FLORIDA BOARD OF MEDICINE FAQ

FLORIDA BOARD OF MEDICINE

FAQ

I need help filling out my application.
The application is lengthy, but not difficult. Board staff can answer questions, but here is your first tip: use email - you can put more detail in it and the staff will be able to concisely answer your question because it will be clearly spelled out in your e-mail. Send your inquiries directly to the person who is handling your application, or contact us.

You should consider using a private attorney if you need more help with the application process than Board staff can provide.

You may also seek assistance from your hospital's personnel/risk management office if you are already employed at the time you apply.

If you do seek assistance from any of these sources, make sure that you don't rely on others to know all the information that is requested. Spend your time reviewing every question and answer before you sign that application form.

Board of Medicine licensure staff spend time at resident training programs to educate residents about applying for licensure. The staff also visits Florida's medical schools to explain the different licensure avenues.

How long does it take?

Once your application is COMPLETE and there are no "red flags," the process takes between 45 and 90 days.
The important word here is "COMPLETE." If all the information that you are required by law to submit is received, the application is complete. If you do not provide this information, the process will take longer. An important part of the application process is the documentation that must be provided to the Board. The process will go much quicker if you get the documents in as soon as possible. Do not leave this task to someone else – either provide the documents yourself or see that they are quickly provided – follow-up with others that are providing them for you if necessary. This is the #1 delay in application processing.
Where do I go if I have a question after I send in the form?
Your application goes to a Board of Medicine staff member called a "reviewer." There are 7 reviewers in the Board of Medicine office. Your reviewer will contact you and will provide you with their name, phone number, fax number and e-mail address so that you will be able to communicate with them. Again, the best way to communicate is by e-mail. The reviewer will have a clear question in front of them, and will be able to research the answer if necessary. This will also give you your answer in writing, in case you need to have it on file.

Who makes the decision on my application?
Your application, once complete, goes to a supervisor for a second review and then to the Board for approval or denial.
At any step along the way a "red flag" on the application may require it to be reviewed by the Program Administrator to determine if the application must go before the Credentials Committee. A "red flag" does not mean denial; it simply means an explanation is necessary.
This Board of Medicine's Credentials Committee meets every two months to review any of the applications that require explanation or more information or perhaps a personal appearance by the applicant. The Board of Medicine is charged with protecting the health care of Florida consumers by licensing only qualified health providers so the Board is required to make this extra inquiry when called for.
What really happens to my application when it arrives at the Department of Health?
The application arrives at a centralized mailroom at the Department of Health headquarters in Tallahassee.
The mail handler that supports all the health care boards directs your application to the Board of Medicine.
TIP: send your application and fee to the special address as directed on your application – this will save time.
Mail that includes a check is required to go to the vendor that receives all monies for the Department. If you send an overnight letter with a check on Monday, it will not get to your reviewer on Tuesday because it must first go to the vendor. This simple fact of processing unfortunately frustrates applicants who send such mail, and then call the next day and are told the mail is not yet received. Knowing about this step in advance will keep you from being frustrated.
After the application is forwarded to the Licensure section at the Board of Medicine, it is assigned to a reviewer, the person who will process your application. The reviewer puts your information into a data bank that will be part of your record for as long as you have a Florida license.
Staff Goals: Applications are processed within 30 days of the date received. E-mails and mail are processed within five days of the date received. Phone calls returned within 24 hours of the date received.
What are the most common problems that slow up and application?
NOT BEING COMPLETELY CANDID ABOUT YOUR HISTORY AND EDUCATION is the #1 reason for denial of a full-unrestricted license. Failure to disclose a problem will get you in trouble with the Board far more often than the problem itself. Here are some other causes for delay in your application:
     Actions during postgraduate training
     Hospital staff privileges with action/termination of employment
     Action by a specialty board
     Action by another state regulatory board
     Misdemeanor or felony convictions
     Results of the criminal background check
     Civil judgments/malpractice
     Medical, physical, mental or chemical dependence impairment/condition within the last five years
     Lack of active practice
     Action by DEA
     Action by the military
     Applications that require Petition of Waiver/Variance
Do most complete applications get approved?
Yes, most applicants are granted an unrestricted Florida medical license. Those applicants who are not issued an unrestricted license may have the following occur:
     Approval with conditions such as a fine, corrected application and new application fee.
     Approval with condition such as taking or retaking an examination.
The Board may also outright deny the license, or may allow the applicant to withdraw the application.
TOP TEN WAYS TO GET YOUR APPLICATION PROCESSED QUICKLY

