U Nw] RECEVED- STATE OF FLORIDA ~— DEPARTMENT OF HEALTH S9APR-8 PN I: 3° DEPARTMENT OF HEALTH, PETITIONER, 00-0867 vs. CASE NUMBER: 97-05048 BARBARA KEIFER RESPONDENT. 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 BARBARA KEIFER, 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 (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(£), 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 PRACTICAL Nurse in the state of Florida, having been issued license number PN 0833051. Respondent’s last known address is 4118 Maywood Dr., Brandon, FL 33511. 3. Pursuant to chapter 893, Florida Statutes, Darvocet is a schedule IV controlled substance, abuse of which may lead to limited psychological or physical dependence. 3: U UY 4, - On or about January 6, 1997, Respondent submitted to an pre-employment urine drug screen for Tampa Health Care Center. The urine drug screen returned positive for Darvocet. . 5. Respondent did not have a prescription for, nor did she have a legitimate purpose engaging in the use of Darvocet. 6. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(1)(e)18., Florida Administrative Code, testing positive for any drugs under chapter 893 on any pre- employment or employer ordered drug screén when the nurse does not have a prescription and legitimate medical reason for using such drug. - 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. SIGNED this m\ day of (You g , 1999. Robert G. Brooks, M.D. Secretary, Department of Health Nancy M. Snurkowski Chief Attorney Agency for Health Care Administration FILED DEPARTMENT O° “1EALTH EPUTY CLERK cuenngptipha0. uw -1- 95 DATE Ht 95 i U COUNSEL FOR PETITIOQ} Chris Steinhaus, Attorfey / Florida Bar Number (oyb 66 Agency for Health Caré Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 850) 414-8576 CJS/cjs Pcp; LR\LM" DATE: ealac|9

Docket for Case No: 00-000867