Prudence Hall, M.D. Placed on Probation

Stephen Barrett, M.D.


Prudence Hall, M.D. who operates The Hall Center in Santa Monica, California, has been placed on probation by the Medical Board of California. In 2017, the board accused her of unprofessional conduct, negligence, and inadequate record-keeping in her management of two patient identified as "L.H." and "M.S." The accusation (reproduced below) stated:

In 2018, Hall signed a consent order under which was placed on probation for four years and required to complete (a) a comprehensive clinical competence assessment program, (b) a specified course in ethics, and (c) at least 40 hours of additional continuing education "aimed at correcting any areas of deficient practice or knowledge." She must also engage aboard-approved specialist to monitor her practice or engage in a board-approved professional enhancement program that includes chart reviews and periodic assessments. The board also barred her from supervising physician assistants or advanced practice nurses or representing herself as a specialist in obstetrics, gynecology, or "hormone therapy."

Hall has received testimonials from celebrity patients such as model Cindy Crawford and actress-author Suzanne and has promoted bioidentical hormone therapy as a featured guest on the Dr. Phil and Dr. Oz shows


XAVIER BECERRA
Attorney General of California
JUDITH T. ALVARADO
Supervising Deputy Attorney General
RANDALL R. MURPHY
Deputy Attorney General
State Bar No.165851
California Department of Justice
300 So. Spring Street, Suite 1702
Los Angeles, CA 90013
Telephone: (213) 897-2493.
Attorneys for Complainant

BEFORE THE
MEDICAL BOARD OF CALIFORNIA
DEPARTMENT OF CONSUMER AFFAIRS
STATE OF CALIFORNIA

In the Matter of the Accusation Against:

Prudence Elizabeth Hall, M.D.
406 Wilshire Blvd.
Santa Monica, CA 90401

Physician's and Surgeon's Certificate
No. G 41661,

Respondent.


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Case Nos. 800-2015-010885

 

ACCUSATION

 

Filed September 12, 2017

Complainant alleges:

PARTIES

1. Kimberly Kirchmeyer (Complainant) brings this Accusation solely in her official capacity as the Executive Director of the Medical Board of California, Department of Consumer Affairs (Board).

2. On or about March 24, 1980, the Medical Board issued Physician's and Surgeon's Certificate Number G 41661 to Prudence Elizabeth Hall, M.D. (Respondent). The Physician's and Surgeon's Certificate was in full force and effect at all times relevant to the charges brought herein and will expire on August 31, 2017, unless renewed.

JURISDICTION

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. The Medical Practice Act ("Act") is codified at sections 2000-2521 of the Business and Professions Code.

5. Pursuant to Code section 2001.1, the Board's highest priority is public protection.

6. Section 2004 of the Code states:

"The board shall have the responsibility for the following:

"(a) The enforcement of the disciplinary and criminal provisions of the Medical Practice Act.

"(b) The administration and hearing of disciplinary actions.

"(c) Carrying out disciplinary actions appropriate to findings made by a panel or an administrative law judge.

"(d) Suspending, revoking, or otherwise limiting certificates after the conclusion of disciplinary actions.

"(e) Reviewing the quality of medical practice carried out by physician and surgeon certificate holders under the jurisdiction of the board.

" "

7. Section 2234 of the Code, states:

"The board shall take action against any licensee who is charged with unprofessional conduct. In addition to other provisions of this article, unprofessional conduct includes, but is not limited to, the following:

"(a) Violating or attempting to violate, directly or indirectly, assisting in or abetting the violation of, or conspiring to violate any provision of this chapter.

"(b) Gross negligence.

"(c) Repeated negligent acts. To be repeated, there must be two or more negligent acts or omissions. An initial negligent act or omission followed by a separate and distinct departure from the applicable standard of care shall constitute repeated negligent acts.

"(1) An initial negligent diagnosis followed by an act or omission medically appropriate for that negligent diagnosis of the patient shall constitute a single negligent act.

"(2) When the standard of care requires a change in the diagnosis, act, or omission that constitutes the negligent act described in paragraph (1), including, but not limited to, a reevaluation of the diagnosis or a change in treatment, and the licensee's conduct departs from the applicable standard of care, each departure constitutes a separate and distinct breach of the standard of care.

"(d) Incompetence.

"(e) The commission of any act involving dishonesty or corruption which is substantially 'related to the qualifications, functions, or duties of a physician and surgeon.

