Soe J i) ~~ STATE OF FLORIDA ° DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH | PETITIONER, vs. mee CASENUMBER: 97-19215 TERESA ANN SMITH HAAS, OOS E45 RESPONDENT. i 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 TERESA ANN SMITH HAAS, hereinafter referred toe 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), Florida Statutes, the Petitioner has contacted with the Agency for Health Care - Administration to. : “by the Division not f Medical Q Quality Assurance, councils, or boards, as s appropriate : “2 2. "Respondent is, and has been a at all times material hereto, a licensed Registered known address is 7800 sw 161" Street, “Miami, F FL 33157: 3735. 3. While employed at Baptist Hospital of Miami, on or about May 9, 1997, the Respondent withdrew morphine sulfate “in greater amounts than she charted as being administered. P . Ww 4 U 4. Specifically, at 11: 00 a.m., Respondent withdrew 4 mg. of morphine sulfate and ; charted i it correctly for patient EA. At 12: 25 Pa m., she withdrew 10 mg and charted it as 5 mg. -given.. . 5. At 14:35 she withdrew 10 mg. of morphine sulfate, but charted it as 5 mg. given. Later that same day, she withdrew a morphine drip 250 mg/250 ml. without a physician’s order. She then recorded that morphine drip was wasted at 18:04 p.m. and withdrew 5 me. of morphine sulfate, but did not record that 5 mg. as given on the patient record. 6. Morphine is a controlled substance under chapter 893, Florida Statutes, having the potential for physical and psychological dependence. 7. Respondent was referred to the Intervention Project for Nurses (IPN), a monitoring and referral program for impaired nurses. 8. Respondent initially agreed to participate in IPN, but was not eligible for participation because she denies any problem. 9. Based on the foregoing, the Respondent has violated the following statutory provisions: a). "Section 464,018(1)(f), Florida Statutes, by making a false report or record or 3 intentionally or negligently failing to file a report or record required bys state or federal law: ‘Section 464.018(1)(b), Florida departure from or failure to conform to the minimal Standards of acceptable and prevailing tutes, by unprofessional conduct ora $ret: ; Nd WHEREFORE, Petitioner respectfully requests the Board of Nursing to 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 eifath aay of 4999. Robert G. Brooks, M.D. Secretary Department of Health Nancy M. Snurko’ Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Diane K. Kiesling, Contract Attorney Agency for Health Care Fi LE D Administration DEPARTMENT OF HEALTH ~ 2727 Mahan Drive DEPUTY CLERK ~~ Building3,Room3231A Ge oh ae ~~ Tallahassee, Florida 32308. ; Tb ki ~ (850)410-3468 pate 1/2 fo pce: ABVAM DATE: &//7/¢7 dia aad aaa

Docket for Case No: 00-001843