g) The practice of medicine from this state into another state or country without meeting

23 the legal requirements of that state or country for the practice of medicine. Section 2314 shall not

24 apply to this subdivision. This subdivision shall become operative upon the implementation of the

25 proposed registration program described in Section 2052.5.

26 "(h) The repeated failure by a certificate holder, in the absence of good cause, to attend and

27 participate in an interview by the board. This subdivision shall only apply to a certificate holder

28 who is the subject of an investigation by the board."

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8. Section 2236 ofthe Code states:

"(a) The conviction of any offense substantially related to the qualifications, functions, or

duties of a physician and surgeon constitutes unprofessional conduct within the meaning ofthis

chapter [Chapter 5, the Medical Practice Act]. The record of conviction shall be conclusive

evidence only of the fact that the conviction occurred.

"(b) The district attorney, city attorney, or other prosecuting agency shall notify the

Medical Board of the pendency of an action against a licensee charging a felony or misdemeanor

immediately upon obtaining information that the defendant is a licensee. The notice shall identify

the licensee and describe the crimes charged and the facts alleged. The prosecuting agency shall

also notify the clerk of the court in which the action is pending that the defendant is a licensee,

and the clerk shall record prominently in the file that the defendant holds a license as a physician

and surgeon.

"(c) The clerk of the court in which a licensee is convicted of a crime shall, within 48 hours

after the conviction, transmit a certified copy of the record of conviction to the board. The

division may inquire into the circumstances surrounding the commission of a crime in order to fix

the degree of discipline or to determine if the conviction is of an offense substantially related to

the qualifications, functions, or duties of a physician and surgeon.

"(d) A plea or verdict of guilty or a conviction after a plea of nolo contendere is deemed to

be a conviction within the meaning of this section and Section 2236.1. The record of conviction

shall be conclusive evidence of the fact that the conviction occurred."

9. Section 2239 of the Code states:

"(a) The use or prescribing for or administering to himself or herself, of any controlled

substance; or the use of any of the dangerous drugs specified in Section 4022, or of alcoholic

beverages, to the extent, or in such a manner as to be dangerous or injurious to the licensee, or to

any other person or to the public, or to the extent that such use impairs the ability of the licensee

to practice medicine safely or more than one misdemeanor or any felony involving the use,

consumption, or self-administration of any of the substances referred to in this section, or any

5

(RAVINDER SINGH KAHLON, M.D.) ACCUSATION NO. 06-2013-235523

1 combination thereof, constitutes unprofessional conduct. The record of the conviction is

2 conclusive evidence of such unprofessional conduct.

3 "(b) A plea or verdict of guilty or a conviction following a plea of nolo contendere is

4 deemed to be a conviction within the meaning of this section. The Medical Board may order

5 discipline of the licensee in accordance with Section 2227 or the Medical Board may order the

6 denial of the license when the time for appeal has elapsed or the judgment of conviction has been

7 affirmed on appeal or when an order granting probation is made suspending imposition of

8 sentence, irrespective of a subsequent order under the provisions of Section 1203.4 ofthe Penal

9 Code allowing such person to withdraw his or her plea of guilty and to enter a plea of not guilty,

10 or setting aside the verdict of guilty, or dismissing the accusation, complaint, information, or

11 indictment."

12 1 0. California Code of Regulations, title 16, section 1360, states:

13 "For the purposes of denial, suspension or revocation of a license, certificate or permit

14 pursuant to Division 1.5 (commencing with Section 475) of the code, a crime or act shall be

15 considered to be substantially related to the qualifications, functions or duties of a person holding

16 a license, certificate or permit under the Medical Practice Act if to a substantial degree it

17 evidences present or potential unfitness of a person holding a license, certificate or penn it to

18 perform the functions authorized by the license, certificate or permit in a manner consistent with

19 the public health, safety or welfare. Such crimes or acts shall include but not be limited to the

20 following: Violating or attempting to violate, directly or indirectly, or assisting in or abetting the

21 violation of, or conspiring to violate any provision of the Medical Practice Act."

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1 FIRST CAUSE FOR DISCIPLINE

2 (Unprofessional Conduct I Substantially Related Criminal Conviction)

3 11. Respondent Ravinder Singh Kahlon, M.D. is subject to disciplinary action under

4 sections 490 and/or 2234 and/or 2236, in that he has been convicted of crimes substantially

5 related to the qualifications, functions or duties of a Physician and Surgeon. The circumstances

6 are as follows:

7 September 14,2013 Arrest and Subsequent Conviction

8 12. On or about September 14,2013 at approximately 9:10p.m., Respondent was driving

9 his vehicle northbound on Normandie Avenue in Los Angeles County. In the presence oftwo

1 0 uniformed officers riding police motorcycles, Respondent turned right on to eastbound Santa

11 Monica Boulevard at a red light. Respondent drove his vehicle immediately in front of another

12 driver's vehicle causing the other driver to brake, honk and swerve to avoid a collision with

13 Respondent. Officers immediately conducted a traffic stop. Respondent admitted that he had

14 consumed alcohol "about an hour ago in Malibu." Respondent presented with obvious signs of

15 intoxication including: an odor of an alcoholic beverage emitting from his breath, bloodshot

16 watery eyes, a flushed face, poor coordination and "slow, slurred" speech. Respondent performed

17 poorly on field sobriety tests and provided two breath samples for a preliminary alcohol screening

18 test at 9:25p.m., which resulted in blood alcohol levels of0.133% and 0.142%. Respondent

19 provided three additional breath samples for a alcohol screening tests at 1 0:04 p~m., 10:10 p.m.

20 and 1 0: 13 p.m., which resulted in blood alcohol levels of 0.128%, 0.125% and 0.122%.

