STATE OF FLORIDA - . DEPARTMENT OF HEALTH 00 JAN 13 AM Io: 35 DEPARTMENT OF HEALTH, AO i fee PETITIONER, vs. CASE NUMBER: 97-19066 RONDA LA-CHERYL AMMONS Od-o OSE 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 RONDA LA-CHERYL AMMONS, 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)(f), 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 PRACTICAL Nurse in the state of Florida, having been issued license number PN 0994291. Respondent's last known address is 900 NW 9th Ave., #170, Mulberry, FL 33860. 3. On or about October 10 through October 11, 1997, Respondent was employed by the Groves Center and assigned to work a double-shift from approximately 3:00 p.m. through 7:00 a.m. 4. On or about October 10, 1997, patients WM and HG were transferred from the hospital to the Groves. 5. Respondent was responsible for performing admitting the aforementioned patients to the Groves and conducting assessments on them. : 6. On or about the aforementioned dates, Respondent failed to complete the admission process for the aforementioned patients. 7. Respondent admitted to failing to complete the admission process for the aforementioned patients. 8. Respondent’s failure to properly admit the aforementioned patients constitutes action that falls below the minimal standards of acceptable nursing practice. Count I 9. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. , i 10. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(15), Florida Administrative Code, by practicing beyond the scope of the licensee’s license, educational preparation or training. Count II 11, Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs as if fully stated herein. 12. 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 arise day of ia AL , 1999. Dr. Robert G. Brooks, M.D., Secretary - Department of Health ancy M. Snurko Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Chris Steinhaus, Staff Attorney Florida Bar Number - 0147966 Agency for Health Care Administration F Allied Health P.O. Box 14229 DEPARTMENT OF HEALTH YCLERK Tallahassee, FL 32317-4229 peigh v0, ee 850) 41498576 CLERK hom 2. CIS! omen aalaa | PCP: | DATE:

Docket for Case No: 00-000056