UL . STATE OF FLORIDA 0 Wh gs DEPARTMENT OF HEALTH Ow OG | of 4 4Aonghis. /; DEPARTMENT OF HEALTH, 00-03 @ As. lip, 93 | Ak) as PETITIONER, 4 A ie 0 vs. CASE NUMBER: 99-03466 SANDRA J. WILSON PETERS RESPONDENT. a 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 SANDRA J. WILSON PETERS, 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. nn 7 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 85575-2. Respondent’s last known address is c/o Bruce Lamb, Esq., 201 East Kennedy Blvd., 10 Floor, Tampa, FL 33602. | vA \/ 3. At all times material hereto, Respondent was working at Lakeland Regional Medical Center (hereinafter “LRMC”). 4. On or about March 30, 1999, patient L.M. presented to LRMC with a potential complication regarding her pregnancy. 5. On or about March 30, 1999, L.M. was examined by her physician, Dr. John Caravello, who performed a sharp uterine dilation and curettage on the patient. , 6. Following the procedure, Dr. Caravello ordered the patient to receive a 75 mg intramuscular dose of Methotrexate prior to her discharge from LRMC. 7. The aforementioned order was documented on L.M.’s order sheet along with other medications that were ordered to be administered to L.M. 8. On or about March 30, 1999, Respondent was responsible for ensuring that the aforementioned ordered medications were transcribed to L.M.’s Medication Administration Record (hereinafter “MAR”). 9. Respondent failed to transcribe the aforementioned order for Methotrexate to L.M.’s MAR. 10. As arresult of the transcription error, L.M. was not administered Methotrexate prior to her discharge from LRMC. 11. Respondent’s aforementioned conduct constitutes conduct that falls below the minimal standards of acceptable and prevailing nursing practice. 12. _ 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. nt Le 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. SIGNED this Af Aday of hovonlae—_, year of f aX : COUNSEL FOR PETITI Chris Steinhaus, Staff A; Florida Bar Number - 6 Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 pcp: “bv Bw CIS/cjs Dr. Robert G. Brooks, M.D., Secretary - Department of Health Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration DATE: cohefp? oo. - FiLEO DEPARTMENT OF HEA LTH EPUTY CLERK CLERK Q iow DATE MIS GG

Docket for Case No: 00-000384