WU YW STATE OF FLORIDA ~, . DEPARTMENT OF HEALTH Pipe D DEPARTMENT OF HEALTH, _ PETITIONER, we vs. . CASE NUMBER: 98-18574 MATTYE C. HILL JEFFERSON RESPONDENT. QOO-O BO Lb ADMINISTRATIVE COMPLAINT COMES NOW, the Petitioner, Department of Health, hereinafter referred to as “Petitioner,” and files this Administrative Complaint before the Board of Nursing against MATTYE C. HILL JEFFERSON, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(f), Florida Statutes, the Petitioner has contracted with the Agency of Health Care Administration to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. aa ° 2. . Respondent is, and has been at all times material hereto, a licensed REGISTERED Nurse in the state of Florida, having been issued license number RN 75448-2. Respondent’s last known address is c/o William Furlow, Esq., P.O. Box 1877, Tallahassee, FL 32302-1877. WU UY 3. Atall times material hereto, Respondent was employed by University Medical " Center (hereinafter “UMC”). - 4. On or about March 9, 1998, Respondent was assigned to the 7:00 a.m. — 7:00 p.m. shifon the surgical floor and responsible for monitoring the care of patient A.H. 5. During the aforementioned time period, patient A.H. suffered significant changes in his vital signs that warranted notification to his physician or an attending physician and timely documentation of the changes. 6. Following the aforementioned changes in patient A.H.’s condition, Respondent failed to notify a physician of the changes or document the changes in a timely manner. 7. Respondent’s failure to monitor patient A.H., including, but not limited to, the action and/or failure to act listed in paragraph number six (6) constitutes conduct that falls below the minimal standards of acceptable and prevailing nursing practice. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct, which shall include, but not be limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s license, restriction of the Respondent’s practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. Y signe this MLA day of \ Yorn Dy » year of If ). COUNSEL FOR PETITIONES: Chris Steinhaus, Staff Attorney Florida Bar Number - 0147966 Agency for Health Care Ne Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 CIS/cjs pcp: (gv bw) Dr. Robert G. Brooks, M.D., Secretary - Department of Health Nancy M. Snurkows Chief Attorney Agency for Health Care Administration DATE: hel 47 FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK inners meat pate_ff-(5 97

Docket for Case No: 00-000306