STATE OF FLORIDA DEPARTMENT OF HEALTH Pe = PILED DEPARTMENT OF HEALTH 9! Koy 13 PH 4 7] a sas Dy Petitioner, ADMINIS O OF vs. Case No.’ papel oaME BETH PETTY, L.P.N. Respondent. / ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DEPARTMENT OF HEALTH, by and through - jts undersigned counsel and files this administrative complaint before the Board of Nursing against the Respondent, BETH PETTY, and in support thereof alleges: i. Petitioner is the state agency charged with regulating the practice "of nursing pursuant to Chapters 20, 456, 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. 38. Respondent is and has been at all times material hereto, a licensed PRACTICAL NURSE in the State of Florida, having been issued license number PN 729801. oe 8% 43S re an io £ om 4. Respondent's last known address is 4937 Yacht Harbor Drive, Pensacola, Florida 32514. 5. On or about 12/13/00, while employed as Assistant Administrator of Northpointe Assisted Living Facility, the Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: oe Respondent failed to take appropriate nursing intervention when Respondent knew or should have known that Patient A.L.S. was experiencing a change in condition. . 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. 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 this A OPay ot Leohomler 200. John O. Agwunobi, MD, MBA Acting Secretary, Department of Health DEPARTMENT OF HEALT DEPUTY CLERK q CLERK Yebi R, kenen DATE (/28/o6 . BY: Nancy Snurkowski, Cii€f Attorney On Behalf of the Agency for - Health Care Administration we « ca a COUNSEL FOR THE PETITIONER: Michael J. Kapperman, Senior Attorney FBN 879721 Agency for Health Care Administration Allied Health Section Post Office Box 14229 . Tallahassee, Florida 32317-4229 (850) 487-9670 MJK/ pop: (Cx DS pom: 7//7/0! bial cp peepee

Docket for Case No: 01-004400PL