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Dr. Gurpreet S Bajwa of Fairfax, VA

2019-04-17

From the License Lookup for Dr. Gurpreet S Bajwa of Fairfax, VA

License Number 0101231157 Occupation Medicine & Surgery Name Gurpreet S Bajwa Address Fairfax, VA 22031 Initial License Date 11/01/2001 Expire Date 04/05/2018 License Status Suspended

From Public Disciplinary Proceedings

ORDER OF SUMMARY SUSPENSION Pursuant to Virginia Code § 54.1-2408.1(A), a quorum of the Board of Medicine (“Board”) met by telephone conference call on April 5, 2019, after a good faith effort to convene a regular meeting of the Board had failed. The purpose of the meeting was to receive and act upon information indicating that Gurpreet Singh Bajwa, M.D., may have violated certain laws relating to the practice of medicine in the Commonwealth of Virginia, as more fully set forth in the “Notice of Formal Administrative Hearing and Statement of Allegations,” which is attached hereto and incorporated by reference herein. WHEREUPON, pursuant to its authority under Virginia Code § 54.1-2408.1(A), the Board concludes that a substantial danger to public health or safety warrants this action and ORDERS that the license of Gurpreet Singh Bajwa, M.D., to practice Medicine and Surgery in the Commonwealth of Virginia is SUSPENDED. It is further ORDERED that a hearing be convened within a reasonable time of the date of entry of this Order to receive and act upon evidence in this matter. Pursuant to Virginia Code § 54.1-2400.2, the signed original of this Order shall remain in the custody of the Department of Health Professions as a public record and shall be made available for public inspection or copying on request.

STATEMENT OF ALLEGATIONS The Board alleges that:

  1. At all times relevant hereto, Guxpreet Singh Bajwa, MX)., was licensed to practice Medicine and Surgery in the Commonwealth of Virginia.
  2. In spite of a November 30,2012 Consent Order suspending Dr. Bajwa’s license based on findings that he excessively prescribed controlled substances in a dangerous manner likely to harm patients and the public and maintained deficient medical records, and notwithstanding Dr. Bajwa’s completion of continuing medical education in the proper prescribing of controlled substances and medical recordkeeping pursuant to the Consent Order, Dr. Bajwa violated Virginia Code §§ 54.1-2915(A)(3), (12), (13), (16), (17), and (18), 54.1-3303(A), and 54.1-3408(A); 18 VAC 85-20-26(C) of the Board’s Regulations Governing the Practice of Medicine (Board’s General Regulations); and the Board’s Regulations Governing the Prescribing of Opioids and Buprenorphine (effective for conduct on or after March 15, 2017) (Board’s Prescribing Regulations) with regard to his care and treatment of Patients A, B, and C from approximately January 2017 through August 2018. Specifically: a. Regarding Patient A, a then 23 -year-old female: i. Dr. Bajwa began prescribing Patient A benzodiazepines at her first office visit on August 5, 2017, based solely on the patient’s self-report of anxiety and neuropathy without conducting a comprehensive physical examination, documentation of symptoms or findings supporting a therapeutic purpose, or formulating a diagnosis. ii. In spite of checking Patient A’s Prescription Monitoring Program (PMP) report for the patient’s medication history at the first office visit on August 5,2017, which showed that Patient A received a 30-day supply of alprazolam (C-IV) 2mg #60 on July 24,2017, Dr. Bajwa nonetheless prescribed an additional 30-day supply of alprazolam 2mg #60 and gabapentin (C-VT) 300mg #90. As a result, Patient A obtained #120 dosage units of alprazolam 2mg in a two-week period, or 8mg/day, a dose double the manufacturer’s recommended daily maximum of 4mg/day. iii. Although the patient's August 5,2017, PMP report also indicated that in the approximate six-weeks prior to the visit Patient A filled prescriptions for Suboxone (a narcotic used for the maintenance and treatment of opioid dependence), clonazepam (a C-IV benzodiazepine), and eszopiclone (a C-IV sedative-hypnotic), Dr. Bajwa failed to verify Patient A's substance use and mental health history. Had Dr. Bajwa done so, he would have learned that Patient A had a lengthy history of anxiety, depression, addiction and substance misuse, including heroin, cocaine, POP, benzodiazepines, and alcohol abuse, as demonstrated by the following: • Hospitalizations in October 2015 and December 2015 at Fairfax Hospital for seizures secondary to benzodiazepine withdrawal. • Fairfax Hospital emergency department visits on March 23,2017; April 27,2017; May 17, 2017; and May 26,2017, complaining of drug withdrawal and requesting benzodiazepines and detox. • Multiple admissions (October 15,2014; December 28,2014; May 26,2017; and June 12, 2017) to the Fairfax Hospital Comprehensive Addiction Treatment Services (CATS) for detox, Suboxone maintenance, and rehabilitation. • Documented history of combining alcohol with benzodiazepines and opiates; doctor shopping; not taking medications as prescribed; and discharges from physician practices for non-compliance with treatment iv. Although Patient A's PMP report indicated that four different providers prescribed clonazepam lmg to Patient A between January and July 2017, on August 21,2017, Dr. Bajwa doubled the strength and prescribed Patient A clonazepam 2mg #60 (30-day supply) without documenting any therapeutic need to do so in the medical record. v. On September 19,2017, December 29,2017, January 17,2018, January 18,2018, February 18,2018, April 12,2018, May 3,2018, and July 2,2018, Dr. Bajwa prescribed carisoprodol (C- IV) 350 mg to Patient A when the patient did not present to the office for an examination or evaluation to
    determine the therapeutic need for such medication and without any documented diagnosis warranting such prescriptions. vi. On August 28,2017, Dr. Bajwa prescribed Patient A hydrocodone/acetaminophen (C-II) 10/325mg #30 (15-day supply), and on March 22,2018, he prescribed tramadol (C-IV) 50mg #14 (seven-day supply), while failing to satisfy provisions of the Board's Prescribing Regulations. Specifically, Dr. Bajwa failed to do the following: • Document having considered nonphannacologic and non-opioid treatment for Patient A's complaints of pain, as required by 18 VAC 85-21 -30(A). • Perform a history and physical examination appropriate to the complaint and also failed to conduct an assessment of the patient's history and risk of substance misuse, as required by 18 VAC 85-21-30(B). • Prescribe Naloxone to Patient A as required when concomitant benzodiazepine use is present, as required by 18 VAC 85-21-40(B)(3). • Document the extenuating circumstances justifying co-prescribing hydrocodone/ acetaminophen and tramadol with benzodiazepines and other sedative-hypnotics, as required by 18 VAC 85-21-40(C). • Document a tapering plan to achieve the lowest possible effective doses when co¬prescribing hydrocodone/acetaminophen and tramadol with benzodiazepines, sedative- hypnotics, and carisoprodol, as required by 18 VAC 85-21-40(C). • Document a description of the pain, a presumptive diagnosis for the origin of the pain, an examination appropriate to the complaint, and a treatment plan when he prescribed hydrocodone/acetaminophen and tramadol to Patient A, as required by 18 VAC 85-21-50. vii. Although Dr. Bajwa prescribed multiple controlled substances with high abuse potential to Patient A, he failed to monitor and manage the patient's use of such medications, and continued prescribing to Patient A when he knew or should have known that Patient A was exhibiting signs and symptoms of addiction and medication overuse/misuse. Specifically: • Dr. Bajwa regularly authorized prescriptions for controlled substances prior to the time Patient A should have needed more had she taken the medications as prescribed, as follows: Date Drug/Dose Written Quantity [Days Supph Date Last Prescription/Dayi Supph 8/5/17 | alprazolam 2mg 60 T30 7/24/17 30 day supply 8/8/17 alprazolam 2mg 30 rio 8/5/17 30 day supply 8/28/17 zolpidem lOmg 30 ! 30 8/8/17 30 day suppl> 8/28/17 ! 8/28/17 alprazolam 2mg 60 •20 8/5/17 30 day supplv alprazolam 2mg 40 M 8/5/17 30 day supply . 8/28/17 gabapentin 600mg (prior I strength 300mg) 120 30 8/5/17 30 day supply ! 9/19/17 ' zolpidem lOmg 5 5 8/28/17 30 day supply 9/19/17 zolpidem lOmg 10 8/28/17 30 dav supply 9/29/17 carisoprodol 350m g 14 7 9/19/17 15 dav supply 9/29/17 zolpidem lOmg io |io 9/19/17 15 dav supply r 10/16/17 clonazepam 2 mg 60 1 30 10/13/17 7 day supply 10/16/17 f 12/29/17 eszopiclone 3mg 30 T30 10/13/17 7 day supply carisoprodol 350mg 20 10 12/22/17 15 day supply 12/29/17 ! alprazolam 2mg 12 4 12/22/17 15 day supply 1/2/18 I eszopiclone 3mg 30 |40 12/22/17 15 dav supply 1/2/18 I carisoprodol 350mg 60 1 30 12/29/17 10 day supply 1/17/18 carisoprodol 350mg 60 30 1/2/18 30 day supply 1/18/18 carisoprodol 350m g , alprazolam 2 mg 60 30 90 1 30 1/17/i8 30 day supply 2/28/18 2/13/18 30 dav supply 3/22/18 [ alprazolam 2mg 15 5 2/28/18 30 day supply 3/22/18 alprazolam 2mg 33 | 11 2/28/18 30 day supply 3/22/18 h 4/12/18 alprazolam 2mg | 42 14 2/28/18 30 day supply carisoprodol 350mg I 90 30 3/22/18 30 dav supply 5/3/18 1 carisoprodol 350mg 1 90 30 4/12/18 30 day supply 5/23/18 | carisoprodol 350mg 1 3 1 5/9/18 30 day supply 5/23/18 i alprazolam 2mg j 90 30 5/5/18 31 day supply d/13/18 | alprazolam 2 mg | 90 _ J 30 | 5/23/18 30 day supply

