wn ww) STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 98-13642 ALEXANDER S. JONES, 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, ALEXANDER S. JONES, 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 73620-2. 4. Respondent's last known address is 1504 NW 20th Street, Homestead, + Florida 33030 1a ttahy NS, Y 5. Respondent is an Advanced Registered Nurse Practitioner (ARNP) certified by the Florida Board of Nursing. 6. When practicing as an ARNP, the Respondent is required by Board of Nursing (Board) rules to practice under a protocol with a licensed Florida physician (or dentist, where appropriate). 7. When practicing as an ARNP, the Respondent is required by Board rule to maintain a copy of the protocol under which the Respondent practices on the premises in which the Respondent practices. 8. When practicing as an ARNP, the Respondent is required by Board rule to file a copy of the protocol under which the Respondent practices with the Agency for Health Care Administration or the Agency's agents yearly. Count I 9. Respondent practices as an ARNP at two separate sites. 10. Upon a request from an Agency for Health Care Administration investigator to both sites where the Respondent practices as an ARNP, Respondent and/or Respondent's agents could not provide a copy of the protocol under which the Respondent practices. 11. Based on the foregoing, Respondent is subject to discipline pursuant to section 455.624(1)(q), Florida Statutes, by violating Rule 64B9-4.010, F.A.C., by failing to maintain a copy of the protocol under which the Respondent practices at the site and/or sites where Respondent practices. Count II VU YW 12. Respondent and/or Respondent's agents have failed to file yearly protocols with the Agency for Health Care Administration or the Agency's agents. 13. Based on the foregoing, Respondent is subject to discipline pursuant to section 455.624(1)(q), Florida Statutes, by violating Rule 64B9-4.010, F.A.C., by failing to maintain a copy of the protocol under which the Respondent practices at the site and/or sites where Respondent practices, 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 Otay of DY LO) low Robert G. Brooks, M.D. Secretary, Department of Heal BY: Nancy Snurkowski, Chfeff Attorney On Behalf of the Agency for Health Care Administration FILED HEALTH . DEPARTMENT OF COUNSEL FDR THE PETITIONER: Deputy C ae pon Reginald D. n, Senior Attorney FBN: 01129 - CLERK lay 9/99 Agency for Health Care Administration ore (27/27 Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCPABV LM DOM: Vhed \\FDHCTLH02\NURSING\Nursing\Administrative Complaints\jones-alexander.doc

Docket for Case No: 00-000762