Mail the application to the correct address.
Keep in mind that any monies have to be processed by the Department vendor. This may take a couple of days.
Identify any variation of names and nicknames.
Once you start the process, submit the application within 30 days so that your supplemental documents, including transcripts, will have an application file to go to.
Have the correct address on the application for training programs and hospitals.
Send in necessary back up documents in a timely manner.
Follow up with sources that are sending the Board of Medicine your documents.
Watch for letters or e-mail from your reviewer. This is how we tell you what else is needed for your application to be complete.
If asked for follow-up information from the Board, please read the request carefully to identify exactly what is needed to make your application complete.
Answer questions honestly and provide an explanation where appropriate.

A great deal of the Board of Medicine's staff time is dedicated to processing medical license applications. The Board of Medicine and its staff are charged with licensing those applicants that qualify for licensure under state law who can safely practice medicine. The Board works very hard to ensure that all of this is done in a timely manner. Knowing how the process works will help to ensure that your application is handled expeditiously.

64B8-1.001 Probable Cause Determinations.
(1) The determination as to whether probable cause exists that a violation of the provisions of Chapters 456 and 458, F.S., and/or the rules promulgated pursuant thereto, has occurred shall be made by a majority vote of a probable cause panel of the Board.
(2) There shall be two probable cause panels of the Board. Each probable cause panel shall be composed of three members, one of whom may be a physician who was a past Board member who is not currently appointed to the Board and one of whom may be a past lay member who is not currently appointed to the Board. One member of the probable cause panel must be a current Board member.
(3) In instances when the probable cause panel is considering cases involving a physician assistant, the panel shall also have a physician assistant participating on the probable cause panel. The physician assistant is only permitted to hear cases involving discipline of physician assistants. If the physician assistant is not able to attend the meeting of the probable cause panel, the panel may consider the case and vote on the matter in the absence of the physician assistant.
(4) The probable cause panel members shall be selected by the Chair of the Board, one (1) of whom shall be designated by the Chair of the Board as the presiding officer of the panel.
(5) Each probable cause panel shall meet at such times as called by the presiding officer of the panel or by two members of the panel.
Specific Authority 120.53, 456.073(4) FS. Law Implemented 456.073(4), 458.311(10) FS. History–New 12-5-79, Amended 11-26-80, 5-27-81, Formerly 21M-18.06, Amended 12-4-86, 7-4-88, 1-1-92, Formerly 21M-18.006, 61F6-18.006, 59R-1.006, Amended 3-29-01, 12-4-06.

https://www.flrules.org/gateway/readFile.asp?sid=0&tid=2425987&type=1&file=64B8-55.001.doc
64B8-55.001 Disciplinary Guidelines.
(1) Purpose. Pursuant to Section 478.52(4), F.S., the Board provides within this rule disciplinary guidelines which shall be imposed upon applicants or licensees whom it regulates under Chapter 478, F.S. The purpose of this rule is to notify applicants and licensees of the ranges of penalties which will routinely be imposed unless the Board finds it necessary to deviate from the guidelines for the stated reasons given within this rule. Each range includes the lowest and highest penalty and all penalties falling between. The purposes of the imposition of discipline are to punish the applicants or licensees for violations and to deter them from future violations; to offer opportunities for rehabilitation, when appropriate; and to deter other applicants or licensees from violations.
(2) Sexual misconduct in the delivery of electrolysis services is sexual behavior or involvement as defined in Section 456.063(1), F.S.
(3) Violations and Range of Penalties. In imposing discipline upon applicants and licensees in proceedings pursuant to Sections 120.57(1) and 120.57(2), F.S., the Board shall act in accordance with the following disciplinary guidelines and shall impose a penalty as provided in Section 456.072(2), F.S., within the range corresponding to the violations set forth below. The identification of offenses are descriptive only; the full language of each statutory provision cited must be consulted in order to determine the conduct included.

