00 hy STATE OF FLORIDA CB DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 98-13145 SHERYL LOCK, d 4 , 0 Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through its undersigned counsel and files this administrative complaint before the Board of Nursing against the Respondent, SHERYL LOCK, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. 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 2216982. 4. Respondent's last known address is 4761 SW 57th Terrace, Davie, Florida 33314-4523. . . 4 U U 5. At all times material hereto, Respondent was employed. by Broward General Medical Center. 6. Respondent received a verbal order from a physician to draw and administer medication to a patient. 7. Respondent delegated this duty, via verbal communication, to another nurse to carryout. 8. The medication was subsequently drawn and administered to the patient. 9. It was subsequently discovered that the medication administered was not the medication that was ordered by the physician. 10. Respondent should have carried out the physician's order instead of delegating the duty to another via verbal order; Respondent was negligent in failing to do so. 11. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by failing to conform to the minimal acceptable standards of prevailing nursing practice. WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this\ Uday of 19A\ Robert G. Brooks, M.D. Secretary, Department of Health COUNSEL FOR JHE PETITIONER: Reginald D. Dix, Senior Attorney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: Boyd & Malasanos DOM: 11-20-98 HABOARD\ACS\NURSING\ac98-13145.doc BY: Nancy Snurkowshi, Chief Attorney On Behalf of the Agency for Health Care Administration

Docket for Case No: 00-000670