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

"(g) The practice of medicine from this state into another state or country without meeting the legal requirements of that state or country for the practice of medicine. Section 2314 shall not apply to this subdivision. This subdivision shall become operative upon the implementation of the proposed registration program described in Section 2052.5.

"(h) The repeated failure by a certificate holder, in the absence of good cause, to attend and participate in an interview by the board. This subdivision shall only apply to a certificate holder who is the subject of an investigation by the board."

8. Section 2266 of the Code states:

"The failure of a physician and surgeon to maintain adequate and accurate records relating to the provision of services to their patients constitutes unprofessional conduct."

FACTS

Patient L.H.1

1Initials are used to protect patient privacy.

9. Respondent treated L.H. with bioidentical hormones,2 which potentially can cause uterine cancer. Respondent then failed to diagnose L.H.'s aggressive uterine cancer.

2Bioidentical hormones are hormones that are identical in molecular structure to the hormones women naturally produce. They are synthesized, from a plant chemical extracted from yams and soy, "Bioidentical hormone" is a marketing term and not a scientific term. These are scientifically untested and unproven hormones.

10. L.H., was under the gynecologic care of Respondent from September 23, 2011, until October 15, 2014. Throughout the pendency of the care, L.H. received bioidentical hormone therapy. Respondent noted in the initial intake notes for L.H. that the patient had a documented family history of maternal uterine cancer.

11. At her interview, Respondent asserted that she is a specialist in "hormone balance," or "endocrinology." However, Respondent does not have any post-medical school training in endocrinology by an ACGME3 accredited fellowship in either Medical Endocrinology4 or Reproductive Endocrinology.

3ACGME is the acronym for the Accreditation Council for Graduate Medical Education.
4Endocrinology is the subspecialty of internal medicine that focuses on the diagnosis and care of disorders of the endocrine (glandular) system and the associated metabolic dysfunction.

12. L.H. completed a patient questionnaire prior to her initial visit with Respondent on September 23, 2011. On L.H.'s initial visit she was evaluated as having menstrual migraines one day before the start of her menses and "zero" libido. In her initial assessment, Respondent concludes that L.H. is: (1) Perimenopausel (despite L.H. having regular periods and prior to performing any laboratory studies); (2) hypothyroid5 (prior to performing thyroid studies); (3) adrenal deficient6 (prior to performing any adrenal studies); (4) "create her cycle in the books" (which term is unexplained); (5) has low [Vitamin] D3 (prior to performing any studies of her Vitamin D levels); and, (6) that they discussed psychological work, which discussion is not explained anywhere in the records.

5Hypothyroid indicates an underactive thyroid and is a common disorder of the endocrine system in which the thyroid gland does not produce enough thyroid hormone.
6Adrenal deficiency is a condition in which the adrenal glands do not produce adequate amounts of steroid hormones, primarily cortisol; but may also include impaired production of aldosterone (a mineralocorticoid), which regulates sodium conservation, potassium secretion, and water retention.

13. L.H. was noted to have normal lab values in the report submitted on September 11, 2011. Despite normal lab values for all of the sex hormones and adrenal hormones and no lab value for thyroid hormones on September 23, 2011, Respondent prescribed L.H. Estrogen,7 Progesterone,8 DHEA,9 Pregnenolone,10 D3, Testosterone, thyroid replacement, iodine and lemon drops. In addition, L.H. underwent a pelvic ultrasound and a thyroid ultrasound on September 23, 2011, both in Respondent's office that were both normal.

7Estrogen is the primary female sex hormone. It is responsible for the development and regulation of the female reproductive system and secondary sex characteristics. Estrogen may also refer to any substance, natural or synthetic, that mimics the effects of the natural hormone.
8Progesterone is an endogenous steroid and progestogen sex hormone involved in the menstrual cycle, pregnancy, and embryogenesis of humans and other species. Progesterone is also a crucial metabolic intermediate in the production of other endogenous steroids, including the sex -hormones and the corticosteroids, and plays an important role in brain function as a neurosteroid.
9DHEA is an endogenous steroid hormone. It is one of the most abundant circulating steroids in humans, produced in the adrenal glands, the gonads, and the brain, where it functions as a metabolic intermediate in the biosynthesis of the androgen and estrogen sex steroids.
10Pregnenolone is an endogenous steroid and precursor/metabolic intermediate in the biosynthesis of most of the steroid hormones, including the progestogens, androgens, estrogens, glucocorticoids, and mineralocorticoids. In addition, pregnenolone is biologically active in its own right, acting as a neurosteroid.