• In spite of Patient A’s approximate two-month absence from Dr. Bajwa’s practice prior to the patient's December 22, 2017, office visit (due to the patient’s attempt at another detox/rehab via the inpatient/outpatient CATS program), and although Dr. Bajwa checked Patient A’s PMP report on December 18, 2017, prior to the visit, and thus knew Patient A was prescribed Suboxone by another provider while absent from his practice, Dr. Bajwa failed to consult with the Suboxone prescriber to coordinate Patient A’s care, or document having done so, and did not request medical records connected to the patient’s Suboxone therapy. • In spite of the significant risk of central nervous system depression when Suboxone is taken with benzodiazepines, other sedative-hypnotics, and muscle relaxants. Dr. Bajwa nonetheless resumed prescribing alprazolam, eszopiclone, and carisoprodol at Patient A’s December 22,2017, office visit. • On April 4, 2018, Patient A was taken to Inova Fair Oaks Hospital via EMS with a suspected poly-substance overdose requiring ventilator support. EMS reported that Patient A was found with an empty bottle of alprazolam, and bottles of Suboxone, clonazepam, Phenergan, Lexapro, catapres, vistaril, gabapentin, and Lunesta (cszopiclone). After reviewing Patient A’s PMP report and noting the prescriptions from Dr. Bajwa, Patient A’s treating physician called Dr. Bajwa to discuss Patient A’s condition, and documented that Dr. Bajwa took her phone number but never called her back. In spite of actual notice of Patient A’s overdose. Dr. Bajwa nonetheless immediately resumed prescribing benzodiazepines, other sedative-hypnotics, a muscle relaxant, and a stimulant to Patient A as follows: Date Written Filled Medicadon/Dofe Quantity Days Supply 4/12/18 4/13/18 zolpidem lOmg 15 15 4/12/18 4/16/18 zolpidem lOmg 1 15 1 15 4/12/18 4/13/18 clonazepam 2mg 30 15 4/12/18 4/13/18 carisoprodol 350mg IKT rw~ 4/23/18 4/23/18 alprazolam 2mg 45 15 4/23/18 4/23/18 methylphenidate ER18 mg 30 30 4/23/18 4/23/18 eszopiclone 3 mg 5 5 4/23/18 4/27/18 eszopiclone 3 mg 4 4 4/23/18 4/28/18 eszopiclone 3 mg 21 21

• On April 28,2018, Patient A was admitted to Fairfax Hospital with another benzodiazepine overdose. The treating physician noted Patient A’s years’ long history of drug misuse and overdoses, particularly with benzodiazepines, her overdose risk score of 950/999, and the quantity of benzodiazepines Patient A had received in the prior month from Dr. Bajwa and others. Based on the provider’s assessment and “concern for death related to OD when she is released,” this physician notified Dr. Bajwa of Patient A's overdose on or about April 28,2018. In spite of notification of a second benzodiazepine overdose in less than a month, Dr. Bajwa promptly continued prescribing Patient A benzodiazepines and muscle relaxants as set forth below:
rDate Written Filled Medkation/Dose Quantity i Days Supply 5/3/18 5/4/18 carisoprodol 350mg 90 30 5/5/18 5/9/18“ gabapentin 600 mg 90 5/5/18 5/5/18 alprazolam 2mg z0~ l“7 5/5/18 5/7/18 alprazolam 2mg 45“ 15 5/5/18 5/8/18 alprazolam 2mg 25 9 5/9/18 5/9/18 temazepam (C-IV) 30mg 30 30 5/9/18 5/9/18 carisoprodol 250 mg 108 30 5/9/18 5/9/18 carisoprodol 250 mg 12 3 5/9/18 5/9/18 carisoprodol 250 mg 18 30 |

smeared make-up, and admitting that she had filled prescriptions written the day before by Dr. Bajwa for alprazolam 2mg #90, carisoprodol 350mg #3, zolpidem lOmg #15, and triazolam (C-IV) 0.25mg #10 prior to presenting to CATS. • On May 28, 2018, Patient A was admitted to Fair Oaks Hospital with her fourth poly-substance overdose in approximately a month, and again required ventilator support. She was discharged home on June 5,2018, with an alprazolam taper and information regarding community resources because no inpatient facility would accept her transfer. • In spite of Dr. Baj wa’s knowledge of Patient A*s abuse of the medications he prescribed, Dr. Bajwa continued prescribing Patient A multiple benzodiazepines, other sedative- hypnotics, and muscle relaxants through August 2018 as follows: Date Written Date Filled Medication/Dose Quantity Days Supply i 6/6/18 6/6/18 temazepam 30m g 15 30 I 6/13/18 6/27/18 eszopiclone 3 mg 30 30 1 6/13/18 6/18/18 alprazolam 2mg 30 10 6/13/18 6/22/18 alprazolam 2mg 60 20 6/14/18 6/14/18 r6/29/18 diazepam lOmg 14 14 6/29/18 diazepam lOmg 14 H 7/2/18 7/2/18 carisoprodol 250m g 20 20 1 7/13/18 7/19/18 alprazolam 2mg 33 n 7/13/18 7/18/18 alprazolam 2mg 6 2 1 7/13/18 7/16/18 | alprazolam 2mg e : 2 7/13/18 7/16/18 gabapentin 300mg 45 15 1 7/19/18 7/19/18 eszopiclone 3 mg 16 15 7/27/18 7/27/18 alprazolam 2mg 45 Is 1 7/27/18 7/27/18 zolpidem 10 mg 15 15 . 8/18/18 8/10/18 8/18/18 temazepam 30mg 7 7 8/13/18 alprazolam 2rog 60 20 1 8/10/18 8/13/18 zolpidem lOmg 30 30 1 8/10/18 8/13/18 gabapentin 300mg 90 30 ,

