WU UW if ap a oy . STATE OF FLORIDA xx fe as DEPARTMENT OF HEALTH a 4 40 ef by, toed Sea DEPARTMENT OF HEALTH Mis Ny, «a “yg Se Petitioner, eas ‘a vs. : . Case No. 98-12080 VIOLETA DATO SEBASTION, R.N., 0 O . 6 b g Respondent. / 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 the Respondent, VIOLETA DATO SEBASTION, RN., 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. 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 2139222. 3. Respondent's last known address is 1391 Capricorn Blvd., Deep Creek, Punta Gorda, Florida 33983. 4. At all times material hereto, Respondent was employed by New Horizons Assisted Living Facility. 5. On or about April 22, 1998, an AHCA HQA facility surveyor made an unanounced site visit to New Horizons. UW ww] 6. At approximately 8:00 a.m., a review of the Respondent's documentation for the administration of medications to patients, indicated that the patients had received the medications for the entire day. 7. _- Some of the medications documented as having been administered by the Respondent, were documented as having been administered later in the afternoon, e.g. 4:00 p.m, 5:00 p.m., etc. 8. The Respondent inappropriately documented administering the aforementioned medications prior to administering them. 9. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, for unprofessional conduct as defined by Rule 64B9-8.005(1)(e)1., F.A.C., by inaccurate recording, altering or falsifying 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 lalrday of By PAN AQ , 9k Robert G. Brooks, M.D. Secretary, Department of Health a Ss. BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration FILED H EPARTMENT OF HEALT aeenQEPUTY CLERK UW Wd COUNSEL FO. E PETITIONER: Reginald D. Dikkin, Senior Attorney FBN: 011292 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDDird Pcp: Lg | po: 3ldv |" HABOARD\ACS\NURSING\ac98-12080.doc

Docket for Case No: 00-000668