14. The medical records show that Respondent did not take a thorough sexual history and attempt to address any underlying physical, psychological and relationship factors in treating L.H. 's low libido.

15. L.H. had additional labs performed on October 13, 2011, which demonstrate changes in her baseline from the initial labs performed on September 11, 2011. The notes for these results indicate that her testosterone levels are now supratherapeutic.11 In her interview, Respondent justifies this result by claiming that the elevated levels are in accordance with her plan of care.

11Supratherapeutic levels means that the laboratory results reflect levels that are greater than normal levels.

16. L.H. was next examined by Respondent on December 31, 2012, when a pap smear, pelvic exam, pelvic ultrasound, and a breast ultrasound were performed. All results were within normal limits. Respondent's interview discussion of the chart for this day indicated that L.H. was having irregular uterine bleeding, but Respondent suggests the ultrasound findings were reassuring. This is inconsistent because the EEC12 was 1.7mm, which is far from reassuring.

12Endometrial echo complex (EEC) is a commonly measured parameter on routine gynecologic ultrasound. The appearance, as well as the thickness of the endometrium, will depend on whether the patient is of reproductive age or post-menopausal. The measurement is of the thickest echogenic area from one basal endometrial interface across the endometrial canal to the other basal surface. The designation of "normal" endometrial thickness rests on the thickness, age, menopausal status and presence of abnormal bleeding.

17. On January 23, 2013, L.H. underwent a screening mammogram, the results of which were normal.

18. On March 5, 2013, L.H. had a breast ultrasound which was normal.

19. On December 10, 2013, L.H. received a pelvic ultrasound in Respondent's office. Small ovarian cysts were discovered. The EEC of 2.1 mm was also noted, again indicating that L.H. was not perimenopausal.

20. A chart note made on December 12, 2013, states that patient is going into menopause and small cysts on ovary are normal and physiologic. However, no objective medical evidence supports that statement. L.H. then has an abdominal and pelvic CT performed on December 27, 2013, for "Stone Microhematuria."13 This CT shows a 3.3cm right ovarian cyst.

13It is likely that what is meant is microscopic hematuria which means three or more red blood cells in a high-power microscopic field of urinary sediment from two of three properly collected urinalysis specimens. Thus, the blood is only visible in the urine under a microscope. This can be related to kidney stones.

21. Although numerous tests were performed, L.H. 's actual third visit with Respondent takes place on June 28, 2014, almost three years after the initial visit. During this visit the estrogen dosage is increased and a recommendation is made for follow up in six months. The notes reflect no objective medical reason for the increase in estrogen.

22. As could be expected, on July 15, 2014, L.H. complains of feeling foggy and Respondent adjusts the hormone dosing via the telephone, instead of requiring L.H. to come into the office.

23. On September 2, 2014, L.H. calls Respondent's office reporting that her menstrual cycle has been continuing for a month and that she has been bleeding heavily for 8 days. Instead of requiring L.H. to come into the office, Respondent recommends "P4 6 drops [progesterone] nightly, 2 c BID (twice a day) of E2 (estrogen)."

24. Respondent prescribed L.H. exogenous estrogen starting in September of 2011 and continued through October of 2014. When L.H. complained on September 2, 2014, that she was experiencing a menstrual cycle that lasted for over a month, and during which she had heavy bleeding for 8 straight days, Respondent did not perform any endometrial sampling14 to exclude endometrial hyperplasia15 as the cause of her menometrorrhagia.16

14Endometrial sampling is obtaining a tissue sample from the glandular mucous membrane that lines the uterus, for testing.
15Hyperplasia is an abnormal increase in the number of cells in a tissue or organ, with consequent enlargement of the part or organ.
16Menometrorrhagia is a condition in which prolonged or excessive uterine bleeding occurs irregularly and more frequently than normal. It is thus a combination of metrorrhagia and menorrhagia.

25. On September 25, 2014, Respondent notes that L.H. is being "recommended" 4c of estrogen, twice a day, progesterone drops in the evening, 3c of testosterone in the am, 2 grains of thyroid, 5mg DHEA, D3 and Cortisol. Respondent recommended another ultrasound and if L.H. continues to bleed, "office D&C."17

17Dilation and curettage (D&C) is a surgical procedure in which the cervix is opened (dilated) and a thin instrument is inserted into the uterus. This instrument is used to remove tissue from the inside of the uterus (curettage).

