; 6 . »ceived Event (Event Succeeded) LA ~ / G He vA date: ages: temote@eiDs—oga2 aa:56 5/16/02 Time: 8:44 AM 18 Sender: ™ on STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 200110512 LISA KAY FARMER, LPN, Respondent. / ES 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, LISA KAY FARMER, 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 Practical Nurse in the State of Florida, having been issued license number 5144988. P.@8/18 ceived Event (Event Succeeded) ate: 5/16/02 Time: 8:44 AM ages: 18 Sender: emote GslBs—2aa2 28:57 5 P.a9/18 ro" a 4, Respondent's last known address is 20 Cormorant, Daytona, Florida 32119. 5. On or before August 2, 2001, while employed as the Director of Nursing at Kates Cove, Inc., an assisted living facility; Respondent practiced below the minimal acceptable standards of prevailing nursing practice, by inaccurately recording, altering or falsifying employee training certificates for employees who needed them. 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 thisooH aay of Atlor aad ,200.>)- John O. Aqwunobi, M.D., M.B.A. D Secretary, Department of Health DEPARTMENT OF MEALTH DEPUTY CLERK BY: Nancy Snurkows On Behaif of the Agency for Health Care Administration Received Event (Event Succeeded) Date: 5/16/02 Time: 8:44 AM Pages: 18 Sender: Remote GS!0;-2992 29:57 a 4 P.10/18 COUNSEL FOR THE PETITIONER: Michael T. Flury, Senior Attorney FBN: 0118590 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 487-9686 MTF/mf PCP: . DOM: T furs ayer 10

Docket for Case No: 02-001994PL