STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, . Ob- YL 6 vs. CASE sani 98-10642 REGINA IRENE HILL 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 REGINA IRENE HILL, 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 (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. ‘Pursuant to the authority of Section 20.43 — G0, Florida Statutes, the Petitioner has contracted with the Agency of Health Care : Administration to provide > consumer complains, investigative, and prosecutorial services required | by the Division of Medical Quality Assurance, councils, OF boards, as appropriate. sons 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 RN 1130851. Respondent's last known address is 1790 Baywood Ave., Orlando, FL 32818. . 3. On or about September 3, 1993, Respondent was in the process of obtaining licensure as a practical nurse. eH ~ 4. On or about September 3, 1993, Respondent was employed as a Certified Nursing Assistant at Orlando Regional Medical Center. 5. On or about September 3, 1993, Respondent submitted to an employer-ordered urine drug screen; the urine drug screen returned positive for Cannabinoids. 6. On or about September 20, 1993, Respondent was referred to the Intervention Project for Nurses (hereinafter “IPN”, a monitoring and referral service for impaired nurses, by her employer for the aforementioned incident. 7. On or about October 13, 1993, Respondent obtained licensure as a practical nurse. 8. On or about October 15, 1996, Respondent submitted to an IPN-ordered drug screen; the drug screen returned positive for alcohol. . 9. On or between October 13, 1993, and March 5, 1998, Respondent was delinquent in turning in her required IPN-paperwork, prompting IPN to mail eleven (11) noncompliance letters to her. 10. Onor about March 5, 1998, Respondent was notified by IPN that if she did not send in her required Paperwork by March 13, 1998, she would be dismissed from IPN. “11. Onor about March 31, 1998, Respondent was dismissed from IPN for repeated ; noncompliance i in sending her paperwork i in, 12. esp nt? 's ‘use ofa lcohol and/or controlled substances affects her ability to Practice nursing with reasonable skill and safety to Patients. LBP eet Bienes eRe nt en SR . 13. Based on the foregoing, Respondent is subject to -isipin pursuant to Section 464, 01806), Florida Statutes, for being unable to practice nursing with reasonable skill and safety to patients by. reason of iliness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. A el » Allied Health _P.O. Box 14229 Y os ad 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 wie Dah ny ot Oclsln __, 1998. Douglas M. Cook, Chief. Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Chris Steinhaus, OPS Attorney Agency for Health Care Admihj Tallahassee, FL 32317-4229 (850) 487-9692 FILED CIS/ejs PCP: FA|Bw3 oP AEbUTY cure Bee 0, Din pare_/O-OR- 9

Docket for Case No: 00-000746