VIOLATION     RECOMMENDED RANGE OF PENALTY
(a) Attempting to obtain a license by bribery, fraud,
misrepresentation, or through error of the department or
the council.
(478.52(1)(a), 456.072(1)(h), F.S.)
(a)1. Attempting to obtain an initial licensure by      (a)1. Denial of application and $10,000 fine.
bribery or fraud.
(a)2. Attempting to renew a license by bribery or fraud.     (a)2. For the first offense, from revocation of the license with ability
     to reapply upon payment of a $10,000 fine to permanent revocation.
     After the first offense, permanent revocation and a $10,000 fine.
(a)3. Obtaining or renewing a license by fraud.     (a)3. For the first offense, from revocation of the license with ability
     to reapply upon payment of a $10,000 fine to permanent revocation.
     After the first offense, permanent revocation and a $10,000 fine.
(a)4. Obtaining or renewing a license through error of      (a)4. Revocation.
the department or the council.
(a)5. Obtaining or renewing a license through negligent     (a)5. For the first offense, from a $250 fine and 3 hours of continuing
misrepresentation.     education on ethics to suspension and a reprimand and a $1,000
     administrative fine.
(b) Action taken against license by another     (b)1. From imposition of discipline comparable to
jurisdiction.     the discipline which would have been imposed if
(478.52(1)(b), F.S.)      the substantive violation had occurred in Florida to
     suspension or denial of the license until the license
     is unencumbered in the jurisdiction in which
     disciplinary action was originally taken, and an
     administrative fine ranging from $250 to $5,000.
     Impaired practitioners working in this state shall be
     evaluated to determine the need for referral to PRN.
     (b)2. After the first offense, from imposition of
     discipline comparable to that which would have
     been imposed if a second or higher substantive
     violation had occurred in Florida to suspension or
     denial of license until it is unencumbered in the other
     jurisdiction, and an administrative fine from $1,000
     to $5,000.
(c) Guilt of crime directly relating to practice.     (c)1. From probation to revocation or denial of
(478.52(1)(c), F.S.)      license, and an administrative fine ranging from
     $250 to $5,000.
     (c)2. After the first offense, from a three-year
     probation with conditions to revocation or denial of
     the license, and an administrative fine ranging from
     $350 to $5,000.
(d) Filing a false report or failing to file a report as
required.
(478.52(1)(d), F.S.)
(d)1. Negligently filing a false report or failing to file a     (d)1. For the first offense, from a letter of concern or denial of
report as required.     application to one (1) year probation and an administrative fine from
     $500 to $5,000. After the first offense, from one (1) year probation to
     revocation, and an administrative fine from $1,000 to $5,000.
(d)2. Fraudulently filing a false report or failing to file     (d)2. For the first offense, from one (1) year probation to revocation
a report as required.     or denial of application, and a $10,000 fine. After the first offense,
     from suspension to revocation and a $10,000 fine.
(e) False, deceptive or misleading advertising.
(478.52(1)(e), F.S.)
(e)1. Negligent false, deceptive, or misleading     (e)1. For the first offense, from a letter of concern to one (1) year
advertising.     suspension or denial or application, and an administrative fine
     from $500 to $2,500.
(e)2. Fraudulent false, deceptive, or misleading      (e)2. For the first offense, from reprimand to up to one (1) year
advertising.     suspension or denial of application, and an administrative fine of
     $10,000. After the first offense, from suspension up to revocation
     and a fine of $10,000.
(f) Unprofessional conduct, failure to conform to     (f)1. For first-time violation where no actual patient
acceptable standards.     harm occurred, citation and $250 fine. For first-time
(478.52(1)(f), F.S.)     violation where actual patient harm occurred from
(456.072(3)(b), F.S.)      six months probation to revocation or denial, and
     an administrative fine from $1,000 to $2,500.
     (f)2. After the first offense, from one year probation to
     revocation or denial, and an administrative fine
     from $1,000 to $5,000.
(g) Possession, sale or distribution of illegal or     (g)1. From six months suspension to revocation
controlled substance.     or denial, and an administrative fine from $1,000
(478.52(1)(g), F.S.)      to $5,000.
     (g)2. After the first offense, from one year
     suspension to revocation, and an administrative fine
     from $1,500 to $5,000.
(h) Failure to report any known violation of     (h)1. From a reprimand to probation or denial, and
Chapter 478, F.S.     an administrative fine from $250 to $5,000.
