U a VU STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH . CO-140 Petitioner, vs. Case No. 99-03755 DAVID K. WILLIAMS, 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, DAVID K. WILLIAMS, 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. DAVID K. WILLIAMS, (hereinafter referred to as “WILLIAMS”), is a licensed registered nurse in the State of Florida, having been issued license number RN 2852382. WILLIAMS’s last known address is 8305 NW 170th Street, Alachua, Florida 32615. U oe U 4, In April 1997, WILLIAMS had a prescription for Percocet from his treating physician, Dr. Phillip Springer. 5. Percocet is a Schedule II controlled substance under Chapter 893, Florida Statutes. 6. A substance in Schedule II has a high potential for abuse and has a currently accepted but severely restricted medical use in treatment in the United States, and abuse of the substance may lead to severe psychological or physical dependence. 7. WILLIAMS altered the prescription provided to him by Dr. Springer to reflect that Dr. Springer had authorized refills on the prescription when in fact Dr. Springer had not authorized refills on the prescription. 8. In April 1997, WILLIAMS sought chemical dependency and/or psychiatric treatment from Charter Springs Behavioral Health System (hereinafter referred to as "Charter"). 9. At the time of admission to Charter, WILLIAMS admitted to abusing Percocet, ingesting up to thirty (30) tablets a day. 10. WILLIAMS was diagnosed opiate dependent and treated for opiate withdrawal. . . 11. In May 1997, WILLIAMS contacted the Intervention Project for Nurses (hereinafter referred to as "IPN"), a monitoring and referral program for impaired nurses, on the advise of his treatment professionals at Charter. 12, WILLIAMS admitted to a history of abusing Percocet and entered , Monitoring through IPN. 13. Inor about June or July 1998, WILLIAMS relapsed by using Percocet. U a U. 14. In August and September 1998, WILLIAMS was re-evaluated by chemical addiction professionals; WILLIAMS was diagnosed with opiod depence. 15. In March 1999, WILLIAMS successfully completed intensive outpatient treatment through Perspectives, a drug and alcohol treatment facility. 16. On or about May 6, 1999, WILLIAMS submitted to a random urine drug screen pursuant to IPN monitoring policy. 17. WILLIAMS's urine sampled tested positive for opiates, specifically Morphine. 18. | Morphine is also Schedule II controlled substance under Chapter 893, Florida Statutes, having the same restricted use in the United States and potential for abuse as Percocet. 19. WILLIAMS had no prescription or valid medical reason for using Morphine. 20. Based on the foregoing, WILLIAMS is subject to discipline pursuant to Section 464.018(1)(j), Florida Statutes, by being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or any other type of material or as a result of any mental or physical condition. 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. U oe U Signed this ¢Crday of Awl. 19 Robert G. Brooks, M.D. Secretary, Department of Health Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixgn, Senior Attorney FBN: 0112925| Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 850) 414 - 8576 EDDA pcp: £ove" pom: 42/4 7 S:\Nursing\ACs\ac-williams-d.doc FILED DEPARTMENT OF HEALTH EPUTY CLERK

Docket for Case No: 00-000740