led ci Er STATEOF FLORIDA —-P9AUG 15 gy Hi: 38 DEPARTMENT OF HEALTH Wy A Toe aa DEPARTMENT OF HEALTH ES TRATIVE Petitioner, vs. Case No. 98-03282 PATRICIA ANDERSON SILVER, 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, PATRICIA ANDERSON SILVER, 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 51406-2. U oS U 4. Respondent's last known address is 14920 SW 129th Place, Miami, Florida 33186. 5. At all times material hereto, Respondent was employed by Jackson Memorial Hospital. 6. A review of facility records revealed discrepancies in the Respondent's documentation, including but not limited to: a. Respondent signed out controlled substances under the name of "Irene Dunn"; b. Respondent signed out controlled substances without documenting administering the medication to patients; c. Respondent signed out controlled substances at a time prior to her shift having begun; and d. Respondent signed out controlled substances for patients who did not have physician's orders for the medication checked out. 7. Respondent's documentation is inaccurate and/or false. x. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by violating Rule 64B9-8.005(1)(e)1., F.A.C., by inaccurate recording, altering and/or falsifying patient records. 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. U Ne] Signed this {ay of Byrd , 19] Robert G. Brooks, M.D. Secretary, Department of Heal COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDDird cP: LB|Ln Nancy Sn #7 Chief Attorney On Behalf of the Agency for Health Care Administration FILED DEPARTMENT OF HEALTH EPUTY CLERK oxen gptphau0. uw pate 4-24-99 DOM: 3b 44

Docket for Case No: 00-003443PL