26. On September 26, 2014, L.H. had another ultrasound in Respondent's office that shows a slightly enlarged uterus, and an EEC of2.3mm, as well as a mass thought to be a fibroid in the uterus, measuring 1.4 x 1.6 x 1.9cm. L.H. is also noted to have periods that are heavy and red lasting for 3 weeks, as well as passage of clots and cramping for 2 weeks. The chart reflects the recommendation is to decrease her E2 (estrogen) to "2c" bid [assuming that means 2 clicks,18 twice a day].

18A "click" is a unitary bioidentical hormone measurement that is unknown to Board Certified ObGyn's. Neither is it a recognized value in standard of care analysis. Thus, there is no way to determine what amount the patient was receiving.

27. Respondent is not certified in gynecologic ultrasound analysis and has not had post-medical school training in gynecologic ultrasound analysis.

28. On October 3, 2014, a telephone note documents L.H. questioning Respondent's prescription of a steroid. L.H. advises Respondent's office that she is having irregular menses and bleeding lasting up to 19 days in a row for the last 2 months. L.H. advises the office that her intention is to have blood drawn and make an appointment [presumably with Respondent]. However, no records indicate that such an appointment was made.

29. On October 10, 2014, L.H. underwent another abdominal and pelvic CT from University Imaging Centers showing a right adnexal mass 8.5 x 8.5mm, and simple cysts on the left ovary. Note the prior CT showed a right ovary cyst.

30. On October 13, 2014, L.H. called Respondent's office and asked why the cyst that was found on the October 10, 2014, CT was not seen on an ultrasound performed by Respondent on September 26, 2014, two weeks prior.

31. On October 15, 2014, L.H. underwent another abdominal and pelvic ultrasound in Respondent's office, which revealed a 8.2 x 6.5 x 8.5cm adnexal mass on the right side, and an EEC of 2.5mm. On the same day L.H. also had a pelvic ultrasound at Argus Radiology that shows an enlarged uterus of 9.3cm x 4.4cm and a left ovarian cyst measuring 4.0 x 2.7 x 2.7cm and an EEC of 2.98cm. In addition, it shows a right adnexal mass of 8.2 x 6.5 x 8.5cm.19

19The ultrasound and CT show a right adnexal mass. The CT from University Imaging apparently made a typographical error when they classified L.H.'s right adnexal mass as being in the units of "mm", as opposed to "cm", which the mass was later found to measure.

32. L.H.'s testosterone levels recorded by Respondent reveal the following values: 14, 89, 45,442, 46. A review of L.H.'s Estradiol levels as recorded by Respondent reveal the following values: 96.9, 58.3, 162.7, 13.4, 16.2. A review of L.H.'s TSH20 levels reveals the following values as recorded by Respondent: 0.936, 0.027, 0.175. Two of these values represent supratherapeutic levels of hormones.

20TSH means thyroid-stimulating hormone.

33. The cost of Respondent's "bioidentical hormone" prescriptions to L.H., over the course of 3 years, was in excess of $7000.00.

Patient M.S.

34. M.S. presented to Respondent on May 6, 2013, for sleeping problems and low energy. At that initial visit M.S. signed the consent for treatment. M.S. had previously had blood drawn and filled out an extensive medical questionnaire. Respondent used the patient questionnaire to diagnose M.S. with thyroid issues, instead of M.S.'s laboratory data regarding thyroid function.

35. Respondent's notes indicate that M.S. previously had undergone bypass surgery (2000-with a revision in 2011), a cholecystectomy in 2005 and a uterine ablation in 2011 (due to menorrhagia or heavy menses).

36. Respondent notes that M.S. had night sweats, hair loss, and difficulty with sleeping even while on 5mg Ambien, 50mg Benadryl and 0.5mg Xanax every night before bed.

37. Respondent's notes state that M.S. had recently been diagnosed with Diabetes, Type II and prescribed Acarbose21 25mg TID by her primary care physician. In her subject interview, Respondent stated that she assessed M.S.'s menses as "irregular", although that is not noted in the records. Respondent also refers to M.S. as "perimenopausal" without any objective medical evidence to support that conclusion.

21Acarbose is an anti-diabetic drug used to treat diabetes mellitus type 2.

