STATE OF FLORIDA — ¥2 DEPARTMENT OF HEALTH * DEPARTMENT OF HEALTH oz - Petitioner, Agt Wit vs. oe Case No. 2000-14504 GAIL A. RYAN, R.N., 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, GAIL A. RYAN, R.N., and in support thereof alleges: 1. 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. 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 1920662. creer poe re 4, Respondent's last known address is 824 Briar Glen Court, ’ Englewood, Florida 34223-6021. 5. At all times material hereto, including but not limited to between _ September 1999 and September 2000, Respondent was the Director of Nursing for Harborside Healthcare Center-Pinebrook Care Center (Harborside). 6. As the Director of Nursing, Respondent is responsible, to some degree, for the safety and development of care plans for the patients under her care. 7. Respondent failed to ensure the safety of the patients under her care, to wit: Respondent knew or should have know that several patients under her care were abusive and or physically acting out, but failed to timely and appropriately address those patient’s nursing and or medical needs or requirements, including modifying the patient’s _ care plans, resulting in those patients causing injuries, some of which were serious, to other patients and or nursing staffs at Harborside. 8. Respondent practiced below the minimal acceptable standards of prevailing nursing practice. 9. 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, aor Sere Rr pe pempe cemameme gee + cope aa issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems vy Signed this eH /\day of i nA NY Why , 200 | John O. Agwunobi, MD, MBA Acting Secretary, Department of Health / A BY! Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSE R.THE PETITIONER: Reginald ixon, Senior Attorney D FBN: 011 Depart Agency for Health’ Care Administration DEPUN oe REALTE Allied Health Section CLEP Post Office Box 14229 K Tei Eenon Tallahassee, Florida 32317-4229 ore a Je (850) 414 - 8576 3 Ei RDD/rd PCP: " MPohan ay iy 7 / one RRC ETTORE RR RR RE RR Re RR RE Sa

Docket for Case No: 02-000338PL