JUN-B2-28 : 18 16:55 AHCA Jun 2 2010 16:04 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2009-22932 CARLA DENICE COLLINS, R.N., RESPONDENT. Ee 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 Respondent, Caria Denice Collins, R.N., and in support thereof alleges: . 1. Petitioner is the state department charged with regulating the practice of nursing pursuant fo Section 20.43, Florida Statutes, Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2, At all times material to this Administrative Complaint, Respondent was 4 licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 9266587. P.@4/12 JUN-@2-2818 16156 AHA Jun 2? 2010 16:05 3. Raspondent’s address of record is 17 Buffalo Plains Lane, Palm Coast, Florida 32137. 4. Onor about June 25, 2007, the Board of Nursing filed a Notice of Intent to Approve with Conditions (Notice). 5. The Notice, which conditionally approved Respondent's license, required Respondent to enter into the Intervention Project for Nurses (IPN) and comply with all conditions of the IPN advocacy contract. 6. IPN is the impaired nurses program for the Board of Nursing, designated pursuant to Section 456.076, Fiorida Statutes. IPN is 2 program that monitors the evaluation, care, and treatment of impaired nurses. IPN also provides for the exchange of information between treatment providers and the Department for the protection of the public. 7, On or about November 6, 2009, Respondent was dismissed from IPN for failure to comply with all conditions imposed by IPN. g. Section 456. 072(1)(q), Florida Statutes (2009), provides that violating 4 lawful order of the department or the board, or failing to comply with 4 lawfully issued subpoena of the department, constitutes grounds for disciplinary action. Department of Health v. Carla Denice Collins, R.N. 2 Cage Number 2009-22832 iy \PSU\Nursing\Jodi- -ANN Sohnson\Administrative Compiaints\Violation of a Final Order\Collins, Carla Denice.dac P.@5/12 JUN-@2-2618 16:56 AHCA Jun 2 2010 16:05 P6712 9, Respondent is licensed pursuant to Chapter 464, Florida . Statutes, and is a health care practitioner as defined in Section 456.001(4), Florida Statutes (2009). 10, Respondent violated an order of the Board of Nursing by tailing to comply with any and all terms and conditions imposed by IPN as required by the Notice filed on June 25, 2007. 11, Based on the foregoing, Respondent violated Section 456,072(1){a}, Floriaa Statutes (2009), by violating @ lawful order of the department or the board, or failing to compiy with a lawfully issued subpoena of the department WHEREFORE, the Petitioner respectfully requests that the Board of Nursing enter an order imposing one or more of the following penalties: Department of Health v. Carla Denice Colling, RN. case Number 2009-22922 J:\PSU\Nursing\Jadi-Ann Johnson Administrative Camplaints\Wolation of @ Final Order\Colling, Carla Denice.doc JUN-@2-2818 16:56 SHA Jun 2 2010 16:05 Parle 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. SIGNED this a2>_ day of be toy Lage 200). Ana M. Viarnonte Rese, M.D., M.P.H. State Surgeon General eiED, “ey ta cities f t DEPARTMENT Or HEATH = Jbdi-Ann V. Johnso CLERK: ea eae \_Assistant General Cute . ORE “_* Biacleee DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0073525 (850) 245 - 4640 Telephone (850) 245 - 4683 Facsimile 1/25/10 PCP: PCP Members: C. HORNE & 8. BOWEN NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120.57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and Department of Health v. Carla Denice Collins, RN. Case Number 2009-22932 J\PsU\Nursing\odi-Ann Johnson\administrative Complaints\Violation of a Final Order\Collins, Catia Denige.doc JUN-@2-2010 16! 6:5? AHCA Jun 2 2010) 16:05 cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing ts requested. NOTICE REGARDING ASSESSMENT OF costs Respondent 1s placed on notice that Petitioner has incurred costs related to the investigation and prosecution of this matter: Pursuant to Section 456.072(4), Ejorida Statutes, the Board shall assess costs rafated to the investigation and prosecution of 2 disciplinary matter, which may include atrorney hours and cests, on the Respondent in addition to any other discipline imposed. Department of Health v. Carla Denice Cohing, RAN. Cage Number 2009-22932 J:\PSU\NursingodrAnn Jonnson\Administrative Complaints\vielation of a Final Order\Collins, Carla Denice.dac P.@8/12

Docket for Case No: 10-003028PL