STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 99-03953 TAMMY JEANETTE HESS, R.N., 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, TAMMY JEANETTE HESS, R.N., 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)(2), 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 ADVANCED REGISTERED NURSE in the State of Florida, having been issued license number RN 3099332. WY QW 4. Respondent's last known address is 3036 Hudson court, Decatur, Georgia 30033 5. At all times material hereto, Respondent provided nurse-midwife services to Patient C.S. 6. Patient C.S.'s medical condition was such that the Respondent knew or should have known, that the Respondent was not sufficiently prepared by education, training or experience to manage the care of Patient C.S. during the course of Patient C.S.'s pregnancy. 8. Respondent failed to refer Patient C.S. to the appropriately trained medical personnel for management of Patient C.S.'s pregnancy. 9. Respondent practiced below the minimal acceptable standards of nursing practice. 10. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. 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 thisdebday of (Ye cw, 1995 Robert G. Brooks, M.D. Secretary, Department of Health On Behalf of the Agency for ‘Health Care Administration 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 RDD/rd PCP: CoV AA— ‘DOM: Va / S:\Nursing\Administrative Complaints\hess, tammy.d LED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK Webi RAM ont pate_/& /23/97

Docket for Case No: 00-000818