b. Regarding Dr. Bajwa’s treatment of Patient B, a then 22-year-old male, for complaints of anxiety from approximately January 2017 until his death due to fentanyl, morphine, and alprazolam intoxication on January 21,2018: i. Absent any assessment or documentation of symptoms or a substance use history and risk assessment. Dr. Bajwa prescribed Patient B alprazolam lmg #90 (30-day supply) at his second office visit on February 4,2017 visit, based on only the patient’s report of "moderate" anxiety and his claim that he had taken alprazolam in the past. Only four days later, on February 8,2017, Dr. Bajwa ism authorized a telephone prescription for alprazolam 2mg TID #45 (15-day supply), a substantial dosage increase, without documenting any therapeutic purpose for doing so in the medical record ii. Also at his February 4,2017 visit. Patient B complained of “muscle spasms, esp. lower back. ’ Although Patient B disclosed his previous back surgery, Dr. Bajwa foiled to obtain or document a detailed history related to such surgery, including prior treatments and therapies, before prescribing carisoprodol 350mg #30 (30-day supply). iii. During a February 24, 2017 visit, Dr. Bajwa prescribed hydrocodone/acetaminophen (C-H) 10/325mg #30 (15-day supply) at Patient B’s specific request due to an “exacerbation of back pain,’ without conducting an examination, ordering diagnostic testing, obtaining prior treatment records, or referring the patient for an appropriate woik-up and further treatment. iv. On March 27, 2017 and November 17, 2017, Dr. Bajwa respectively prescribed Patient B oxycodone/acetaminophen (C-II) 10/325mg #60, a 30-day supply, and oxycodone/acetaminophen 10/325mg #14, a 7-day supply, at Patient B’s specific request, while foiling to satisfy provisions of the Board’s Prescribing Regulations. Specifically, Dr. Bajwa foiled to do the following: • Document having considered nonpharmacologic and non-opioid treatment for Patient B’s complaints of pain, as required by 18 VAC 85-21-30(A). • Perform a history and physical examination appropriate to the complaint, query the patient’s PMP report, and conduct an assessment of the patient’s history and risk of substance misuse prior to initiating treatment with an opioid, as required by 18 VAC 85- 21-30(B). • Document the extenuating circumstances justifying more than a seven-day supply, as required by 18 VAC 85-21-40(A)(1). • Prescribe Naloxone when co-prescribing opioids and benzodiazepines or carisoprodol, as required by 18 VAC 85-21-40(B)(3). by 18 VAC 85-21-40(C). • Document a description of the pain, a presumptive diagnosis for the origin of the pain, an examination appropriate to the complaint, and a treatment plan, as required by 18 VAC 85- 21-50. v. Dr. Bajwa failed to monitor and manage Patient B’s use of the controlled substances he was prescribing. Specifically: • Dr. Bajwa continued to prescribe opioids, several different benzodiazepines, and carisoprodol to Patient B without taking responsive action even though his check of the patient’s October 18, 2017 PMP report revealed that Patient B received Suboxone on October 4,2017. • Although Dr. Bajwa admitted in his statement to the Board that he learned from the patient’s mother that Patient B had a significant substance abuse and addiction history, including approximately two-years of intravenous heroin addiction and daily use, as well as opioid and benzodiazepine addiction and misuse, Dr. Bajwa failed to obtain or document a comprehensive mental health and substance misuse history, and did not take any steps to obtain the patient’s prior treatment records or coordinate with the patient’s other treating providers. • Even after learning of Patient B’s addiction and drug misuse history, Dr. Bajwa continued to prescribe controlled substances to the patient without monitoring or managing the elevated risk as follows: o Dr. Bajwa continued to prescribe Patient B alprazolam 2mg #90 and carisoprodol 350mg #90 approximately monthly from October 2017 through Patient B’s death in January 2018 without conducting a single urine drug screen (UDS) or pill count o Although Dr. Bajwa claimed in his statement to foe Board that he checked Patient B’s PMP report “with every visit,” his PMP Access Audit records show that Dr. Bajwa prescribed controlled substances at office visits without checking the patient’s PMP report on February 4,2017; March 22,2017; March 27,2017; April 13,2017; August 14, 2017; and September 9, 2017; and authorized telephonic prescriptions without checking foe patient’s PMP report on February 8,2017; June 9,2017; and January 15, 2018, approximately a week before Patient B’s fatal overdose. o On November 7,2017, Dr. Bajwa added lorazepam lmg #14 (7-day supply) to Patient B’s medication regimen for foe first time absent any documentation in foe medical records supporting a therapeutic purpose for foe medication. vi. Patient B voluntarily entered foe Farley Center on January 6,2018, for drug detox and substance abuse treatment. On January 15,2018, although he had not seen Patient B in a month. —— A XUUAKlPICjr Dr. Bajwa authorized telephonic prescriptions for alprazolam 2mg #90 and carisoprodol 350mg #90. Patient B was administratively discharged from drug treatment on January 17,2018, after he was found with the drugs Dr. Bajwa prescribed. Patient B died on January 21,2018, as a result offentanyl, morphine, and alprazolam intoxication. c. Regarding Patient C, a then 29-year-old male, to whom Dr. Bajwa prescribed controlled substances from approximately January through August 2018: i. At Patient C’s first visit on January 30, 2018, Dr. Bajwa prescribed oxycodone/acetaminophen 7.5/325mg #14 (7-day supply) in response to Patient C’s specific request and on May 25, 2018, again prescribed that medication for vague complaints of “moderate” back pain; prescribed oxycodone 15mg #60 (20-day supply) on June 4,2018, when Patient C presented after a hip fracture and surgical repair requesting pain medication; prescribed oxycodone 15mg #30 (10-day supply) on August 13,2018, for further complaints of pain related to the patient’s May 2018 hip fracture; and co-prescribed alprazolam, while foiling to satisfy provisions of the Board’s Prescribing Regulations. Specifically, Dr. Bajwa foiled to do the following: • Consider or document having considered nonpharmacologic and non-opioid treatment for Patient C’s complaints of pain prior to treatment with an opioid, as required by 18 VAC 85-21-30(A). • Perform a history and physical examination appropriate to the complaint, query the patient’s PMP report, and conduct an assessment of the patient’s history and risk of substance misuse prior to initiating treatment with an opioid, as required by 18 VAC 85- 21-30(B). • Document the extenuating circumstances justifying prescribing greater than a seven-day supply of opioids on June 4, 2018 and August 13, 2018, as required by 18 VAC 85-21- 40(A)(1).
on June 4, 2018, in addition to the May 29, 2018, prescriptions for oxycodone Smg #84 and morphine ER 15mg #40 that Patient C received from Fairfax Hospital on discharge after hip surgery, resulting in a total MME/day of 160.5, as required by 18 VAC 85-21- 40(B)(2). • Prescribe Naloxone when prescribing opioids in doses exceeding 120 MME/day and/or when co-prescribing opioids and benzodiazepines, as required by 18 VAC 85-21-40(B)(3). • Document die extenuating circumstances justifying co-prescribing alprazolam with opioids and a tapering plan to achieve the lowest possible effective medication doses, as required by 18 VAC 85-21-40(C). • Document a description of the pain, a presumptive diagnosis for the origin of the pain, an examination appropriate to the complaint, and a treatment plan, as required by 18 VAC 85- 21-50. ii. Based on Patient C’s complaint of Attention Deficit Hyperactivity Disorder (ADHD) and request for medication “refills” at his first office visit on January 30, 2018, Dr. Bajwa had Patient C complete half of the 18-question Adult ADHD-Rating-Scale-IV, a self-assessment tool used as one part of a comprehensive ADHD work-up. Had Dr. Bajwa checked the patient's PMP report, he would have seen that Patient C was not in need of “refills,” in that Patient C had not been prescribed Adderall or any other stimulant in file prior two years. Nonetheless, without conducting a comprehensive work-up or documenting any assessment as to whether Patient C’s symptoms were clinically consistent with a diagnosis of ADHD, Dr. Bajwa prescribed Patient C Adderall (C-II) 15mg #60 (30-day supply). iii. Dr. Bajwa failed to monitor and manage Patient C’s use of controlled substances, and continued to prescribe multiple controlled substances to Patient C when he knew or should have known that Patient C was exhibiting signs and symptoms of addiction or medication overuse, abuse, or misuse. Specifically: • AthisMarch 14,2018 visit. Patient C complained that his Adderall 15mg prescription (#30 filled March 5, 2018) was “not strong enough & wants dose adjusted.” Patient C also reported that he was using the previously prescribed alprazolam lmg more frequently than as prescribed. Notwithstanding this overuse of prescribed medication and medication seeking behavior, and absent a PMP report check, Dr. Bajwa prescribed alprazolam lmg TID #90, and Adderall 20mg BID #60, thus significantly increasing the daily dosage of JUUUUilU both medications without a valid therapeutic reason for doing so. • At an April 19,2018 office visit, Dr. Bajwa provided new prescriptions for Adderall 20mg #60 and alprazolam lmg #90 (both filled April 19,2018) when Patient C stated that “he lost his meds & needs early refill.” • At his May 21, 2018 visit. Patient C complained that alprazolam “lmg not strong enough & needs dose adjusted." Absent any documentation supporting a therapeutic purpose or need for increasing the dose above the manufacturer recommended dose of 4mg/day, Dr. Bajwa doubled the strength and prescribed alprazolam 2mg #90 (30-day supply). Four days later, on May 25,2018, Patient C stated his alprazolam was “taken from him & needs refill,” and Dr. Bajwa prescribed alprazolam 2mg #90 (30-day supply). • Dr. Bajwa admitted in his statement to the Board that he recommended Patient C see a psychiatrist However, when Patient C declined, and stated that he wanted only Dr. Bajwa to “treat his psychiatric conditions,” Dr. Bajwa took no action and continued to prescribe benzodiazepines and amphetamines. • Although Dr. Bajwa noted that Patient C was treated at Fairfax Hospital after being hit by a car, he failed to review or request those medical records or speak with any of those providers. Had he done so, he would have learned the fallowing: o Patient C suffered a fracture to his right acetabulum during a fight outside a bar, rather than a car accident, which necessitated surgical repair. o During his admission, he admitted to recreational drug use including marijuana. o While hospitalized, he was found taking controlled substances from home, not taking the pain medication given to him in the hospital and instead, “saving it for later.” o The patient’s wife and friend were noted to have slurred speech and unsteady gaits while visiting Patient C.

