STATE OF CALIFORNIA

DEPARTMENT OF INDUSTRl/\L RELATIONS DIVISION OF WORKERS' COMPENSATION LEGAL UNIT 1515 Clay Street, Suite 1700 Oakland, Cali forn ia 94612 Tel (5 10) 286 -7 100 Fax (5l0) 286-0687

November 3, 2017

Hee Jung Mun 1746 W. 169th Place, Unit A Gardena, CA 9024 7

EDM UND G. BROWN J R., Governor

NOTICE OF PROVIDER SUSPENSION - WORKERS' COMPENSATION

Dear Ms. Mun:

The Administra tive Director of the Division of Workers' Compensation (DWC) is required by Labor Code sections 139.2l(a)(l)(A) and 139.2l(a)(l)(C) to suspend you from participation in the California workers' compensation system for one or more of the following reasons: you have been convicted of a crime described in Labor Code section 139.2l(a)(l)(A) and/or yo ur license, certification, or approval to provide health care services has been surrendered or revoked. Enclosed are copies of the documents relied upon by the Administrative Director as the basis for taking this action.

Your suspension will start 30 calendar days after the dale of mailing of this notice, unless you submit a written request for a hearing, which wi ll stay the suspension pending the outcome of the hearing. Your request must be made within 10 calendar days of the date of mailing of this notice. If you do not request a hearing within the 10-day time limit, you wi ll be suspended from participation in the California workers' compensation system pursuant to California Code of Regulations, title 8, section 9788.2(b).

Your request for a hearing must contain:

Your current mailing address; The legal and factual reasons as to why you do not believe Labor Code section 139.21(a)(l)

is applicable to you; and Your original signature or the original signature of your legal representative.

The scope of the hearing is limited to whether or not Labor Code section 139.21(a)(l ) is applicable to you. The Administrative Director is required to suspend you unless you provide proof in the hearing that Labor Code section 139.21(a)(l) does not appl y.

Your original request for a hearing and one copy of the request must be fil ed with the Administrative Director. Additionally, you must also serve one copy of the request fo r a hearing on the DWC Legal Unit. The addresses for the Administrative Director and the Legal Unitare:

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Hee Jung Mun November 3, 2017

Hearing Request Administrative Director Division of Workers' Compensation 1515 Clay Street, Suite 1800 Oakland, California 94612

and

Hearing Request Legal Unit, Division of Workers' Compensation 1515 Clay Street, Suite 1800 Oakland, Californ ia 94612

The original and all copies of the request for hearing must have a proof of service attached. A sample proof of service, contain ing all necessary elements, can be found on the DWC website at https://www.dir.ca.gov/dwc/fo rms.html , under the category "Court Forms," and then "Proof of Service." The Administrative Director is requi red to hold your hearing within 30 days of the receipt of your written request. The hearing will be conducted by a hearing officer appointed by the Adm inistrative Director. You will be notified shortl y after the receipt of your request of the date and time of the hearing.

For more information about the suspension procedure, please refer to Provider Suspension Regulations, California Code of Regulations, title 8, sections 9788.1 - 9788.4, which can be found on the DWC website at http://www.di r.ca.gov/dwc/DWCPropRegs/Provider-Suspension-Procedure/Clean- Vers ion/Text-of-Regu lations.pdf.

Ge ge Parisotto Administrative Director Division of Workers' Compensation

Encls: -In fo rmation in United States of America v. Hee Jung Mun, aka "Angela Mltn " (Case No. CR-11 -01169), Un ited States District Court, Central District of California -Plea Agreement for Defendant Hee Jung Mun in United Sla tes of America v. Hee Jung Mun, aka "Angela Mlln " (Case No. CR-11-01169), Uni ted States District Court, Central District of Californi a -Criminal Minutes - - Change of Plea in United States of America v. Hee Jung Mun, aka "Angela Mun " (Case No. CR-11-01169), United States District Court, Central District of Californi a -Judgment and Probation/Co mmitment Order in United States of America v. Hee Jung Mun, aka "Angela Mun " (Case Nu. CR-11-011 69), Uni ted States District Court , Central District of Cali forni a -Default Decision and Order - In the Matter of the Accusation Against Hee Jung Mun (Case No. 2016-423), Before the Board of Registered Nursi ng, Department of Consumer Affairs, Slate of Cali fornia, with accompan ying Accusation -Declaration of Socorro Tongco in Support of Not ice of Provider Suspension -Proof or Service

