its, a es = dit ne ee ee ibis STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2001-07627 ANDREA NORMAN, L.P.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, ANDREA NORMAN, L.P.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 c consumer r 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 i is and has been at all times material hereto, a licensed L ‘NURSE in ihe’ State of Florida, having been issued license number 4. Respondent's last known address is 20 Foster Lane, Palm Coast, Florida 32137. ° 5. On or about January 11, 2001, Respondent was employed by i the Huntington Assisted Living Facility (Huntington). 6. On or about January 11, 2001, Patient AW, an 80-year-old female, fell and sustained a black eye, bruises to her right hip and right wrist, and knee pain. 7. On or about January 11, 2001, Respondent examined Patient AW, but did not contact the patient's family or the patient's physician. 8.- Onor about January 11, 2001, Respondent did not complete an incident report regarding Patient AW's fall. 9... .On or about January 12, 2001, the patient was taken to Halifaz Medical Center, for the injuries resulting from the aforementioned fall; the Patient required surgery to address some of the injuries. 10. Respondent practiced below the. minimal acceptable standards or nursing practice by failing to notify the patient's physician and or family. 41. Respondent practiced below the minimal acceptable standards by failing to complete an incident report regarding the patient's fall. 12. Respondent's actions “and or failure to act resulted in an un- necessary delay in Patient AW receiving the appropriate medical treatment. _ 13. "Based on the foregoing, Respondent is subject to discipline pursuant to section 464. ore()(h), Florida Statutes, by unprofessional conduct by SE RIC IC mem failing to conform to the minimal acceptable standards of prevailing nursing practice. WHEREFORE, Petitioner respectfully request that the Board of Nursia 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 | Wtyday of bowvew lar, 200. . John O. Agwunobi, MD, MBA - Acting Secretary, Department of Health BY: Nancy Snurkowskt, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: , Fil LED . Reginald D. Dixon, Senior Attorney DEPARTMENT OF HEAL FBN: 04112925 oa oe Agency for Health Care Administration CLERK ushi Re Kenon Allied Health Section Le Post Office Box 14229 . pare_ti [22 Jor Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: DOM: tovdd ufo! DEPUTY CLERK

Docket for Case No: 02-000383PL