  1. Dr. Bajwa violated Virginia Code §§ 54.1-2915(A)(3), (12), (13), (16), (17), and (18), 54.1- 3303(A), and 54.1-3408(A) and 18 VAC 85-20-26(C) of the Board’s General Regulations in his care and treatment of Patients D-H between July 2015 and May 2017. Specifically: a. Regarding Patient D, a then 31-year-old female and spouse of Patient E, who presented to Dr. Bajwa on May 19,2014, with a chief complaint of neck pain and muscle spasms recently exacerbated: i. Although Dr. Bajwa told Patient D that he would not prescribe her any narcotics, he nonetheless prescribed tramadol 50mg #150 at the patient’s first visit, absent a diagnosis and without reviewing or attempting to obtain prior medical records or imaging reports, developing a treatment plan, or ordering a workup for the patient’s complaint of neck pain. ii. In spite of noting on multiple occasions that Patient D was obtaining Norco (hydrocodone/acetaminophen) from her gynecologist for endometriosis. Dr. Bajwa began prescribing Patient D oxycodone lOmg #60 (30-day supply) on July 15,2015 for complaints of pelvic pain. Dr. Bajwa failed to document whether he checked the patient’s PMP report and did not document any psychiatric or substance use history, nor did Dr. Bajwa communicate with Patient D’s gynecologist in order to coordinate their opioid prescribing. iii. Dr. Bajwa continued to prescribe tramadol and oxycodone to Patient D regularly for complaints of neck pain even though a September 7, 2014, MRI showed only mild degenerative cervical spondylosis. Moreover, Dr. Bajwa failed to initiate any treatment other than opioids for the patient’s neck pain (e.g, neuromodulators, physical therapy), and failed to refer the patient for an appropriate evaluation and treatment of her neck pain. iv. Patient D presented to Dr. Bajwa’s office on December 24,2015,24 hours after undergoing a laparoscopic total hysterectomy and right salpingectomy requiring an overnight hospital stay. Patient D complained of post-operative pain and told Dr. Bajwa that hydromozphone had worked well for her in the past. Without checking the patient’s PMP report or verifying with the surgeon and/or hospital what medications the patient had received in the hospital and were prescribed/provided to her at discharge. Dr. Bajwa prescribed hydromorphone 4mg #30 (15-day supply), and oxycodone 30mg #30 (15-day supply). v. Dr. Bajwa continued prescribing opioids to Patient D through April 2017 for complaints of neck and pelvic pain, routinely prescribing such medications prior to the time the
    prescriptions should have needed to be refilled had the medications been taken as prescribed, and without addressing Patient D’s overuse of the opioids he was prescribing, as follows: Date Written Medication Dose/ Quantity Days Supply Per PMP Report/MME Date Previous Rx Days Supply for Prior Rx Per PMP Report 8/5/15 Oxycodone lOmg #30 30/15 7/15/15 B0 day supplv 8/5/15 Tramadol 50mg #120 '30/20 7/15/15 30 day supply 8/31/15 Oxycodone lOmg #60 30/30 8/5/15 30 day supply 8/31/15 Tramadol 50mg #130 21/31 8/5/15 30 day supply 9/23/15 Oxycodone lOmg #60 30/30 8/31/15 30 day supply 1/4/16 Oxycodone 15mg #60 30/45 12/24/15 15 day supply 1/20/16 Oxycodone 30mg #90 30/135 1/4/16 30 day supply 1/20/16 Tramadol 50mg #90 30/15 1/4/16 30 day supply 4/22/16 Oxycodone 30mg #90 30/135 3/31/16 |B0 day supply 6/29/16 Oxycodone 30mg #90 30/135 6/6/16 30 day supplv 6/29/16 Tramadol 50mg #90 30/15 6/6/16 30 day supply 8/15/16 Tramadol 50mg #90 30/15 7/22/16 30 day supplv 9/7/16 Tramadol 50mg #30 30/5 8/15/16 30 day supply 3/13/17 Oxycodone 30mg #150 25/270 2/24/17 30 day supply 3/31/17 Oxycodone 30mg #180 30/270 3/13/17 25 day supply 4/24/17 | Oxycodone 30mg #180 30/270 3/31/17 30 day supply

vi. Dr. Bajwa began prescribing Patient D clonazepam 0.5mg #60 (30-day supply) on January 20, 2016, absent any documentation in the medical record supporting a therapeutic need, and without documenting any psychiatric or substance use history. On February 24,2017, Dr. Bajwa significantly increased the daily dosage of clonazepam prescribed to 2mg #60 (30-day supply) absent any documentation supporting a therapeutic need for doing so. b. Regarding Patient E, a then 29-year-old male, and spouse of Patient D: i. Patient E presented to Dr. Bajwa on June 5,2014, to establish care, with a chief complaint of “hip pain” for which the patient was prescribed OxyContm, oxycodone, and tramadol by a physician at an orthopedic and spine care practice in the recent past. Although Dr. Bajwa told Patient E that he “would not write any narcotics for him,” Dr. Bajwa nonetheless prescribed Patient E tramadol 50mg 1-2 tabs TID pm #150 on that date without performing a physical exam, formulating a diagnosis, obtaining a detailed history including substance use, checking the patient’s PMP report, conducting a UDS, developing a treatment plan, or coordinating his care with other treating providers. ii. In spite of telling Patient E he would not prescribe narcotics, on July 1, 2015, Dr. Bajwa prescribed oxycodone/acetaminophen 10/325mg #30 (30-day supply) for a diagnosis of hip pain without having checked the patient's PMP report, verifying with Patient E's other treating providers that they were not also concurrently prescribing controlled substances, conducting a UDS, or documenting a treatment plan. iii. Dr. Bajwa continued prescribing Patient E opioids through May 2017 when he knew or should have known that the patient was exhibiting signs of addiction and misuse. Specifically: • Dr. Bajwa steadily increased the strength and/or quantity of oxycodone he prescribed Patient E based on the patient’s specific requests on July 24, 2015; August 19, 2015; October 10, 2015; November 23, 2015; December 17, 2015; February 2, 2016; June 21, 2016; and August 5,2016. , • Dr. Bajwa prescribed Patient E fentanyl lOOmcg #15 on September 3, 2016 because the patient “has friend on fentanyl & wants to see if this will be more effective.” Moreover, Dr. Bajwa prescribed hydromorphone 8mg #30 to Patient E on January 18,2017 when the patient complained that the cold weather made his pain worse, and because “He tried Dilaudid in past and requests one/day as needed.” • Dr. Bajwa failed to take any steps to monitor Patient E’s drug use by performing UDS’ or regularly checking, or documenting having checked, the patient’s PMP report. • Dr. Bajwa prescribed opioids prior to the time the prescriptions should have needed to be refilled if the medications were taken as prescribed and failed to take any appropriate responsive action in spite of the patient’s demonstrated overuse of opioids, as set forth below: Date Written Medication Dose/ Quantity Days Supply Per PMP Report/MME Date of Previous Rx Days Supply for Prior Rx Per PMP Report 7/24/15 oxycodone lOmg #60 '30/30 7/1/15 30 day supply 10/29/15 oxycodone 15mg #60 30/45 r 10/5/15 30 day supply 11/23/15 tramadol 50mg #120 30/20 10/29/15 j 30 day supply 11/23/15 oxycodone 30mg #60 30/90 10/29/15 30 day supply 12/17/15 oxycodone 30mg #90 30/135 11/23/15 1 30 day supply

12/17/15 tramadol 50mg #90 30/15 11/23/15 30 day supply 1/11/16 oxycodone 30mg #90 30/135 12/17/15 30 day supply 1/11/16 tramadol 50mg #90 30/15 12/17/15 30 day supply 2/5/16 oxycodone 30mg #90 30/135 1/11/16 30 dav supply 2/5/16 tramadol 50mg #90 30/15 1/11/16 30 day supply 2/29/16 tramadol 50mg #60 '30/10 2/5/16 30 dav supply 2/29/16 oxycodone 30mg #120 30/180 2/5/16 30 day supply 5/6/16 tramadol 50mg #60 30/10 14/15/16 30 day supply 5/6/16 oxycodone 30mg #120 30/180 14/15/16 30 dav supply 5/31/16 tramadol 50mg #60 130/10 5/6/16 [30 dav supply 6/21/16 oxycodone 30mg #150 25/270 5/31/16 [30 day supply 8/5/16 oxycodone 30mg #180 30/270 7/15/16 30 day supply 8/26/16 oxycodone 30mg #180 30/270 8/5/16 30 dav supplv 9/19/16 oxycodone 30mg #180 30/270 8/26/16 30 dav supph 10/10/16 oxycodone 30mg #180 30/270 9/19/16 30 dav supph 2/9/17 hydromorphone 8mg #30 30/32 1/18/17 30 day supply 2/9/17 oxycodone 30mg #150 25/270 1/18/17 25 dav supply 3/2/17 oxycodone 30mg #180 30270 2/9/17 25 day supply 3/21/17 oxycodone 30mg #180 30/270 3/2/17 30 day supply 4/12/17 oxycodone 30mg #180 30/270 3/21/17 30 day supply 5/6/17" oxycodone 30mg #180 30/270 4/12/17 30 day supply