38. M.S 's blood lab report done prior to the initial visit with Respondent shows TSH22 was 1.65.

22This is the thyroid stimulating hormone indicative of thyroid malfunction. A 5.3 reading is abnormal, thus thyroid hormones are an inappropriate treatment.

39. M.S. 's blood laboratory analysis, taken prior to the initial visit with Respondent, show only two (2) values that fall outside the normal ranges; the HgbAlc23 (for which she was recently started on therapy by her ObGyn), and Pregnenolone (a value that does not warrant treatment in a gynecologic standard of care analysis).

23Hemoglobin Al C is the major fraction of glycosylated hemoglobin-a blood value particularly relevant to diabetes patients.

40. Respondent then used M.S.'s patient questionnaire and a review of the blood laboratory analysis, with no physical examination (other than reflexes according to the chart), to diagnose M.S. as perimenopausal (a diagnosis unsupported by M.S. 's laboratory data and her clinical history) and hypothyroid (a diagnosis unsupported by any laboratory abnormalities and based solely on clinical symptomatology elicited from M.S.).

41. At no time did Respondent examine M.S.'s thyroid, a standard exam for all women, but especially for those women being treated for thyroid disorders.

42. Respondent recommended the following for M.S.: Estradiol, testosterone, Omega 3, melatonin, magnesium, chromium, digestive enzymes, thyroid and vitamin D, with a recommendation to repeat the laboratory blood work in 2 months and a follow up appointment in 1 month.

43. On May 6, 2013, M.S. was given a transvaginal ultrasound, whose indication is "endometrial lining" showing a uterus measuring 5.85 x 3.32 x 5.44cm, right ovary measuring 2.33 x 1.45cm, and left ovary measuring 3.82 x 2.35cm. A cyst is noted on the left ovary measuring 2.69mm x 1.43mm (it is not characterized as simple or complex). The endometrial echo complex is measured at 1.7mm. No interpretation of the ultrasound is provided in the medical record; thus, it is unknown why M.S. received the ultrasound.

44. At M.S. 's first visit to Respondent her estrogen and testosterone were within normal limits for both the laboratory values, as well as Respondent's own "normal"24 values. However, Respondent prescribed medication for both of these normal values. In addition, although M.S.'s three thyroid studies (TSH, Free T4 and Free T325) were also within normal clinical limits (although two were outside Respondent's. "normal"), Respondent prescribed M.S. thyroid hormone therapy.

24Respondent explained at her interview that she did not follow recognized standards for hormonal normalcy, but followed her own value determinations based on her experience. Respondent's values do not track clinical norms.
25
These are three standard thyroid hormonal values.  

45. Respondent did not contact M.S.'s other care providers, made no records request, and made no effort to coordinate the care being given to M.S., or coordinate prescriptions that could potentially have interactions with M.S.'s other prescribed medications.

46. M.S. was on multiple psychiatric medications at her initial presentation to Respondent. M.S. was on Ambien (5mg), Xanax (0.5mg) and Pristiq (50mg) at her initial consultation. Respondent made no effort to determine what potential interactions her prescriptions might have with these other prescribed medications and no indication is present that M.S. was cautioned or otherwise advised regarding taking all of these medications concurrently. There is no indication that M.S.'s suicidality issues were addressed regarding all of the prescribed medications and their possible interactions.

47. M.S. next spoke with Respondent on May 20, 2013, in a telephone call follow up and additional medications were sent (apparently through the mail) to M.S. on June 3, 2013.

48. M.S. then underwent laboratory work on June 11, 2013, which showed completely normal range values. However, M.S. returned to Respondent's office on July 11, 2013, wherein estrogen and testosterone dosages were increased.

49. M.S. also went to Respondent's office on July 1, 2013. Additional labs were ordered and M.S.'s dosage of estradiol, testosterone and thyroid hormones were increased, although the records lack any justification for the increases

50. M.S. saw Respondent on August 26, 2013, and again on October 2, 2013. Respondent increased M.S.'s thyroid hormone from 1gm to l.5gm on October 2, 2013, despite M.S. having completely normal Free T4 and Free T3 lab values, as well as normal TSH values. Respondent increased M.S. 's thyroid hormone based on symptoms, not lab values, although the specific symptoms are unclear from the medical records. M.S. then notified Respondent that she had increased her thyroid dosing herself, and Respondent notes that 50% of her patients increase their medications on their own. Respondent apparently took no action as a result of this information, including counseling M.S. about such a choice.

