Jun-22-2000 02:37pm From 7-858 = P.O1N/021 = -F+777 Ve. UY Ae STATE OF FLOP 2 i a AGENCY FOR BEALTH DA mista TiN E p Pg. oye 0 STATE OF FLORIDA, AGENCY FOR OWUL 20 AM 10: 42 YY HEALTH CARE ADMINISTRATION, is iw or . Petitioner, auica wel YOG-NH Ae * 00-2907 BEV. ENTERPRISES-FLA. INC. d/b/a BEV Gi d/b/a BEV., HEALTH & REHAB.CENTER- PA Respondent. ia oe ADMINISTRATIVE COMPLAINT YOU ARE HEREBY NOTIFIED that after twenty-one (21) days from receipt of this Complaint, the Agency for Health Care Administration (hereinafter referred to as the “Agency”) intends to impose a civil penalty in the amount $1,000.00 upon BEV. ENTERPRISES-FLA. INC, W/h/a BEV. GULF COAST, d/b/a BEV. HEALTH & REHAB. CENTER- PARADISE PINES (hereinafter teferred to as “Respondent”), As grounds for the imposition of this civil penalty, the Agency alleges as follows: (1) The Agency has jurisdiction over the Respondent pursuant to Chapter 400 Part-I, Florida Statutes. | (2) Respondent is licensed to operate a mursing home at 11565 Harts Road, Jacksonville, Florida 32218, in compliance with Chapter 400 Part I, Florida Stamites, and - Rule 594-4, Florida Administrative Code. (3) The Respondent has violated the provisions of Chapter 400 Part 1, Florida Statutes, and provisions of Rule 59A-4, Florida Administrative Code, in that it was cited for one (1) Class III deficiency during an follow-up inspection of May 4, 2000. These Jun-22-2000 02:38em From T-858 = P.012/02 Cran , U deficiencies, set forth below, were previously cited during an initial inspection of March 30, 2000 and constitute uncorrected deficiency. (a) The Respondent has not always provided care and services to ensure that residents who enter the faciliry without pressure ulcers do not develop pressure ulcers, and to promote healing for those residents who have pressure ulcers. This is in violation of Chapter 400.23, and Rule 59A-4.1288, Florida Administrative Code. Class I deficiency. Fme: 3$1,000,00. (4) The above referenced violations constitute grounds to levy this civil penalry pursuant to Section 400.23, and Rale 59.4-4.1288 Florida Administrative Code, in that the above referenced conduct of Respondent constitutes a violation of the minimum standards, rules, and regulations for the operation of a Nursing Home. (5) Respondent is notified that it has a right to request an administrative hearing pursuant to Section 120.57, Florida Statutes, to be represented by counsel (at its expense), 10 take testimony, to call or cross-examine witness, to have subpoenas and/or subpoenas duces tecum issued, and to present written evidence or argument if it requests a hearing. Chapter 59-1, Part I, Florida Administrative Code, constitutes the Agency’s procedural rales for administrarive proceedings under Section 120.57(1), Florida Statutes, your request for administrative hearing must conform to the requirements in Rule 29-5. 201, Florida Administrative Code, and must state which issues of material fact in your request for a hearmg may be treated by the Agency as an election by you of an informal proceeding under Section 120.57(2), Florida Stamtes. All requests for hearing shall be made to the Agency for Health Care Administration, and delivered to Agency for Health Care Administration, Building #3, Suite3431, 2727 Mahan Drive Tallahassee, Florida F~777 Jun=22-2000 02:38em From 7-958 013/021 UW 7] 32308; Anention: Michael O, Mathis, Senior Artomey. Payment of fines shall be sent to the Agency for Health Care Administration, P.O. Box 13749, Tallahassee, Florida 32317- 3749. (Please reference the case number and facility name on the front of your check). (6) Respondent is further notified that failure to request @ hearing within twenty one (21) days of reccipt of this complaint will result in an admission of the facts alleged in the complaint and the entry of a final order by the Agency. CERTIFICATE OF SERVICE | ‘I HEREBY CERTIFY that a true copy hereof was sent by U_S. Certified Mail, remm Receipt Requested to Connie Bend, Administrator, Beverly Health & Rehab- Paradise Pines, 11565 Harts Road, Jacksonville, Florida 32218 on this 9th day of 5 June , 2000. CS foo en Swann Supervisor, Area #4 Agency for Health Care Administration Health Quality Assurance 921 North Davis St., A-115 Jacksonville, FL 32209 . Copies fiurmished te: Michael O. Mathis, Esquire Senior Attormmey Connie Bend, Administrator Agency for Health Care Administration Beverly Health & Rehab-Paradise Pines 2727 Mahan Drive 11565 Harts Road Bldg. #3, Sure 3408-D Jacksonville, FL 32218 Tallahassee, FL 32308-5403 Karen Swann Finance & Accounting Supervisor, Area Office #4 Agency for Health Care Agency for Health Care Administration Administrator Health Quality Assurance Bldg, 2, 2™ Floor 921 North Davis St., A-115 2727 Mahan Dr. Jacksonville, FL 32209 Tallahassee, FL 32308 F-T777

Docket for Case No: 00-002969