c. Regarding Patient F, a then 48-year-old female: i. Dr. Bajwa began prescribing alprazolam lmg #90 (30-day supply) on July 6, 2015 for a diagnosis of anxiety, absent any assessment or description of the patient’s symptoms or substance use history. ii. At Patient F's next visit on August 8, 2015, Dr. Bajwa began prescribing carisoprodol 350mg #60 (30-day supply) for a diagnosis of muscle spasms, absent any documented physical examination, description of symptoms, or associated information relating to the spasms. iii. Dr. Bajwa began prescribing opioids regularly to Patient F on December 8, 2015 for complaints of back pain at the request of another physician. Although a November 6,2012 MRI report included in Dr. Bajwa’s records showed only mild encroachment of the left neural foramen at L4- 5, Dr. Bajwa nonetheless continued regularly prescribing hydromorphone 4mg #120 (30-day supply) and methadone lOmg #120 (two tabs BID, 30-day supply) (total 384 MME/day) through October 2016. iv. Dr. Bajwa failed to monitor and manage Patient F’s use of controlled substances, in that he did not conduct any UDS* or pill counts during the treatment period. Moreover, Dr. Bajwa failed to respond to the patient’s overuse of the controlled substances he was prescribing, and regularly provided prescriptions prior to the time the medications should have needed to be refilled had Patient F taken them as prescribed, as set forth below: Date Written Medication Doie/Quantity Days Supply PerPMP Report/MME Date of Previous Rx i Days Supply for Prior Rx PerPMP Report 2/24/16 alprazolam lmg #90 30 2/1/16 30 1 2/24/16 carisoprodol 350rag #90 30 2/1/16 30 1 2/24/16 methadone lOmg #120 30/320 2/1/16 30 1 2/25/16 hydromorphone 4mg #120 30/64 r2/1/16 30 1 3/22/16 hydromorphone 4mg #120 30/64 2/25/16 30 3/22/16 methadone lOmg #120 30/320 2/24/16 30 6/6/16 alprazolam lmg #90 30 5/16/16 30 6/6/16 carisoprodol 350mg #90 30 5/16/16 J0 1 6/6/16 hydromorphone 4mg #120 30/64 5/16/16 30 6/6/16 methadone lOmg #120 30/320 5/16/16 30 6/27/16 alprazolam lmg #90 30 6/6/16 30 6/27/16 carisoprodol 350mg #90 30 6/6/16 30 6/27/16 hydromorphone 4mg #120 30/64 6/6/16 30 6/27/16 methadone lOmg #120 30/320 6/6/16 30 7/8/16 methadone lOmg #120 30/320 6/27/16 30 7/18/16 hydromorphone 4mg #120 30/64 6/27/16 30 8/12/16 hydromorphone 4mg #120 30/64 7/18/16 3° r 9/6/16 hydromorphone 4mg #120 30/64 8/12/16 30 9/6/16 methadone lOxng #120 30/320 8/12/16 30 10/27/16 1 alprazolam lmg #90 30 10/4/16 30 10/27/16 1 hydromorphone 4mg #120 30/64 10/4/16 30 10/27/16 methadone lOmg #120 30/320 10/4/16 30

d. Regarding Patient O, a then 48-year-old female: i. Dr. Bajwa prescribed Patient G oxycodone/acetaminophen 5/325mg #30 (15-day supply) at her first visit on February 9, 2016, for her complaint of shoulder pain without performing or documenting an appropriate physical examination, obtaining a detailed medical and substance use history, or obtaining or reviewing prior medical records. Three days later, Dr. Bajwa now increased the oxycodone/acetaminophen to 10/325mg BID #30 at the patient's request absent documentation of any therapeutic support for that change in the medical record. ii. Dr. Bajwa continued prescribing Patient G oxycodone through 2017 and took no action in spite of the patient's signs of addiction and misuse. Specifically: • When Patient G reported at her March 8, 2016 visit that she had been taking the oxycodone/acetaminophen more frequently than prescribed. Dr. Bajwa increased the prescription to TID, and then increased it to QID at the patient's request during her next visit on March 21,2016, without any documentation supporting a therapeutic need for the increased dose at either visit. • In spite of a June 2016 MRI and orthopedic consult diagnosing shoulder tendinosis, and recommending a steroid injection, physical therapy, and anti-inflammatories, Dr. Bajwa continued prescribing oxycodone/acetaminophen through April 2017, did not prescribe anti-inflammatory medication, and did not require Patient G to follow through with physical therapy and steroid injections as conditions of treatment. In addition to prescribing oxycodone/acetaminophen in spite of the orthopedist’s recommendation, Dr. Bajwa added hydromorphone 4mg #60 (15-day supply) to Patient G’s drug regimen on March 22,2017 due to “increased pain at night” • Dr. Bajwa failed to take any action in spite of the patient’s overuse of oxycodone/acetaminophen, and regularly prescribed opioids prior to the time the prescriptions should have needed to be refilled if taken as prescribed, as follows: Date Written Medlcation/Qnantlty Days Supply per PMP Report/MME Date Previou* Rx Days Supply for Prior Rx Per PMP Report 3/8/16 oxycodone/acetaminophen 10/325mg #63 21/45 2/25/16 15 3/21/16 oxycodone/acetaminophen 10/325mg #120 30/60 3/8/16 21 5/2/16 oxycodone/acetaminophen 10/325mg

90 30/45 4/20/16 27 j

5/18/16 oxycodone/acetaminophen 10/325mg #120 30/60 5/2/16 30 7/26/16 oxycodone/acetaminophen 10/325mg

80 20/60 7/11/16 30

9/14/16 oxycodone/acetaminophen 10/325mg

30 7/64.5 9/7/16 27

9/19/16 oxycodone/acetaminophen 10/325mg #90 23/58.5 9/14/16 7 1/4/17 oxycodone/acetaminophen 7.5/325mg #120 30/45 12/30/16 30 1/25/17 oxycodone/acetaminophen 10/325mg 30/60 1/4/17 30 J

#120	!	

| 2/7/17 oxycodone lOmg #120 30/60 i 1/30/17 30

e. Regarding Patient H, a then 43-year-old male: i. Dr. Bajwa assumed the care, treatment, and regular controlled substance prescribing for Patient H from his prior physician, a psychiatrist and pain management specialist, in approximately November 2015. Dr. Bajwa failed to perform or document an appropriate physical examination; document appropriate information regarding the patient’s complaints of abdominal pain, including a diagnosis; document a substance use history; or develop or document a comprehensive treatment plan prior to prescribing hydromoiphone 4mg #60 (20-day supply), tramadol 50mg #120 (30- day supply), and diazepam lOmg #90 (30-day supply) at the first visit. ii. Although Dr. Bajwa’s records from the prior physician indicate that she was concerned the patient possibly had track/injection marks on his arms, Dr. Bajwa failed to follow up on this information by, for example, monitoring Patient H for the appearance of track marks or using UDS’ to ensure the patient’s compliance with his medication regimen. In spite of these concerns, Dr. Bajwa prescribed hydromoiphone and diazepam on December 7, 2015, December 19, 2015, and May 9, 2016, dates when those medications should not have needed to be refilled had Patient H taken them as prescribed, and failed to take any action in response to the patient’s overuse of hydromoiphone and diazepam.