(478.52(1)(h), F.S.)     (h)2. After the first offense, from one year
     probation to revocation or denial, and an
     administrative fine from $350 to $5,000.
(i) Repeated or willful violation of rule or order.     (i)1. From six months suspension to revocation or
(478.52(1)(i), F.S.)      denial, and an administrative fine from $1,000 to
     $2,500.
     (i)2. After the first offense, from one year
     suspension to revocation or denial, and an
     administrative fine from $1,500 to $5,000.
(j) Delivery of electrolysis services without an     (j)1. From probation to revocation or denial, and an
active license.     administrative fine from $250 to $5,000.
(478.52(1)(j), F.S.)      (j)2. After the first offense, from one year
     suspension to revocation or denial, and an
     administrative fine from $1,000 to $5,000.
(k) Employing unlicensed person to practice     (k)1. From one year probation to denial or five years
electrology.     suspension followed by probation,
(478.52(1)(k), F.S.)      and an administrative fine from $250 to $5,000.
     (k)2. After the first offense, from one year
     suspension to denial or five years suspension
     followed by probation, and an administrative fine
     from $1,000 to $5,000.
(l) Failure to perform legal obligation.     (l)1. From a reprimand to probation up to one year
(478.52(1)(l), F.S.)      or denial, and an administrative fine from $250 to
     $1,500.
     (l)2. After the first offense, from probation to
     suspension or denial, and an administrative fine
     from $1,000 to $5,000.
(m) Accepting and performing responsibilities for     (m)1. From six months probation to revocation or
which licensee knows, or has reason to know, he     denial, and an administrative fine from $500 to
or she is not competent to perform.     $2,500.
(478.52(1)(m), F.S.)      (m)2. After the first offense, from one year
     probation to revocation or denial, and an
     administrative fine from $1,000 to $5,000.
(n) Delegating professional responsibilities to     (n)1. From probation to denial or two years
unqualified person.     suspension followed by probation, and an
(478.52(1)(n), F.S.)      administrative fine from $250 to $5,000.
     (n)2. After the first offense, from six months
     suspension followed by probation to revocation, and
     an administrative fine from $1,000 to $5,000.
(o) Malpractice.     (o)1. From two years probation to revocation or
(478.52(1)(o), F.S.)      denial, and an administrative fine from $250 to
     $5,000.
     (o)2. After the first offense, from one year
     suspension followed by probation to revocation or
     denial, and an administrative fine from $1,000 to
     $5,000.
(p) Judicially determined mental incompetency.     (p) From probation to denial or indefinite
(478.52(1)(p), F.S.)      suspension until licensee is able to demonstrate
     ability to practice with reasonable skill and safety
     followed by probation.
(q) Practicing under a name other than that of
licensee.
(478.52(1)(q), F.S.)
(q)1. Negligently practicing under a name other than     (q)1. For the first offense, form one (1) year suspension to revocation
that of the licensee.     or denial of application, and an administrative fine from $250 to
     $5,000. After the first offense, revocation and an administrative fine
     from $1,000 to $5,000.
(q)2. Fraudulently practicing under a name other than      (q)2. For the first offense, revocation or denial of application, and an
that of the licensee.     administrative fine of $10,000.
(r) Inability to practice because of mental or     (r)1. From probation to denial or indefinite
physical condition or use of alcohol or controlled     suspension until licensee is able to demonstrate the
substances.     ability to practice with reasonable skill
(478.52(1)(r), F.S.)      and safety followed by probation, and an
(456.072(1)(v), F.S.)     administrative fine from $250 to $5,000.
     (r)2. For a second offense, from indefinite
     suspension until licensee is able to demonstrate the
     ability to practice with reasonable skill and safety
     followed by probation to revocation, and an
     administrative fine from $1,000 to $5,000.
(s) Being terminated from or failing to successfully     (s)1. First Offense - Minimum stayed Suspension and Probation for a
complete an impaired practitioners treatment program.     period of 1 year with a fine of $500. to a Maximum of Suspension
     or denial of license until successful completion or receipt of a Written
     Confirmation from the program that further treatment is neither
     required nor indicated followed by a 1 year probation and a fine of
     $1,000.
     (s)2. Subsequent Offenses - Minimum Suspension for 3 years or
     until licensee is able to demonstrate to the Board the ability to
     practice with reasonable skill and safety, whichever is longer and a
     fine of $1,000. to a Maximum of revocation or denial of license and
     a $2,000. fine.
