Feb 21 2008 14:42 FEB-21-2888 15:13 AHCA STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO, 2006-10817 . DIANNE J.M. MEREDITH, A.R.N.P., & RESPONDENT. 6 / 3 iT NT COMES NOW, Petitioner, Department of Health, by and through its undersigned counsel, and files this Administrative Complaint before the Board of Nursing against Respondent, Dianne J.M. Meredith, A.R.N.P., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. "2, At all times material to this Complaint, Respondent was a Licensed Practical Nurse within the State of Florida, having been issued license number RN- 2556372, 3. Respondent's address of record is 20538 Keaton Beach Road, Perry, Florida 32348. -—h,-—_On—or—about_February—5,—2006,-Respondent_was—an --on-call_purse—__...___ anesthetist for Doctor's Memorial Hospital (Hospital) in Perry, Florida. Feb 21 2008 14:42 FEB-21-2888 15:14 AHCA P.a4 ). On or about February 5, 2006, Respondent was called into the Hospital to administer anesthesia to a patient. 6. Respondent was driven to the Hospital by her husband. 7. Respondent appeared to be intoxicated. Specifically, Respondent was described as having difficulty maintaining her balance, improperly placing a nasal cannule on the patient, acting in a disoriented manner, and being generally unorganized. 8. The asked by a member of the Hospital staff, the husband stated that Respondent had been drinking. ED Respondent provided a written response to the Department's investigation wherein she explains that she had consumed Ambien CR. - 10. Ambien CR is in a class of drugs calléd sedative/hypnotics or sleep medications. Ambien will cause drowsiness and may cause dizziness. Alcohol will increase drowsiness and may increase dizziness while you are taking Ambien. 11. Respondent explained that on February 5, 2006, the Ambien CR caused her to become uncoordinated and disoriented, have impaired judgment, suffer memory loss, and rendered her unable to perform her job functions when she reported for duty at the Hospital. The Respondent also indicated that she made a great error in judgment | and is grateful the patient was not harmed as a result of her impairment. 12. Section 464.018(1)(h), Florida Statutes (2004), provides that unprofessional ————-conduct_as_defined_by _board +ule-consiitutes-grounds-fer disciplinary action_by the Beard of Nursing. Dianne J.M, Meredith, A.R.ALP. Page 2 DOH Case Number 2006-10617 3:\P5U\Nursing\William Miller\Goard of Nursing\Meredith 2006-1081 7\Meredith.Administrative Complaint.dac Feb 21 2008 14:43 FEB-21-2888 15:14 AHCA P.@S 13. Rule 64B9-8,.005(1)(e), Florida Administrative Code, provides that unprofessional conduct shall include acts of negligence either by omission or commission. | | 14. Respondent provided negligent care to a patient by attempting to administer anesthesia while under the influence of a medication that caused her to become uncoordinated and disoriented, have impaired judgment, suffer memory loss, and rendered her unable to perform her job functions when she reported for duty at the Hospital. 15, Based on the foregoing, Respondent has violated Section 464.018(1)(h), Florida Statutes (2006), through acts of unprofessional conduct as defined by Rule 64B9-8.005(1)(e), Florida Administrative Cade. WHEREFORE, the Petitioner respectfully requests that the Board of Nursing enter an order imposing one or more of the following penalties: permanent revocation or suspension of Respondent’s license, restriction of practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. Dianne J.M. Meredith, A.R.N.P. Page 3 DOH Case Number 2006-10817 JA\PSU\Nursing\William Miller\Board of Nursing\Meradith 2006-1081 7\Meredith. Administrative Complaint.dec FEB-21-2888 15:14 SIGNED this _ 2 DEPARTMENT OF HEALTH UTY CLERK OLERK: DATE__ = iR7 O71 pop: 223-21 PCP Members: Ramos & Munoz Feb 21 2008 14:43 day of _ eb 2007. Joseph J. Chiaro, M.D., FAAP Interim Secretary, Department of Health °° William F Miller Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar # 0421080 (850) 245-4640 Ext. 8203 (850) 245-4683 FAX Dianne J.M. Meredith, A.R.N.P. DOH Case Number 2006-10817 Page 4 J:\PSU\Nursing\William Miller\Board of Nursing\Meredith 2006-10817\Meredith, Administrative Complaint.doc Feb 21 2008 14:43 FEB-21-2088 15:15 AHCA Pa? Dianne J.M. Meredith, A.R.N.P. DOH Case Number 2006-10817 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 170.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. Dianne J.M. Meredith, A-R.N.P, DOH Case Number 2006-10817 J:\PSU\Nursing\William Miller\Board of Nursing\Meredith 2006-10817\Meredith.Administrative Complaint.doc Page 5

Docket for Case No: 08-000947PL