eo] oo ) STATE OF FLORIDA RECEIVE ty, DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH He 5 a ; yy te ; Petitioner, 0 O “3 7 Qo Oo a7 vs. , Case No. 98-10599 SAMUEL RIVERA, 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 the Respondent, SAMUEL RIVERA, and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Chapters 20, 455, and 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, a licensed PRACTICAL NURSE in the State of Florida; having been issued license number PN 1218571. 4. Respondent's last known address is 1497 Johnson Road, Auburndale, Florida 33823. SOMAY 11 niga "e% Y Y oe U 5. At all times material hereto, Respondent was employed by Mariner Health of Winter Haven. 6. Respondent documented changing the dressing on a patient's wound when in fact he had not changed the dressing on the patient's wound. 7. The Respondent's changing of the patient's dressing when in fact he had not constituted inaccurate recording and/or falsifying of patient records. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by violating Rule 64B9-8.005(1)(e)1 + F.AC., by inaccurate recording, altering and/or falsifying of patient records. WHEREFORE, Petitioner respectfully request that the Board of Nursing enter an Order imposing one or more of the following penalties: Revocation or suspension of Respondent's license, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. Signed this)” Ylaay oc Hovl 199 Robert G. Brooks, M.D. Secretary, Department of Health BY: | Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration FILED DEPARTMENT OF HEALTH EPUTY CLERK CLERK Q. ne COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attorney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDDitd PCP: 1 a/ LM DOM: afoalag

Docket for Case No: 00-000392