  1. Dr. Bajwa violated Virginia Code §§ 54.1-2915(A)(3), (12), (13), (16), (17), and (18), 54.1- 3303(A), and 54.1-3408(A), 18 VAC 85-20-26(C) of the Board’s General Regulations, and 18 VAC 85- 21-60 to -120 of the Board’s Prescribing Regulations [effective for conduct on or after March 15, 2017], from approximately July 2015 through January 2018, with regard to his care and treatment of, and continuous prescribing of controlled substances to, Patients I and J, a married couple. Specifically: a. Regarding Patient I, a then 35-year-old female: i. Dr. Bajwa began prescribing diazepam lOmg #60 and zolpidem lOmg #30 to Patient I in July 2015 for diagnoses of insomnia and migraines without conducting or documenting a comprehensive physical examination, description of symptoms, or a substance use history and risk assessment, and notwithstanding the fact that diazepam is not indicated for the treatment of migraines. ii. Dr. Bajwa tailed to document any symptoms, findings, or rationale supporting his prescribing of alprazolam to Patient I, given that benzodiazepines and other sedative- hypnotics are generally not recommended for the treatment of migraines, nor did Dr. Bajwa confirm a therapeutic purpose for such prescribing through a neurological workup. iii. Dr. Bajwa prescribed Patient I morphine sulfate ER 60mg BID #60 on August 14,2015, at the request of another physician “for August” due to an “insurance change.” Although Dr. Bajwa’s diagnoses supporting this prescription were insomnia, migraines, and elevated cholesterol, he failed to document any explanation for prescribing medication not recommended to treat any of those documented diagnoses. Moreover, Dr. Bajwa failed to document any prior history related to such opioid prescribing, a physical examination, a description of the pain he was treating, a pain rating, or any other information in support of his prescribing. iv. On February 17, 2016, Dr. Bajwa became Patient I’s pain management provider, and began regularly prescribing her morphine sulfate ER 60mg #60 and hydromorphone 8mg #120 for the diagnoses of insomnia, migraines, and elevated cholesterol with insufficient medical support for such opioid prescribing documented in the patient’s record. Specifically, although Patient I’s chart included some prior records of her fourteen-year treatment with opioids for head, neck, and chronic “diffiise” pain by various physicians and a pain management clinic, among others, none of the records contained a definitive diagnosis supporting opioid therapy or documented a detailed substance use history. v. Although Patient I's pain management clinic records include a May 22, 2015, UDS positive for a metabolite of heroin, Dr. Bajwa failed to monitor and manage Patient I’s use of controlled substances, in that he failed to check the patient’s PMP report until May of 2017 and did not conduct any pill counts, UDS\ or take any other appropriate measures to determine whether Patient I was taking the medications as prescribed and was otherwise compliant during the time he prescribed controlled substances. vi. After Patient Ps five-month absence from Dr. Bajwa’s practice, he resumed prescribing morphine sulfate ER 60mg #60 and hydromorphone 8mg #120 to the patient on July 1,2016, after documenting merely “|chol, insomnia, migraines all 3 stable w/ meds” without any documentation regarding the patient’s absence or the performance or documentation of a physical exam or UDS. vii. Based on Patient Ps complaint of “ADHD symptoms” and request for medication “refills” at a July 3, 2017 office visit, Dr. Bajwa had Patient I complete half of the Adult ADHD-Rating-Scale-rV. Without conducting a comprehensive physical or mental examination or documenting any assessment as to whether Patient Ps symptoms were clinically consistent with a diagnosis of ADHD, Dr. Bajwa prescribed her Adderall 20mg #30 (30-day supply). b. Regarding Patient J, a then 34-year-old male, who Dr. Bajwa treated for complaints of anxiety and insomnia: i. Dr. Bajwa began prescribing diazepam lOmg BID #60 and Sonata (C-IV) lOmg QD #30 to Patient J in June 2015 for diagnoses of anxiety and insomnia without conducting or documenting a comprehensive physical examination, description of symptoms, a substance use history and risk assessment, or findings supporting a therapeutic purpose. ii. Dr. Bajwa prescribed Patient J moiphine sulfate ER 60mg BID #60 and hydromorphone 4mg TID #90 on August 14, 2015, at the request of another physician “for August” due to an “insurance change.” Dr. Bajwa’s diagnoses supporting the prescriptions were insomnia, hypertension, and GERD, conditions which did not warrant such opioid prescribing. Dr. Bajwa failed to
    document any prior history related to such prescribing, a physical examination, a description of the pain, a pain rating, or any other information in support of his prescribing opioids for the documented diagnoses. iii. Dr. Bajwa began prescribing Patient J carisoprodol 350mg #60 on November 16, 2015 based on the same diagnoses of hypertension, insomnia, and GERD, absent any documentation indicating a therapeutic or medicinal need for a muscle relaxant to treat the documented diagnoses. iv. On December 12, 2016, Dr. Bajwa assumed Patient J’s pain management and began regularly prescribing him morphine sulfate ER 60mg and hydromoiphone 8mg for diagnoses of hypertension, insomnia, and GERD without establishing sufficient medical support for such opioid prescribing in the patient’s record. Specifically, while Patient J’s chart included some prior records from Dr. Greene, those records contain documentation of only Patient J’s self-report of long-term back pain, but do not contain any documentation of a workup for back pain, imaging, referrals for further evaluation, or a definitive diagnosis and treatment. v. In spite of a May 2, 2016 progress note from another physician discussing a UDS positive for methadone, a medication not prescribed to Patient J, Dr. Bajwa failed to monitor and manage Patient J’s use of controlled substances, in that he failed to check the patient’s PMP report until May of 2017, did not conduct any pill counts or UDS’, or take any other appropriate measures to determine whether Patient J was taking the medications as prescribed and was otherwise compliant during the time he prescribed controlled substances. vi. In spite of the fact that Patient J had not had a work up for his back pain. Dr. Bajwa continued prescribing opioids to Patient J through January 2018 without conducting or referring Patient J for a work up to determine a diagnosis and appropriate treatment. c. Dr. Bajwa prescribed Patients I and J opioids regularly from March 2017 through January 2018 while failing to satisfy the provisions of the Board’s Prescribing Regulations. Specifically, Dr. Bajwa failed to: • Document a medical history and physical examination, to include a mental status examination, including: o The nature and intensity of the pain; o Current and past treatments far pain; o Underlying or coexisting diseases or conditions; o The effect of the pain on physical and psychological function, quality of life, and activities of daily living; o Psychiatric, addiction, and substance misuse history of the patient and any family history of addiction or substance misuse; o A urine drug screen or serum medication level; o A query of the PMP as set forth in § 54.1-2522.1 of the Code of Virginia; o An assessment of the patient's history and risk of substance misuse; and o A request for prior applicable records; as required by 18 VAC 85-21-60(A). • Discuss or document having discussed with Patients I and J the risks and benefits of opioid therapy and the patients’ responsibilities during treatment to include securely storing the drug and properly disposing of any unwanted or unused drugs, and an exit strategy far the discontinuation of opioids in the event they are not effective, as required by 18 VAC 85- 21-60(B). • Give consideration to nonpharmacologic and non-opioid treatment for pain prior to treatment with opioids, as required by 18 VAC 85-21-70(A). • Calculate the MME/day and, further, failed to document in the medical records the reasonable justification for prescribing Patients I and J opioids in quantities consistently resulting in a MME/day in excess of 120 far both, or refer the patients to or consult with a pain management specialist, as required by 18 VAC 85-21-70(BX2)- • Prescribe Naloxone to Patients I and J, whose risk factors included the prescription of opioid doses in excess of 120 MME/day and concomitant benzodiazepine prescribing, as required by 18 VAC 85-21-70(BX3). • Document the rationale to continue opioid therapy every three months, as required by 18 VAC 85-21-70(BX4). document in their medical records tapering plans to achieve the lowest possible effective doses of these medications, as required by 18 VAC 85-21-70(D). • Regularly evaluate the patients for opioid use disorder, or document having done so, as required by 18 VAC 85-21-70(E). • Document treatment plans for Patients I and J that state measures to be used to determine progress in treatment, including pain relief and improved physical and psychosocial function, quality of life, and daily activities; include further diagnostic evaluations and other treatment modalities or rehabilitation that may be necessary; and document the presence or absence of any indicators of medication misuse or diversion and take appropriate responsive action thereto, as required by 18 VAC 85-21-80(A) - (C). • Document in the medical record any discussion of informed consent with Patients I and J, nor did Dr. Bajwa obtain a signed written treatment agreement with either patient that addressed the parameters of treatment, including those behaviors that will result in referral to a higher level of care, cessation of treatment, or dismissal from care, and permission for Dr. Bajwa to query the patients’ PMP reports, obtain UDS\ serum or saliva medication levels, and consult with other prescribes or dispensing pharmacists, as required by 18 VAC 85-21-90(A)-(C). • Perform the following: o review the course of pain treatment and the patient's state of health at least every three months; o document and assess the continued benefit from such prescribing; o conduct and review a urine or serum drug screen at the initiation of chronic pain management and thereafter randomly at the discretion of the practitioner, but at least once a year, and o evaluate and document that he regularly evaluated the patients for opioid use disorder, as required by 18 VAC 85-21 -100(AMB), (D)-(E). • Keep current, accurate, and complete records in an accessible manner readily available for review including the medical history and physical examination; diagnostic, therapeutic, and laboratory results; evaluations; treatment goals; treatments; patient instructions; and periodic reviews, as required by 18 VAC 85-21-120. d. Dr. Bajwa failed to monitor and manage the care of Patients I and J, in that he repeatedly prescribed highly abusable controlled substances prior to the time the prescriptions should have needed to be refilled had the medications been taken as prescribed, and failed to take any responsive action to the patients’ obvious overuse of the drugs he was prescribing, as follows: Patient Date Medication/Quantity Days Supply Written per PMP Date Dayi Supply for Previous 1 Prior Rx Per

Iiiuuun> r Report/MM! Rx PMP Report J 3/1/17 hydromorphone 8mg #120 30/128 2/20/17 30 J 3/30/17 alprazolam 2mg #90 30 3/4/17 30 J 4/24/17 morphine sulfote ER 60mg #60 30/120 4/1/17 30 J 4/24/17 hydromorphone 8mg #54 14/124.8 3/30/17 30 J 5/22/17 hydromorphone 8mg #60 15/128 5/12/17 T5 J 5/30/17 hydromorphone 8mg #60 15/128 5/22/17 17 J 7/11/17 morphine sulfote ER 60mg #30 30/60 6/19/17 3d- J 7/11/17 hydromorphone 8mg #60 30/96 6/19/17 30 J 8/18/17 alprazolam 2mg #66 22 8/9/17 30 J 8/18/17 morphine sulfote ER 15mg #30 30/15 8/12/17 30 J 8/18/17 hydromorphone 8mg #60 30/64 8/9/17 ^0~ J 8/30/17 carisoprodol 350mg #60 30 8/9/17 30 J 9/12/17 hydromorphone 4m g #90 30/48 8/18/17 30 J 10/6/17 hydromorphone 4mg #75 30/10 9/12/17 30 J 10/16/17 alprazolam 2m g #90 30 9/20/17 30 J 10/25/17 hydromorphone 8mg #65 16/128 10/6/07 30 I 5/30/17 hydromorphone 8 mg #120 30/128 5/19/17 30 I 7/11/17 morphine sulfote ER 60mg #30 30/60 6/19/17 30 I 7/25/17 amphetamine 20mg #30 30 7/3/17 30 I 8/18/17 hydromorphone 4mg #90 30/48 8/4/17 30 I 12/11/17 amphetamine 20mg #30 30 11/17/17 i 30