(t) Disclosing identity of or information about a     (t)1. From one year suspension to revocation or
patient.     denial, and an administrative fine from $250 to
(478.52(1)(s), F.S.)      $5,000.
     (t)2. For a second offense, revocation, and an
     administrative fine from $1,000 to $5,000.
(u) Practicing permanent hair removal except as     (u)1. From two years probation to revocation or
described in Section 478.52(5), F.S.     denial, and an administrative fine from $250 to
(478.52(1)(t), F.S.)      $5,000.
     (u)2. After the first offense, from one year
     suspension followed by probation to revocation or
     denial, and an administrative fine from $1,000 to
     $5,000.
(v) Providing electrolysis or allowing electrolysis     (v) For second and subsequent offenses: from two
to be performed in an unlicensed facility.     years probation to revocation or denial and an
(478.51(1), F.S.)      administrative fine from $250 to $5,000.
(w) Transferring an electrology facility license     (w) Denial of application as an electrologist and
from the name of the original licensee to another.     denial of application for facility license.
(478.51(1), F.S.)      Revocation of facility license to electrologist who
     accepts or transfers facility license. Revocation of
     electrology license.
(x) Sexual Misconduct.     (x) Denial of licensure, or if licensed,
(456.063, F.S.)     six months suspension to revocation
     and an administrative fine of $500 to
     $10,000.
(y) Failure to comply with continuing education     (y) Second and subsequent violations: from
requirements.     probation up to one year to suspension up to one
(478.50(4) and 478.52(1)(f), F.S.)      year and an administrative fine from $1,000 to
     $2,500; and completion of all incomplete continuing
education credits.
(z) Failure to keep an electrology facility clean,     (z) Third and subsequent offenses: from reprimand
sanitary, and well lit; allowing for circulation of     to suspension until compliance and an
air sufficient to eliminate objectionable odors.     administrative fine of $500.
(478.51(3), F.S.)
(aa) Failure to have four fixed, permanent walls     (aa) Third and subsequent offenses: from reprimand
physically connected to the electrology facility     to suspension until compliance and an
floor at least six feet tall from the floor.     administrative fine of $500.
(478.51(3), F.S.)
(bb) Failure to have required locking doors.     (bb) Third and subsequent offenses: from
(478.51(3), F.S.)      reprimand to suspension until compliance and an
     administrative fine of $500.
(cc) Failure to have a sink with hot and cold     (cc) Third and subsequent offenses: from
running water within the electrology facility.     reprimand to suspension until compliance and an
(478.51(3), F.S.)      administrative fine of $500.
(dd) Failure to provide, on the premises or in the     (dd) Third and subsequent offenses: from
same building, a separate room containing toilet     reprimand to suspension until compliance and an
and lavatory facilities.     administrative fine of $500.
(478.51(3), F.S.)
(ee) Allowing animals in the room wherein     (ee) Third and subsequent offenses: from
electrolysis is performed except those trained to     reprimand to one month suspension and until
assist the hearing impaired, visually impaired or     compliance, and an administrative fine of $500.
physically impaired.
(478.51(3), F.S.)
(ff) Failure to have any one of the following     (ff) Third and subsequent offenses: from
items/equipment in the facility (the failure to have     reprimand to one month suspension and until
any one of the items/equipment shall constitute a     compliance, and an administrative fine of $500.
separate offense):
1. An FDA registered needle type epilation device
in working order;
2. Clean and sterile needles (e.g., probes) and
forceps (e.g., tweezers);
3. Sanitary waste receptacles for the disposal of
used gloves, paper supplies, cotton balls, and other
non infectious items;
4. A sharps container for disposal of used needles;
5. A sterilizer which shall be either an autoclave or
a dry heat sterilizer and color change indicators for
use with either sterilizer;
6. Monthly records of sterilizer biological test
monitoring which shall be made available to the
Department upon request;
7. A holding container for soaking and cleaning
contaminated instruments.
(gg) Failure to maintain an appointment book.     (gg) Third and subsequent offenses: from
(478.51(3), F.S.)      reprimand to suspension until compliance and an
     administrative fine of $500.
(hh) Failure to display any one of the following     (hh) Fourth and subsequent offenses: from
documents in an area that is visible to the general     reprimand to suspension until compliance and an
public entering the facility (the failure to display     administrative fine of $350.
any one of the documents shall constitute a
separate offense):

