ve we ~ MHILED STATE OF FLORIDA DEPARTMENT OF HEALTH COWUL 14 Py 9: 3 DEPARTMENT OF HEALTH ADHAON OF HEARINGS. © Petitioner, vs. Case No. 1999-61088 ESTELLE DOUGLAS, 00-290/ 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, ESTELLE DOUGLAS, 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 2248982 Kea Cy 7 4. Respondent's last known address 11021 Bailey Lane, Tamarac, Florida 33321. Count | 5. ~ On or between January 1999 and October 1999, Respondent practiced below the minimal acceptable standards of prevailing nursing practice by practicing beyond the scope of her license, educational preparation or nursing experience, to wit: While working at the Tamarac Rehab & Health Center, Respondent provided, and or supervised the provision of, nursing care to psychiatric patients with medical and or Psychiatric conditions that the Respondent, and or the nurses under Respondent's supervision, were not qualified to care for. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. Count Il 7. On or between January 1999 and October 1999, Respondent practiced below the minimal acceptable standards of prevailing nursing practice by delegating professional responsibilities to individuals that the Respondent knew, or should have known, were not qualified by licensure, educational preparation or nursing experience to perform, to wit: While working at the Tamarac Rehab & Health Center, Respondent assigned nurses to provide nursing care to patients with medical and or psychiatric conditions that the Respondent knew, or should have known, the nurses were : Not qualified to perform. ' | | | | | i Cee Nd 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct 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 thisJSl_ day of _YY\WQ 2000, Robert G. Brooks, M.D. Secretary, Department of Health Nancy Snurkowski, Chie On Behalf of the Agency’ Health Care Administration COUNSEL FORTHE PETITIONER: COUNSEL FOR THE RESPONDENT: Reginald D. Diz6n, Senior Attomey Karen Goldsmith, Esquire FBN: 011292 Goldsmith & Grout, P.A. Agency for Hedith Gare Administration 2180 Park Avenue, North #100 Allied Health Section Winter Park, Florida 32790-2011 Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 ag eDy ROD Ira Filed PCP: AMY ME DEPARTMENT OF HEALTH Dom: 2/7/a0t° | CLER —o OAT OO ee

Docket for Case No: 00-002901PL