  1. Dr. Bajwa violated Virginia Code §§ 54.1-2915(AX3), (12), (13), (16), (17), and (18), 54.1- 3303(A), and 54.1-3408(A); 18 VAC 85-20-26(C) of the Board’s General Regulations; and 18 VAC 85- 21-30 to -120 of the Board’s Prescribing Regulations (effective for conduct on or after March 15, 2017), from approximately May through October 2018 with regard to his care and treatment of Patients K-O, all of whom lived in the Winchester, Virginia area and travelled approximately 90 minutes each way to Dr. Bajwa’s Fairfax office. For example: a. Dr. Bajwa prescribed Patient K hydrocodone/acetaminophen 10/325mg #14 (7-day supply) on August 15,2018 and October 2,2018, and oxycodone lOmg (7-day supply) on September 11, 2018; Patient L oxycodone/acetaminophen 10/325mg #14 (7-day supply) on July 5,2018, July 19,2018, and August 8,2018, and hydrocodone/acetaminophen 10/325mg#20 (10-day supply) on August 13,2018; and Patient M oxycodone/acetaminophen 10/325mg #10 (5-day supply) on October 18,2018, while foiling to satisfy the provisions of the Board’s Prescribing Regulations. Specifically, Dr. Bajwa foiled to: _ . _ wt1 A'UAIVIALI HILAKIMI i. Document having considered nonphannacologic and non-opioid treatment for the patients’ complaints of pain, as required by 18 VAC 85-21 -30(A). ii. Prior to prescribing opioids, perform a history and physical examination appropriate to the complaint, query the patients* PMP reports, and conduct an assessment of each patient’s history and risk of substance misuse, as required by 18 VAC 85-21-30(B). iii. Document the extenuating circumstances justifying more than a seven-day supply when he prescribed Patient L hydrocodone lOmg #20 (10-day supply) on August 13, 2018, as required by 18 VAC 85-21-40(A)(1). iv. Prescribe Naloxone while co-prescribing benzodiazepines with opioids to Patients K, L» and M, as required by 18 VAC 85-21-40(B)(3). v. Document the extenuating circumstances justifying co-prescribing alprazolam with opioids to Patients K, L, and M, and also failed to document tapering plans for the patients to achieve the lowest possible effective medication doses, as required by 18 VAC 85-21-40(C). vi. Document a description of the pain, a presumptive diagnosis for the origin of the pain, an examination appropriate to the complaint, and a treatment plan for Patients K, L, and M, as required by 18 VAC 85-21-50. b. Dr. Bajwa provided chronic pain management from May through October 2018 to Patient N, prescribing hydrocodone/acetaminophen 10/325mg #14 (7-day supply) on May 29,2018, June 18, 2018, July 17,2018, September 28,2018, and October 6,2018; oxycodone lOmg #14 (7-day supply) on August 13,2018; hydrocodone/acetaminophen 7.5/325mg #14 (7-day supply) on September 6,2018; and tramadol 50mg #14 (7-day supply) on September 19, 2018, and October 15, 2018, while foiling to satisfy provisions of the Board’s Prescribing Regulations. Specifically, Dr. Bajwa foiled to: i. Document a medical history and physical examination, to include a mental status examination and: • The nature and intensity of the pain; • Current and past treatments for pain; • Underlying or coexisting diseases or conditions; • The effect of the pain on physical and psychological function, quality of life, and activities of daily living; • Psychiatric, addiction, and substance misuse history of the patient and any family history of addiction or substance misuse; • A UDS or serum medication level; • A query of the PMP as set forth in § 54.1-2522.1 of the Code of Virginia; • An assessment of the patient's history and risk of substance misuse; and • A request for prior applicable records; as required by 18 VAC 85-21-60(A). ii. Discuss with Patient N, or documenting having done so, the risks and benefits of opioid therapy and the responsibilities of Patient N during treatment to include securely storing the medication and properly disposing of any unwanted or unused medication, and an exit strategy for the discontinuation of opioids in the event they were not effective, as required by 18 VAC 85-21-60(B). iii. Give consideration to nonpharmacologic and non-opioid treatment for pain prior to treatment with opioids, as required by 18 VAC 85-21-70(A). iv. Prescribe Naloxone to Patient N as required for concomitant benzodiazepine use, and further, failed to document the rationale to continue opioid therapy every three months, as required by 18 VAC 85-21-70(B)(3), (4). v. Document the extenuating circumstances justifying his co-prescribing of oxycodone and hydrocodone/acetaminophen with alprazolam and carisoprodol, nor did Dr. Bajwa document in the medical record a tapering plan to achieve the lowest possible effective doses of these medications, as required by 18 VAC 85-21-70(D). vi. Regularly evaluate Patient N for opioid use disorder, or document having done so, as required by 18 VAC 85-21-70(E). vii. Document a treatment plan for Patient N’s chronic pain management, as required by 18 VAC 85-21-80(A). viii. Document in the medical record any discussion of informed consent with Patient N, nor did Dr. Bajwa obtain a written treatment agreement signed by Patient N in the medical record that addresses the parameters of treatment, including those behaviors that will result in referral to a higher level of care, cessation of treatment, or dismissal from care, and permission for Dr. Bajwa to consult with other prescribers, as required by 18 VAC 85-21-90(A)-{C). ix. Review the course of pain treatment and Patient N's state of health at least every three months; document the continued benefit from such prescribing; and check the patient’s PMP report at least every three months after the initiation of treatment, as required by 18 VAC 85-21-100(A)- (C). In fact, although Dr. Bajwa began prescribing opioids to Patient N in May 2018, he did not check the patient’s PMP report until October 6,2018. x. Keep current, accurate, and complete records in an accessible manner readily available for review including the medical history and physical examination and diagnostic, therapeutic, and laboratory results, as required by 18 VAC 85-21-120. c. Based on self-reports of a history of ADHD with stimulant treatment from Patients K-O, Dr. Bajwa had each patient complete an Adult ADHD-Rating-Scale-IV. Without performing a comprehensive physical or mental examination or documenting any assessment as to whether the patients’ symptoms were clinically consistent with a diagnosis of ADHD, Dr. Bajwa prescribed Patients K-0 stimulants continuously from approximately April through October 2018. d. Dr. Bajwa prescribed Patient O alprazolam lmg #60 (30-day supply) and zolpidem lOmg #30 (30-day supply) at her first office visit on October 1,2018, based solely on the patient's self- report of anxiety without conducting a comprehensive examination or documenting symptoms and findings supporting the patient's complaints. Moreover, although Patient O reported a history of depression. Dr. Bajwa failed to take or otherwise verify a detailed mental health and substance use history. Had Dr. Bajwa done so, he would have learned that Patient O had a history of substance misuse/abuse, including use of cocaine, heroin, PCP, alcohol, opioids, and benzodiazepines she purchased off the streets, as well as bipolar disorder treated with Geodon and Elavil.
  2. Dr. Bajwa violated Virginia Code §§ 54.1-2915(A)(3), (12), (13), (16), (17), and (18), 54.1- 3303(A), and 54.1-3408(A) and 18 VAC 85-20-26(C) of the Board’s General Regulations, with regard to his care and treatment of Patients P-T. For example: a. Regarding Patient P, a 39-year-old female, who Dr. Bajwa treated from approximately February 2018 through October 2018 fin* anxiety and ADHD: i. Dr. Bajwa prescribed Patient P alprazolam 0.5mg #30 (30-day supply) at her first office visit on February 22, 2018 based solely on the patient's self-report of anxiety without conducting a comprehensive examination, documenting symptoms or findings supporting the patient’s complaints, or verifying Patient P’s substance use and mental health history, through, for example, reviewing prior medical records. Had Dr. Bajwa done so, he would have learned that Patient P had a lengthy psychiatric history including diagnoses of bipolar disorder and borderline personality disorder, noncompliance with prescribed medications; substance misuse with cocaine, benzodiazepines, and amphetamines; and multiple psychiatric hospitalizations triggered by suicidal ideation occurring on December 13,2016, March 10,2017, March 31,2017, and November 28,2017. ii. At the same February 22, 2018 visit. Dr. Bajwa prescribed Patient P Adderall 20mg #30 (30-day supply) based solely on the patient’s self-report of an ADHD history, without conducting a comprehensive physical or mental examination or documenting any assessment as to whether the patient’s symptoms were clinically consistent with a diagnosis of ADHD. iii. Dr. Bajwa continued to prescribe multiple controlled substances to Patient P when he knew or should have known that she was exhibiting signs and symptoms of addiction or medication overuse/misuse, in that Dr. Bajwa authorized prescriptions for alprazolam and Adderall when Patient P should not have needed a refill of these medications had she taken them as prescribed, as follows: DateRx Written Medication Dose/Quantity Days Supply Per PMP Report Date Previous Rx l 2/22/18 Adderall 20mg #30 30 2/2/18 (from another provider) Adderall ER 30mg #30 30-day supply 4/7/18 alprazolam 2m g #33 11 p/19/18 30-day supply 6/11/18 Adderall 30mg #30 10 S/5/18 (from another provider) Adderall 1 ER 20mg #30 30-day supply 6/11/18 Adderall 30mg #60 30 S/5/18 (from another provider) Adderall 1 ER 20mg #30 30-day supply 7/6/18 alprazolam 2mg #90 30 6/11/18 30-day supply 7/31/18 alprazolam 2mg #90 30 7/6/18 30-day supply 7/31/18 Adderall 30mg #30 10 7/12/18 40-day supply 7/31/18 Adderall 30mg #60 20 7/12/18 40-day supply 9/7/18 j alprazolam 2mg #90 1 30 9/2/18 (from another provider) alprazolam lmg #42 14-day supply