The electrology facility license;
The current license of the electrologist;
The most recent inspection sheet from the

Department of Health;
4. A current copy of Rule 64B8-51.006, F.A.C.
(ii) Failure to have any one of the following     (ii) Fourth and subsequent offenses: from
items/equipment (the failure to have any one of the     reprimand to suspension until compliance and an
items/equipment shall constitute a separate     administrative fine of $350.
offense):

Needle holder tips;
A treatment table or chair with a nonporous

surface capable of being disinfected;
3. Disposable paper drapes or sanitary cloth drapes
stored in a closed container or compartment;
4. Single use disposable towels;
5. A treatment lamp or magnifier lamp capable of
being cleaned with disinfectant;
6. A magnifying device which shall be a magnifier
lamp, optical loupe or microscope capable of
being cleaned and disinfected;
7. Tuberculocidal hospital grade disinfectant
detergent registered by the Environmental
Protection Agency, household bleach or wiping
cloths presaturated with disinfectant for wiping
nonporous surfaces;
8. If eye shields are used, eye shields capable of
being cleaned with disinfectant;
9. Covered containers for needles and forceps
which containers are capable of being cleaned and
sterilized;
10. Betadine, 3% U.S. pharmaceutical grade
hydrogen peroxide or 70% isopropyl alcohol or
mapped single use wipes saturated with 70%
isopropyl alcohol;
11. Clean, non-sterile materials such as cotton
balls, cotton strips, cotton swabs, gauze pads, and
gauze strips;
12. Laundered and sanitized cloth towels stored in
a closed container or compartment;
13. A covered sanitary container for holding used
cloth towels;
14. Non-sterile disposable examination gloves.
(jj) Operating an unlicensed electrolysis facility.     (jj) From denial of licensure if committed prior to
(478.52(1)(u), F.S.)      licensure, or suspension until compliance to
     revocation, and a fine from $250 to $2,500.
(kk) Failure to report, within 30 days     (kk)1. 3 months probation to 2 years
a conviction, finding of guilt, or plea     suspension, and a fine of $500 to $5,000.
of nolo contendere, regardless of
adjudication, to a crime, to the Board.     (kk)2. After the first offense, from 1 year
(456.072(1)(w), F.S.)     probation to revocation, and a fine from
     $1000 to $5,000.
(ll) Using information from accident     (ll)1. Up to six months probation and/or
reports, or from news sources that     a fine of up to $500.
use such information for the solicitation     (ll)2. After the first offense, from one
of people involved in such accidents.     year probation to one year suspension, and
(456.072(1)(x), F.S.)     a fine from $1,000 to $5,000.
(mm) Testing positive for a drug on employment     (mm)1. Probation to revocation or denial licensure,
drug screening     and administrative fine from $250 to $2,500.
(456.072(1)(z), F.S.)     (ll)2. After the first offense, probation to
     revocation, and administrative fine from
      $2,500 to $5,000.
(nn) Violating any provision of Chapter 478 or 456,      (nn) For any offense not specifically listed herein, based upon the
F.S., or any rule of the Board or Department.     severity of the offense and the potential for patient harm, from a
(478.52(1)(v), F.S.)     reprimand to revocation and a fine of $250 to $1,000.
(oo) Performing or attempting to perform electrolysis on     (oo)1. For the first offense, from one year probation with conditions
the wrong patient, a wrong-site procedure, a wrong      and a $1,000 fine to one year suspension, two years probation and
procedure, an unauthorized procedure, or a     a $5,000 fine.
procedure that is medically unnecessary or otherwise     (oo)2. For the second offense, from one year suspension, two years
unrelated to the patient's diagnosis or medical condition.     probation with conditions and a $5,000 fine to revocation and a
(456.072(1)(aa), F.S.)     $10,000 fine.

(4) Aggravating and Mitigating Circumstances. Based upon consideration of aggravating and mitigating factors present in an individual case, the Board may deviate from the penalties recommended above. The Board shall consider as aggravating or mitigating factors the following:
(a) Exposure of patient or public to injury or potential injury, physical or otherwise: none, slight, severe, or death;
(b) Legal status at the time of the offense: no restraints, or legal constraints;
(c) The number of counts or separate offenses established;
(d) The disciplinary history of the