STATE OF FLORIDA 2.5% % DEPARTMENT OF HEALTH Oy, os ; DEPARTMENT OF HEALTH ee Petitioner, One vs. Case No, 2000-01022 DEBRA CURTIS, O | ~ J70? PL 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, DEBRA CURTIS, and in support thereof alleges: 1. Petitioner isthe state agency charged with regulating the practice : of nursing pursuant to Chapters 20, 486, 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 RE ONER jn the State of Florida, RN 1897672. 4, Respondent's last known address is 2500 Avenue R., Ft. Pierce, Florida 34947-2036. Count | 5.. On or between June 1995 and February 2000, white employed by indian River County Health Department, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: Advanced registered nurse practitioners are required practice under a nursing a protocol and to file yeariy practice protocols with the Board of Nursing; Respondent worked between June 1995 and February 2000 as an advanced registered nurse practitioner without a protocol and without filing a protocol with the Florida Board of Nursing. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(4)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing — practice, by violating Rule 64B9-4, 010 (3); Florida Administrative Code, by not — . having a nursing protocol and by not fi ting : a . yearly 1 nursing J protocol with the Board 1 of i Nursing. Count 7. On or between June 4995 and February 2000, while employed by | indian River County Health Department, Respondent practiced below the — minimal acceptable standards of prevailing nursing practice, to wit: 6. pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by a. In July 1999, Respondent knowingly improperly labled a bottle of medication and gave improperly labled bottle of medication to a patient for self- administration. b. In January 2000, after having been instructed net to issue any medications without her supervisors approval, Respondent issued medications (anti- biotics) to a patient under her care without first obtaining her supervisor's approval. Cc, On multiple occasions Respondent documented prescribing Bacitracin to patients for the treatment of urinary tract infections, when in fact the Respondent actually prescribed Bactrim; Bacitracin and Bactrim are significantly different medications. Based on the foregoing, Respondent is subject to discipline failing to conform to the minimal acceptable standards of prevailing nursing practice. WHEREFORE, Petitioner respectlly request that the Board of Nursing ' enter an Order i imposing one or more of the following penalties: Revocation or suspension of Respondent's license, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. imposition of an administrative fine, | | Signed ti Py day of ( DRG MS 200 . Robert G. Brooks, M.D. Secretary, Department of Health BY: ancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration THE PETITIONER: FILED COUNSEL Reginald D Senior Attorney DEPARTMENT OF HEALTH FBN: 0112925 DEPUTY CLERK Agency for Health Care Administration CLERK Nehi ke Keone? Allied Health Section Post Office Box 14229 DATE 1 2tfer— Tallahassee, Florida 32317-4229 (850) 414 - 8576 ) : : : jboproe RDDIrd PCP, DOM: yb

Docket for Case No: 01-002707PL