STATE OF FLORIDA BOARD OF NURSING HOME ADMINISTRATORS DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2020-12066 SEBRINA CAMERON, N.H.A., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner, Department of Health, files this Administrative Complaint before the Board of Nursing Home Administrators against Respondent, Sebrina Cameron, N.H.A. In support, Petitioner alleges: 1. Petitioner is the state agency charged with regulating nursing home administrators pursuant to section 20.43, Florida Statutes; chapter 456, Florida Statutes; and chapter 468, Part II, Florida Statutes. 2. At all times material to this Complaint, Respondent was licensed as a nursing home administrator in the State of Florida, having been issued license number NH 4950. 3. Respondent’s address of record is 13455 West U.S. Highway 90, Greenville, FL 32331 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 4. At all times material to this Complaint, Respondent served as the regional administrator for Golden Senior Care, the parent company for Cross Landings Health and Rehabilitation Center, (Cross Landings) a nursing home located in Monticello, Florida. Respondent served as regional administrator for Cross Landings and was responsible for overseeing and assisting in the administration of Cross Landings. 5. On or about April 5, 2020, Patient 1, a resident at Cross Landings, tested positive for COVID-19, a contagious respiratory disease. 6. On or about April 7, 2020, Patient 2, a resident at Cross Landings, tested positive for COVID-19. 7. On or about April 11, 2020, Patients 3 and 4, residents at Cross Landings, tested positive for COVID-19. 8. On or about April 14, 2020, Patients 6-13, residents at Cross Landings, tested positive for COVID-19. 9. On or about and between April 9 and April 14, 2020, four registered nurses contracted by the Department of Health (team) visited Cross Landings. 10. The team’s objectives at Cross Landings were to: DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 a. assess the general patient care procedures, infection control practices, and cleaning processes at the facility; . assess the process being used for screening of healthcare workers; provide guidance to facility healthcare workers on hygiene, infection control, the proper use of personal protective equipment (PPE‘), proper patient diagnostic procedures, and practices to follow with patients who test positive for COVID-19; . identify and recommend actions to be taken to improve the sanitation practices and control the spread of infection including, but not limited to, proper social distancing practices, isolation of patients, co-locating infected or possibly infected patients away from non-infected patients (in rooms, wings, or buildings), patient treatment, screening and handling practices, and timely transport of infected patients to the hospital; 1 PPE is used to protect health care workers, patients, and others when providing care. PPE helps protect the wearer from infectious diseases, toxic medications, and other potentially dangerous substances used in healthcare delivery. 3 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 e. augment facility nursing staff by providing temporary patient care, filling in for healthcare workers so they can gather for PPE/infection prevention education, and assist with patient/healthcare worker testing; and/or f. help to assess the need for additional resources such as PPE, patient care supplies, proper signage, and commercial deep cleaning of rooms and buildings. 11. As regional administrator, Respondent is responsible for cooperating with the Department of Health’s efforts to control the spread of COVID-19 throughout the facility. 12. On or about and between April 9 and 14, 2020, Respondent failed to cooperate with the team and/or willfully obstructed the team from accomplishing its objectives by instructing staff to disregard the team’s recommendations; and/or by refusing to provide the team with requested information and/or documentation. 13. On or about and between April 9 and 13, the team made recommendations for proper PPE use, hygiene, and sanitization practices at Cross Landings. DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 14. Respondent failed to consistently implement, or ensure the consistent implementation of, the team’s recommendations at Cross Landings. 15. As the regional administrator, Respondent is responsible for overseeing the creation, implementation, and execution of appropriate screening measures at the entrance of Cross Landings. 16. On or about and between April 9 and 14, 2020, Respondent failed to ensure the consistent implementation of appropriate screening measures at the entrance of Cross Landings. 17. On or about and between April 9 and 14, 2020, individuals entered Cross Landings without Cross Landings staff: a. Accurately assessing their temperature; b. Accurately documenting their temperature in a designated log book; c. Asking them appropriate screening questions; d. Documenting the responses to the screening questions; e. Reviewing the responses to the screening questions prior to granting the individuals entry to Cross Landings. DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 18. As the regional administrator, Respondent is responsible for ensuring that Cross Landings residents and staff were properly equipped with protective personal equipment (PPE), including but not limited to gloves and respirators. 19. Respondent failed to provide PPE, including gloves and respirators, to Cross Landings staff and residents. 20. Respondent repeatedly refused to provide PPE to the team. 21. As the regional administrator, Respondent is responsible for ensuring that the Cross Landings staff were properly trained on the use of PPE, personal hygiene practices, and/or sanitization of Cross Landings, to control the spread of COVID-19, and/or ensure that these procedures were followed at Cross Landings. 