21 13. On or about September 26,2013, the Los Angeles County District Attorney's Office

22 filed misdemeanor criminal charges against Respondent for violations of Vehicle Code Sections

23 23152(a) [driving with a 0.08% or higher blood alcohol level]; 23152(a) [driving under the

24 influence of alcohol]; 12500 [driving without a license].

25 14. On or about December 13, 2013, in the Los Angeles Superior Court case number

26 3MP08851, entitled People of the Stale of California vs Ravinder S. Kahlon Respondent entered a

27 no contest plea to the charge that he violated Vehicle Code section 23152(b ), a misdemeanor.

28 The remaining charges for violations of Vehicle Code sections 23152(a) [driving under the

7


influence of alcohol] and 12500 [driving without a license] were dismissed. Respondent was

2 placed on th:ree years of probation and ordered as follows: obey all laws; complete a three month

3 first offender alcohol counseling program; enroll in the AB-541 program; serve 13 days in

4 custody with credit for 2 days already served; not to drive a motor vehicle without a valid

5 California Driver's License; not to drive a motor vehicle without valid insurance; not to drive

6 with any measurable amount of alcohol; not to refuse to take a blood alcohol test, drug chemical

7 test, field sobriety test, or preliminary alcohol screening test when directed by an officer; and to

8 pay fines and fees.

9 May 11,2014, Arrest and Subsequent Conviction

10 15. On or about May 11, 2014 at approximately 1:35 p.m., Respondent, who was still on

11 criminal probation following his prior conviction, was driving his vehicle near State Route 198

12 west of Interstate 5 in Fresno County, California. Respondent failed to yield to cross-traffic at a

13 posted stop sign and collided with another vehicle resulting in damage to both vehicles. As a

14 result of the collision, Respondent's vehicle's air bags deployed, the front bumper was detached

15 from the vehicle, right rear tire was deflated and partially detached form the rim and the right rear

16 passenger door was scraped and dented. Respondent then made a U-turn and drove his vehicle

17 away from the scene of the accident to a nearby hotel parking lot, while the other driver followed

18 him. A California Highway Patrol Officer arrived on scene and found the Respondent standing

19 next to his vehicle. Respondent identified himself as the driver and provided his passport rather

20 than a valid California Driver's License for identification. Respondent presented with obvious

21 signs of intoxication including: a strong odor of an alcoholic beverage emitting from his breath,

22 red/watery eyes and a "mumbled/slurred" pattern of speech. When officer's inquired,

23 Respondent denied drinking alcohol. Respondent provided two breath samples for a preliminary

24 alcohol screening test at 2:32p.m. and 2:34 p.m., which resulted in blood alcohol levels of

25 0.131% and 0.130%. Respondent agreed to provide a blood sample at approximately 3:28 p.m.

26 which resulted in a blood alcohol level of 0.11 %.

27 16. On or about June 25,2014, the Fresno County District Attorney's Office filed

28 misdemeanor criminal charges against Respondent for violations of Vehicle Code Sections

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1 23152(a) [driving with a 0.08% or higher blood alcohol level]; 23152(a) [driving under the

2 influence of alcohol]; l4601.2(a) [driving when privilege suspended for prior DUI conviction];

3 and enhancements pursuant to 23540 for a prior conviction of23152{b) on or about December 13,

4 2013.

5 17. On or about Apri125, 2016, in the Fresno County Superior Court case number

6 14920627, entitled The People of the State of California vs. Ravinder Singh Kahlon, Respondent

7 entered a no contest plea to a charge that he violated Vehicle Code section 23152(b) and admitted

8 the prior conviction alleged as an enhancement. The remaining charges for violations of Vehicle

9 Code sections 23152(a) [driving under the influence of alcohol] and 14601.2(a) [hit and run]

10 were dismissed at the time of the plea. Respondent was placed on three years probation and

11 ordered as follows: obey all laws, submit his person and property to search and seizure, complete

12 152 hours of community service through a non-profit organization prior to March 27, 2017, not to

13 drive a motor vehicle without a valid California Driver's License; not to drive a motor vehicle

14 without valid insurance; not to drive with any measurable amount of alcohol and to pay fines and

15 fees.

16 SECOND CAUSE FOR DISCIPLINE

17 (Unprofessional Conduct: Excessive Use of Alcohol)

18 18. Respondent is subject to disciplinary action under sections 2234 and/or 2239, in that

19 he has engaged in the use of alcoholic beverages, to the extent, or in such a manner as to be

20 dangerous or injurious to the licensee, or to any other person or to the public, or to the extent that

21 it impairs the ability of the Respondent to practice medicine safely, or has been convicted of more

22 than one misdemeanor involving the use, consumption, or self-administration of alcohol which

23 constitutes unprofessional conduct. The circumstances are set forth in paragraphs 11 through 17

24 of this Accusation, which are incorporated as though fully set forth herein.

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PRAYER

2 WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,

3 and that following the hearing, the Medical Board of California issue a decision:

4 I. Revoking or suspending Physician's and Surgeon's Certificate Number A 125871,

5 issued to Ravinder Singh Kahlon, M.D.;

6 2. Revoking, suspending or denying approval of Ravinder Singh Kahlon, M.D.'s

7 authority to supervise physician assistants, pursuant to section 3527 of the Code;

8 3. Ordering Ravinder Singh Kahlon, M.D., if placed on probation, to pay the Board the

9 costs of probation monitoring; and

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4. Taking such other and further action as deemed nec/sary and proper.

12 DATED: August 23, 2016

13 Executive Di ctor Medical Board of California

14 Department of Consumer Affairs State of California

15 Complainant

16 SA2016301423

17 95192436.docx

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