| | i | STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, | PETITIONER, ve | | CASE NO. 2014-18443 "KATIE ELIZABETH, RIN, | 1 RESPONDEN T. | / 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, Katie Elizabeth, R.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 registered nurse (R:N.) within the state of Florida, having been issued license number RN 9278405. | | 3. _ Respondent's addtess of record is 1311 Pullen Road, Jacksonville, Florida 32216. . 4. Respondent. is licensed pursuant to Chapter 464, Florida Statutes, and is a health care practitioner as defined in Section 456.001(4), Florida Statutes (2014). | 5. Qn or about December 10, 2013 Respondent executed a two (2) year monitoring contract: with the Intervention Project for Nurses CIPN). | 6. On or about october 28, 2014, IPN sent the Department a letter indicating that Respondent was terminated from IPN due to Respondent falling to comply W with the terms of her monitoring contract. 7. IPN is the imate 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. 8. Section 456.072(1)(hh), Florida Statutes (2014), provides that _ being terminated from a treatment program for impaired practitioners, which is overseen by an impaired practitioner consultant as described in Department of Health v. Katie Elizabeth, RN. : 2 Case Number 2014-18443 :

Docket for Case No: 16-000932PL