STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, | PETITIONER, v. CASE NO, 2014-05819 DENISE COOPER, 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 Respondent, Denise Cooper, L.P.N., and in support thereof alleges: 1, Petitioner is the state agency 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 Administrative Complaint, Respondent was a licensed practical nurse (L.P.N.) within the state of Florida, having been issued license number PN 5153575. 3. Respondent's address of record is 1831 2" Avenue East, Bradenton, Flerida 34208. 4. - On or about October 14, 2010, Respondent entered into. an Advocacy. Contract with the Intervention Project for.Nurses (IPN). 5. IPN is the impaired nurses program for the Board of Nursing, designated pursuant to Section 456.076, Florida Statutes. IPN. is a 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. 6. The Advocacy Contract, entered into by Respondent, had a projected active monitoring period from on or about October 14, 2010, through on or about October 14, 2015. 7. On or about April 14, 2014, Respondent was terminated from IPN due to noncompliance with the terms of Respondent's Advocacy Contract. 8. Section 456.072(1)(hh), Florida Statutes (2013), provides that being terminated from a treatment program for impaired practitioners, which is overseen by’ an impaired practitioner 2 consultant as described in Section 456.076, Florida Statutes, for _____failure—to—comply—without—good_cause,_with_the_terms_of the monitoring or treatment contract entered into by the licensee, or for not successfully completing any drug treatment or alcohol treatment program, constitutes grounds for disciplinary action. 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 (2013). 10. As set forth above, on or about April 14, 2014, Respondent was terminated from IPN due to noncompliance with the terms of Respondent's Advocacy Contract. il. Based on the foregoing, Respondent violated Section 456.072(1)(hh), Florida Statutes (2013), by being terminated from a treatment program for impaired practitioners, which is overseen by an impaired practitioner consultant as described in Section 456.076, Florida Statutes, for failure to comply without good: cause, with the terms of the monitoring or treatment contract entered Into by the licensee, or for not successfully completing any drug treatment or alcohol treatment program. WHEREFORE, the Petitioner respectfully requests that the Board—of_Nursing_enter—an_order_imposing_ohe. 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. / SIGNED this © day of _ 4m 2015. John H. Armstrong, MD, FACS State Surgeon General and Secretary of Health cas L. May Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 - Florida Bar No.: 0102747 (850) 245 - 4444 ext. 8242 Telephone (850) 245 - 4683 Facsimile Lucas.May@flhealth.gov ILED /LLM. DEPARTMENT (OF HEALTH DEPU EI PCP: Jenuwy S$, tele CLERK Angel Sanders PCP Members: Lepbu 5k & any pare JAN 06 208 4 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 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.

Docket for Case No: 15-001997PL