51. M. S. next saw Respondent on January 13, 2014 when M.S. reported that she had no bleeding secondary to her uterine ablation and that she wants "10 lbs loss" [weight loss]. Her TSH is noted to be non-detectable, and Free T4 and Free T3 are normal.

52. Respondent's analysis of the January 13, 2014, visit indicate her perception that despite the fact that M.S.'s thyroid is "very very" suppressed, the fact that M.S. is going into menopause needs to be accounted for in the analysis of the thyroid. This note is made despite no objective medical evidence that M.S. is going into menopause. Respondent references a TSH of 8.3 as evidence that M.S. is going into menopause. Respondent also states that M.S.'s Hgb A1c dropped from 6.0 to 5.2 on 4 grains of thyroid hormone as proof that the thyroid medication is working (however, the medication was prescribed to M.S. by her primary care physician for the treatment of Diabetes). Respondent fails to include M.S.'s changes in diet or exercise or the numerous other supplements that M.S. has purchased with the intent of maintaining glucose metabolism and for weight loss. The chart reflects that the patient should take 4 "clicks" of 65mg thyroid or 2 clicks of 130mg thyroid.

53. On April 7, 2014, Respondent recommends that M.S. take 1 "click" of socort, 3 "clicks" of estradiol and 2 "clicks" of testosterone.

54. On October 14, 2014, Respondent recommends that M.S. take 4 grains of thyroid, 3 "clicks" of estradiol and 2 "clicks" of testosterone.

55. On December 4, 2014, at an appointment with Weight Management at the Scripps Institute, M.S. was advised to stop taking Acarbose. Laboratory blood work is also ordered at that time.

56. On January 12, 2015, Weight Management at Scripps advises M.S. to cut her thyroid medication in half and to recheck her TSH in 6 weeks. Scripps also recommends stopping the adrenal supplement and the methylation agents,26 continuing the vitamin D and calcium.

26Methylation agents are non-prescription supplements.

57. On February 23, 2015, Weight Management at Scripps recommends stopping the adrenal medication and the progesterone.

58. On April 13, 2015, Weight Management at Scripps recommends changing M.S. to 130mcg of thyroid hormone.

59. On January 4, 2016, M.S. has a consultation with an Endocrinologist, who orders laboratory analysis and documents that M.S.'s chief complaint is weight gain. Those notes also reflect that M.S.'s TSH is normal and maintained on 1.75mcg of levothyroxine.28 This is a dosage significantly lower that the dosages prescribed by Respondent.

27Levothyroxine, also known as L-thyroxine, is a manufactured form of the thyroid hormone, thyroxine. It is used to treat thyroid hormone deficiency.

FIRST CAUSE FOR DISCIPLINE
(Unprofessional Conduct-Gross Negligence)

60. By reason of the matters set forth above in paragraphs 9 through 59, incorporated herein by this reference, Respondent is subject to disciplinary action under Code section 2234, subdivision (b), in that she engaged in unprofessional conduct constituting gross negligence. The circumstances are as follows:

61. Respondent's failure to perform any endometrial sampling to exclude endometrial hyperplasia as the cause of L.H.' s menometrorrhagia, despite the exogenous hormones being prescribed by Respondent, and then adjusting L.H.' s bioidentical hormone prescription, demonstrates that Respondent is unaware of the risks of exogenous bioidentical hormones and the need for excluding such hormones as a cause of malignancy for uterine cancer, and constitutes gross negligence.

62. Despite initiating post-menopausal testosterone prescriptions for L.R, Respondent failed to follow up for potential cosmetic or systemic adverse outcomes, any abnormal uterine bleeding and any lipid and liver function testing. Respondent's failure to perform any of this necessary follow-up testing constitutes gross negligence.

63. Respondent failed to require an annual mammogram despite prescribing L.H. testosterone therapy and failed to use serum blood to achieve an acceptable testosterone level, which constitutes gross negligence.

64. Respondent purposefully tried to achieve a supratherapeutic level of testosterone in L.H., thus putting L.H. at risk for liver, heart disease, breast and uterine cancer and prescribing levels of testosterone that caused L.H.' s testosterone levels to rise to a reading of 442, (reference range for testosterone levels are 3-41), a level over 10 times the highest "normal" level for a woman. At the same time Respondent failed to test L.H.' s lipid and liver functions and did not require yearly mammograms, which constitutes gross negligence for a woman receiving androgen therapy.

