STATE OF FLORIDA 4 DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 1999-61946 MARCIA SLOULIN 0 |-O| loFL Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as "Petitioner," and files this Administrative Complaint before the Board of Nursing against MARCIA SLOULIN, hereinafter referred to 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, Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes; and the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecuterial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. 2. 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 2802652. Respondent's last known address is 727 Hillcrest Drive, Bradenton, Florida 34209. Count | 3. At all times material hereto, Respondent was employed responsible for providing home health care services to patient G.S. 4, Between April 18 and April 24, 1999, Respondent's care of patient G. S. fell below the minimal standards of acceptable and prevailing nursing practice, to wit: While Respondent was providing home health care services to patient G. S., intentionally caused or through negligence allowed patient G. S.'s ear to suffer a scald or contact burn. 5. Between October 21 and October 22, 1999, Respondent's care of patient G.S. fell below the minimal standards of acceptable and prevailing nursing practice, to wit: While Respondent was providing home health care services to ’ patient G. S., intentionally caused or through negligence allowed patient G. S.’s right shoulder and back to suffer a scald or contract burn. 6. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(i), Florida Statutes, unprofessional conduct as defined by the following: Rule 64B9-8.005(13), Florida Administrative Code by failing to conform to the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established; Rule 64B9- 8.005(2), Florida Administrative Code, by administering medications or treatments in a negligent manner; and Rule 6489-8.005(12), Florida Administrative Code, by acts of negligence, gross negligence, either by omission or commission. { on us . ia . WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Otter imposing one or more of the following penalties: _Revocatién 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 thisYth. day of Cus. Mt _ , 200.0. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, ttorney On Behalf of the Agency for Health Care Administration COUNSEL FOR’ THE PETITIONER: ) : DEPARTMENT © Reginald D. Gixon, Senior Attorney F HEALTH FBN: 01129 . DEPUTY CLERK Agency for Haaltf'Care Administratio CLERK Yahi R, Keron, Allied Health Section Post Office Box 14229 pare__ 8/9/2005 7 {2002 Tallahassee, Florida 32317-4229 (850) 414 - 8437 RDD/bp pop: f¢1 1D pom: 7/4 ¢/a7e*

Docket for Case No: 01-000116PL