22. On or about and between April 9 and 13, 2020, one or more Cross Landings staff failed to appropriately use PPE, including masks and/or gloves. 23. On or about and between April 9 and 13, 2020, on one or more occasion, Cross Landings staff failed to wash or otherwise sanitize their hands prior to patient interaction. DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 24. On or about and between April 9 and 13, 2020, Cross Landings staff failed to implement sanitization practices in Cross Landings. 25. Respondent failed to ensure that the procedures for proper use of PPE, personal hygiene practices, and/or facility sanitization to prevent the spread of COVID-19, were being followed. 26. As the regional administrator, Respondent is responsible for ensuring that COVID-19 positive residents are isolated from other residents. 27. Cross Landings staff failed to implement adequate procedures to prohibit Residents that were positive for COVID-19 from leaving the isolation area and/or to prohibit healthy residents from entering the isolation area. 28. Respondent failed to adequately isolate COVID-19 positive patients from other residents and/or failed to implement, or ensure the implementation of, appropriate protocols related to the isolation of COVID- 19 positive residents. 29. Respondent failed to ensure that Cross Landings staff kept COVID-19 positive residents confined to the isolation area and/or failed to keep healthy residents outside of the isolation area. DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 30. As regional administrator, Respondent is responsible for appropriately staffing Cross Landings, and/or managing the staff to avoid repeated patient neglect. 31. On or about and between April 9 and 14, 2020, the team observed one or more residents soiled by urine and/or feces for an extended period of time, indicative of neglect. 32. On or about April 11, 2020, the team observed a resident with multiple sores on the patient’s heels, back, and/or side, indicative of neglect. 33. On or about and between April 9 and 14, 2020, the team observed one or more patients living in rooms in a state of disarray, including no bedsheets on the mattress and/or soiled items on the floor. 34. Respondent failed to appropriately staff Cross Landings, or manage the staff of Cross Landings, to prevent repeated patient neglect. COUNT I 35. Petitioner realleges and incorporates paragraphs 1 through 34 as if fully set forth herein. 36. Section 468.1755(1)(h), Florida Statutes, authorizes discipline for engaging in fraud or deceit, negligence, incompetence, or misconduct in the practice of nursing home administration. 8 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 37. Respondent engaged in negligence, incompetence, and/or misconduct in the practice of nursing home administration in one or more of the following ways: a. b. By failing to cooperate with the team’s recommendations; By obstructing the team’s implementation of the team’s objectives; . By failing to create, implement, or ensure the execution of appropriate screening measures at the entrance of Cross Landings; . By failing to provide staff and residents with appropriate PPE; . By failing to provide adequate training on the use of PPE and hygiene practices to prevent the spread of COVID-19; . By failing to isolate COVID-19 positive patients from other residents; . By failing to implement, or ensure the execution of, appropriate protocols related to the isolation of COVID-19 positive patients; and/or . By failing to appropriately staff Cross Landings, or manage the staff of Cross Landings, to prevent repeated patient neglect. 9 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 38. Based on the foregoing, Respondent violated section 468.1755(1)(h). COUNT II 39. Petitioner realleges and incorporates paragraphs 1 through 34 as if fully set forth herein. 40. Section 468.1755(1)(k), Florida Statutes, authorizes discipline for repeatedly acting in a manner inconsistent with the health, safety, or welfare of the patients of the facility in which he or she is the administrator. 41. Respondent repeatedly acted in a manner inconsistent with the health, safety, or welfare of the patients of the facility in which she was the administrator in one or more of the following ways: a. Repeatedly attempting to obstruct the team’s completion of their team mission; b. Repeatedly refusing to provide PPE to staff; c. Repeatedly failing to implement the team’s recommendations to control the spread of COVID-19 at Cross Landings; and/or 10 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 d. Failing to appropriately staff Cross Landings, or manage the staff of Cross Landings, to prevent repeated patient neglect. 42. Based upon the foregoing,-the Respondent has violated Section 468.1755(1)(k), Florida Statutes (2019). WHEREFORE, the Petitioner respectfully requests that the Board of Nursing Home Administrators 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. il DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 SIGNED this 5th day of May, 2020. Scott A. Rivkees, M.D. State Surgeon General FILED DEPARTMENT OF HEALTH /s/ Kristen SUMIMAEYS DEPUTY CLERK Kristen M. Summers CLERK: (hota Mos Chief Legal Counsel pate:___MAY_0 5 2020 DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Florida Bar Number 112206 (T) (850) 558-9909 (F) (850) 245-4662 (E) Kristen.Summers@flhealth.gov PCP Date: May 4, 2020 PCP Members: Goodman, Kocik, Helmer 12 DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative Code. If Respondent fails to request a hearing within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28-106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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. DOH v. Sebrina Cameron, N.H.A. Case No. 2020-12066

Docket for Case No: 20-003025PL