65. Respondent performed pelvic ultrasounds in her office on L.H. on five separate occasions and found no evidence of thickening of the lining of the endometrium. An ultrasound performed in Respondent's office on October 15, 2014, demonstrated an EEC of 2.5mm, but a pelvic ultrasound performed on the same day by a board certified radiologist demonstrated an EEC of 2.98cm, which is a clinically significant reading and is the difference between a normal reading and a reading that detected cancer. Respondent's failure to recognize a large mass in the uterus that was ultimately found to be endometrial cancer constitutes gross negligence.

66. Respondent diagnosed M.S. with hypothyroidism when no clinical evidence indicated she had hypothyroidism. M.S. had no laboratory aberrations until she had abnormalities caused iatrogenically28 by Respondent. Respondent knowingly allowed M.S. to be maintained at supra-therapeutic thyroid levels without consent and without warning M.S. about the health dangers and risks of doing such treatment. Respondent also knowingly kept M.S. at supratherapeutic thyroid levels purportedly to assist with weight loss, but Respondent never documented that she performed a physical exam of M.S. 's thyroid. Respondent's failure to properly diagnose M.S. 's alleged hypothyroidism, her prescribing thyroid hormones to supratherapeutic levels without consent or proper warnings, and never performing a thyroid examination constitute gross negligence.

28Iatrogenically means induced unintentionally in a patient by a physician.

67. Respondent's failure to: document a physical examination of M.S.; coordinate care for M.S. with other treating physicians (or even obtain their names); obtain medical records from other health care providers to avoid medication interaction issues, and; conform to standard documentation for a pelvic ultrasound when the diagnosis did not support the performance of a pelvic ultrasound as M.S. had undergone an endometrial ablation and did not complain of abnormal bleeding, constitute gross negligence.

68. Respondent's specific failure to coordinate care with M.S.'s psychiatrist when M.S. was at a high-risk for death due to suicidality and Respondent's prescribed medications could potentially exacerbate pre-existing mental health disorders, putting the patient at risk for potentially dangerous side effects, constitutes gross negligence.

SECOND CAUSE FOR DISCIPLINE
(Unprofessional Conduct-Repeated Negligent Acts)

69. By reason of the matters set forth above in paragraphs 9 through 68, incorporated herein by this reference, Respondent is subject to disciplinary action under Code section 2234, subdivision (c), in that she engaged in unprofessional conduct constituting repeated negligent acts. The circumstances are as follows:

70. Respondent's repeated and continuous prescribing of bioidentical hormones, which are scientifically unproven and untested, while failing to properly monitor L.H.'s objective medical issues, constitutes repeated negligent acts.

71. Respondent's repeatedly diagnosing M.S. as perimenopausal, and "approaching" menopause when laboratory data demonstrated that she was definitely not perimenopausal, constitute negligence.

72. Respondent's diagnosing M.S. with perimenopause despite no objective medical evidence of such condition and then treating that incorrect diagnosis in a manner such that Respondent stood to gain financially constitutes negligence.

73. Respondent's performing a "baseline" pelvic ultrasound before treating M.S. with estrogen, progesterone and testosterone, despite M.S. having no complaints of abnormal bleeding constitutes negligence.

THIRD CAUSE FOR DISCIPLINE
(Medical Record Keeping)

74. By reason of the matters set forth above in paragraphs 9 through 73, incorporated herein by this reference, Respondent violated Code section 2266, in that she failed to adequate records for L.H. and M.S. The circumstances are as follows:

75. Respondent's notes for L.H. and M.S. are incomplete, illegible and wholly lacking required information concerning the respective patients.

PRAYER

WHEREFORE, Complainant requests that a hearing be held on the matters her, and that following the hearing, the Medical Board of California issue a decision:

  1. Revoking or suspending Physician's and Surgeon's Certificate Number G issued to Prudence Elizabeth Hall, M.D.;
  2. Revoking, suspending or denying approval of Prudence Elizabeth Hall, M.D.;
  3. authority to supervise physician assistants and advanced practice nurses;
  4. Ordering Prudence Elizabeth Hall, M.D., if placed on probation, to pay tlo pay the Board the costs of probation monitoring; and
  5. Taking such other and further action as deemed necessary and proper.

DATED: September 12, 2017

_________________________
KIMBERLY KIRCHMEYER
Executive Director
Medical Board of California
Department of Consumer Affairs
State of California
Complainant

This page was posted on September 14, 2018.

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