WU A] STATE OF FLORIDA 00 JA - DEPARTMENT OF HEALTH N13 AM 10: 34 ADMIN oe . INES | ne DEPARTMENT OF HEALTH, HE AR noe VE " PETITIONER CO0-004¢6 vs. CASE NUMBER: 99-03808 HOPE ANN SULKOWSKI RESPONDENT. / ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Nursing against HOPE ANN SULKOWSKIL, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(£), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. Respondent is, and has been at all times material hereto, a licensed REGISTERED Nurse in the state of Florida, having been issued license number RN 2942982. Respondent’s last known address is 9084 109th Avenue North, Largo, FL 33777. 3. At all times material hereto, Respondent was employed by Sun Coast Hospital (hereinafter “SCH”). YU UY 4. On or about March 14, 1999, Respondent documented withdrawing 50mg of- Demerol for a patient. _ 5. Respondent documented wasting the Demerol; however, she was not witnessed wasting the Demerol. 6. The minimal standards of acceptable nursing practice require that when nurse wastes a controlled substance, that the wastage be witnessed by a second party and documented. 7. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct, which shall include, but not be limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this en of CX shou" , 1999. Dr. Robert G. Brooks, M.D., Secretary - Department of Health Nancy M. Snurkowski * F | LE D Chief Attorney DEPARTMENT OF HEALTH Agency for Health Care Administration EPUTY CLERK i i COUNSEL FOR PETITION. Chris Steinhaus, Staff aon Florida Bar Number - 0147 Agency for Health Care Administration Allied Health - P.O. Box 14229 Tallahassee, FL 32317-4229 850) 414-8576 CIS/cjs pcp: /4V Bu)

Docket for Case No: 00-000046