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Case 2:11-cr-01169-DDP D0cument 1 Filq~ 12108/11 Page 1of7 Page ID #:1

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Case 2:11-cr-01169-DDP Document 1 Filed 12/08/11 Page 2 of 7 Page ID #:2 ,.,

1 3, Between on or about May l, 2ooa, and on or about April

2 JO, 2011, Medica:te paid appro:idmately $5, J.44, 2'77 to Greatcare

3 for .claims relating .to homa heal t:.h 111

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Case 2:11-cr-01169-DDP Document 1 Filed 12/0B/11 Page 3 of 7 Page ID #:3

I to aituationiu in which specified qi.n1.lifying conditiQns were met.

2 These conditions included the following;

3 a. The Medicare beneficiary was confined to the home

4 and did not have a wil+ing care~siver to assist him or her1

5 b. 'l'he beneficiary needed akilied nursing aexvices or

6 physical or occupational therapy services; 7 c, The beneficia1y WV.I! i.mder the care of a qualified

8 physician who established a written Pl.an of Care for the

9 benefioia:i..-y, signed by the physician and an RN (o:i: by a

10 therapist if only therapy -services were provided) from tl1e home

11 heal. th agency;

12 d. Skilled nursing seX"Vic.es were provided by ol:' under

13 the supa:rv:!.sion of an RN in accordance with the plan of care;

14 . and

15 a. '!'he skilled nurl!ling serviees or physical or

16 occupatiorral therapy were medically necessary.

17 l.O. To determine the proper level of care for a particular

Ul banefioia:ry and the amount of payment, Medicare required home

19 health agencies to perform an initial assessment of the

20 patient's current heal.th and living conditions, using' a tool

21 called the Outcome md Assealillllent Information Set ("OASIS")

22 l'.L Medicare :i:eqilired the initial assessment and OASIS

23 fa.rm to be completed by a.n RN or a qua.lj.fied therapist.

24 12. Medicare also required a home health agency to

25 maintain a. clinical. record of service;s provided to each

26 beneficia:i:y, including signed and dated clinical and progrel!ls

27 . notes record:i.ng each homa visit

.28 13. M(!dicare paid home health agenciea baaed on a payment

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Case 2:11-cr-01169-DDP Document 1. File.s:l 12/0B/ll Page 4 of 7 Page ID #:4

system under which Medicare paid home health agencies for each

sixty-day episode of services. Th~ amount of the payment was

based primarily on the severity of the beneficiary's health

condition and care needs as represented by the OASIS data.

El , l!l:llL:lCliEME TO DJjllj'RAIJD

to

14. Beginning on or about May l, 2000, and continuing to

on or about March 2, 2011, in.Los .l\.ngeles county, within the

central District of. California, and elsewhere, defendant MON,

together with others known and unkno~n.to the Vnited States

Atto:rney, knowingly, willfully, and wit:h intent to def.raud,

executed and attempted to execute a saheme a.nd artifice:

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Case 2:11-cr-01.169-DDP Document 1. FileiJ 12/0B/11 Page 5 of 7 Page ID #:5

d. rhe marketers and doctor1!J :i:ec:ruited and referred

Medicare beneficiaries even though those beneficiaries did not

need skilled nursing or therapy services.

e. Additionally, defendant MON paid Meda.care

beneficiaries approximately $300 to induce them to mign up for

home health lifervices from Greatca:i:e. GreatciilXe enrol.led these

beneficiariea even though they did not need lilldlled nu;t:aing or

the:r.apy services.

f. Defendant Ml.TN concealed her payments to these.

ll\lJlX'klilters, doctors,, and Medicare beneficia:r.ies by making_ those

payments in cash or through checks from her personal accounts,

rather than Greatca.:r.e's business accounts.

g. Defendant MUN hired individuals who were licensed

to provide nursing or th!!rapy services to asisit;1t her in

1:5 . preparing fraudulent docummts that pu:rport:ed to support

16 Greatcare's prPvision of home health se:i:-vicea to Medicare

17 beneficiaries. ln pa:i:ticul;;i,r, defendOUlt MUN and these other

18 licensed employees acting at defendant MON' a instructiont

19 i. Prepared false OASIS forms for Medicare

20 beneficd.aries receivillg home health services f:roin Gr