iv. Dr. Bajwa increased the strength and/or quantity of alprazolam and Adderall he prescribed Patient P on March 16,2018, March 19,2018, April 17,2018, and April 19,2018, at the patient's request, without any therapeutic indication for doing so documented in the medical record. Patient P told the Department of Health Professions Investigator (Investigator) that because she was a Medicaid recipient, her monthly Adderall 30mg was limited to #60 (60mg/day), the maximum recommended daily dose. In order to avoid the Medicaid limit and obtain Adderall 30mg #90 (9Qmg/day) monthly, Patient P stated that she paid Dr. Bajwa cash for a “third” prescription at each visit and then paid out of pocket for the extra medication at the pharmacy. v. Had Dr. Bajwa responded to Patient P’s obvious drug seeking behavior, he might have learned that Patient P was admitted to several hospitals with various combinations of suicidal ideation, psychoses, and hallucinations on May 21,2018, June 17,2018, September 15,2018 (pursuant to a Temporary Detention Order (TDO)), and October 13, 2018 (pursuant to a TDO), related to her consumption of benzodiazepines and Adderall. b. Regarding Patient Q, a then 21-year-old male, who Dr. Bajwa treated from approximately June 2017 through August 2018: i. Absent a comprehensive psychiatric evaluation including a substance use history and risk assessment or documentation of symptoms or findings supporting a therapeutic purpose, Dr. Bajwa prescribed alprazolam lmg #30 (30-day supply) at the patient’s first office visit on June 1, 2017, based solely on the patient’s report of anxiety with panic attacks. At the same visit, Dr. Bajwa prescribed hydrocodone-chlorpheniramine ER #120 (12-day supply) based on the patient’s complaint of a cough that kept him “up at night,” without documenting a comprehensive physical exam or any explanation supporting an opioid as the appropriate treatment for a cough. ii. Although Dr. Bajwa stated in his written response to the Board that he prescribed to Patient Q based on the patient’s response to the medication, Dr. Bajwa doubled the alprazolam to 2mgon June 21,2017, without any documentation of the patient’s response, i.e., symptoms, triggers, or presentation, etc., and simply documented that the patient reported “lmg not effective.” Dr. Bajwa steadily increased Patient Q’s alprazolam to 2mg #90 (30-day supply) on August 28,2017, without any documentation explaining his decision to exceed the manufacturer’s recommended daily dose (4mg/day). iii. Although Patient Q was absent from Dr. Bajwa’s practice for approximately three months. Dr. Bajwa resumed prescribing alprazolam 2mg #90 (30-day supply) on February 2,2018, noting that the patient was stable with medications, without any documentation regarding the patient’s absence or the performance of any physical or mental examination. c. Regarding Patient R, a then 20-year-old female, who Dr. Bajwa treated from approximately December 2017 through August 2018: i. At Patient R’s first visit on December 8, 2017, Dr. Bajwa prescribed alprazolam 2mg #90 (30-day supply), a dose exceeding the manufacturer recommended maximum daily dose (4mg/day), based on the patient’s self-report of anxiety and claim that "She needs it 3x per day." Dr. Bajwa failed to obtain or document a detailed substance use or medical history or description of symptoms. Further, Dr. Bajwa failed to verify that the patient had taken alprazolam previously and if so, at what dose. Although Dr. Bajwa claimed in his statement to the Board that he checked the patient’s PMP report at each visit, the PMP Access Audit records show that he did not access Patient R's PMP report at any time while treating her. ii. At Patient R’s January 9,2018 visit, Dr. Bajwa documented that the patient “wants med for ADHD,” and had the patient complete an Adult ADHD-Rating-Scale-IV tool used as one part of a comprehensive ADHD work-up. Without conducting a comprehensive physical or mental examination or documenting any assessment as to whether the patient's symptoms were clinically consistent with a diagnosis of ADHD, Dr. Bajwa prescribed Adderall 20mg #60 (30-day supply) to the patient for ADHD on that date. d. Regarding Patient S, a then 19-year-old female, who Dr. Bajwa treated from June 2018 through July 2018: i. Absent a comprehensive psychiatric evaluation, including a substance use history and risk assessment, or documentation of symptoms or findings supporting a therapeutic purpose, Dr. Bajwa prescribed alprazolam 2mg #60 (30-day supply) at the patient’s first office visit on June 18, 2018, based solely on the patient’s report of anxiety with panic attacks. ii. At Patient S’s next visit on July 5,2018, Dr. Bajwa increased the patient’s
alprazolam to TID based on the patient's claim that she needed an extra pill to control the anxiety, absent any documentation in the medical record supporting his decision to exceed the manufacturer's recommended daily dose (4mg/day). Moreover, Dr. Bajwa admitted to the Investigator that he discussed the patient seeing a psychiatrist, but the patient only wanted Dr. Bajwa to treat her anxiety, and he did not recommend any other alternative or concomitant treatments. e. Regarding Patient T, a then 24-year-old male, who Dr. Bajwa treated from approximately February 2017 to March 2017: i. Dr. Bajwa prescribed alprazolam lmg #60 (30-day supply) at Patient T’s first visit on February 17,2017 based on the patient’s self-report of anxiety and having taken alprazolam lmg in the past, without documenting a comprehensive examination or obtaining a detailed substance use history. ii. At Patient T's second and final visit with Dr. Bajwa on March 9,2017, in addition to increasing the alprazolam to 2mg based only on the patient's report that lmg “was not effective,” Dr. Bajwa prescribed promethazine with codeine syrup for the patient's complaints of congestion and mild wheezing keeping him “up at night,” without documenting a comprehensive physical exam or any explanation supporting an opioid as the appropriate treatment for a cough*

  1. Dr. Bajwa violated Virginia Code § 54.1-2915(A)(3), (12), (13), (16), and (18) and 18 VAC 85-20-26(C) of the Board’s General Regulations, in that from approximately January 2014 through October 2018, he failed to maintain timely, accurate, and complete medical records for Patients A-T. For example: a. Although the complete medical records Dr. Bajwa produced to the Board for Patient D contain a new patient registration form dated April 1,2009, and lab results and other testing listing Dr. Bajwa as the ordering physician dated bade to 2010-2011, the office progress notes date back only to May 19,2014. b. Although the complete medical records Dr. Bajwa produced to the Board for Patient E contain a new patient registration form dated December 30, 2009, the office progress notes produced date back only to June 5, 2014. c. Although the complete medical records Dr. Bajwa produced to the Board for Patient F contain a new patient registration form dated January 24,2011, the office progress notes produced date back only to January 28,2014. d. The hand-written progress notes for Patients A-T are often identical for multiple patients, and are repetitive over time with little or no changes in chief complaint, symptoms, review of systems, and physical examination. For example, the physical examinations in support of opioid prescribing to treat low back pain for Patients B, C, F, J, K, L, and N all document, “moderate tenderness over lower lumbar paraspinous muscles." e. Although Dr. Bajwa prescribed multiple controlled substances with high abuse potential to Patients A-T, he had no signed medication management contracts with any patient, nor did he conduct any UDS* or pill counts on Patients A-T during die prescribing period. In feet, Dr. Bajwa told the Investigator that UDS monitoring is ‘‘only for pain patients taking opiates.’* f. The complete medical records for Patients A-T produced by Dr. Bajwa lack critical, relevant medical information to the care he was providing, including, for example, medication lists; complete vital signs; weight; plans of care; records of telephone consults, contacts, prescription authorizations; and/or complete problem lists.
  2. Dr. Bajwa violated Virginia Code § 54.1-2915(A)(4) in that he is incompetent to practice medicine and surgery with safety to his patients and the public, as evidenced by his care and treatment of Patients A-T between 2014 and 2018, as detailed above in Allegations 1-7.  See Confidential Attachment for the names of the patients referenced above.