WU I] STATE OF FLORIDA... DEPARTMENT OF HEALTHC; ~:. DEPARTMENT OF HEALTH, PETITIONER, VS. CASE NUMBER: RN 1999-01902 CAMILLE PHILLIPS, RESPONDENT. b- b G7 / 0? 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 CAMILLE PHILLIPS, 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. 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 32174. Respondent’s last known address is 8866 Scenic Highway, Pensacola, Florida 32514. 3. At all times material hereto, Respondent owned and operated the Pensacola Hyperbaric Care Center in Pensacola (hereinafter known as “PHCC”). Respondent arranged for medical treatment by physicians to patients at PHCC . On physicians’ orders, Respondent Pa Ww UW administered prescription medications, kept in stock on the premises, including substances controlled under chapter 893 of the Florida Statutes, to patients at PHCC. 4. At all times material, Respondent had no pharmacy permit. 5. At all times material, in order to obtain the prescription medications for use at PHCC, Respondent used the Drug Enforcement Administration (DEA) number of J.M. Chimiak, MLD., a licensed physician, without his knowledge or consent. 6. Respondent allowed the use of the prescription drugs obtained without knowledge or consent for the benefit of PHCC and other physicians who used the facility. 7. Respondent has a registered nursing license only and practiced outside the scope of that license by purchasing medications, including controlled substances, for the benefit of PHCC and other physicians who used the facility, through the unauthorized use of a licensed physician’s DEA registration number. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, for unprofessional conduct, which shall include, but is not 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, and further pursuant to Rule 64B9-8.005(15), practicing beyond the scope of the licensee’s license, educational preparation or nursing experience. 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. : Gd SIGNED this AU Aday of [DYpftelowc.o. Dr. Robert G. Brooks, M.D., Secretary - Department of Health a —~ Nal icy M. Snurkowski Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: ' R. Lynn Lovejoy, Senior Attomey . Florida Bar Number - 455090 Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 850) 414-8437 RLL pep: AK ¥ Co pate: SA7/%7 DEPARTMENT OF HEALTH EPUTY CLERK CLERK a¥ DATE O-F-F

Docket for Case No: 00-000669