~~} Bision of Administrative Hearings ___ STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, . PETITIONER, Qo-/ O54 vs. : CASE NUMBER: RN 1999-02784 SHEILA M. TORPEY TOOLE, RESPONDENT. a 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 SHEILA M. TORPEY TOOLE, hereinafter referred to as “Respondent, ” and alleges: 1. Effective July 1, 1997, Petitioner i 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 Gyo, Florida Statutes, the Petitioner has contracted with th consumer complaint, investigative, and p secutorial services required by the Division of Medical Quality Assurance, councils, or boards, as appropriate. in the st State of Florida, having been issued license number 1676532. Respondent s last known address i is 222 w 734i Ct, Panama City, FL 32405- 3304. ae At all Limes material hereto, Respondent was employed by Weems Memorial - Hospital, and assigned to the care of patient JG. Se re ME uv 4 \ 4. At no time material hereto did Patient JG have physician’ s orders for Vicodin. 5. On or about February 24, 1999, Respondent withdrew and administered Vicodin to patient JG. 6. Respondent’s administration of medication to a patient who did not have physician’s orders for said medication constitutes action that falls below the minimal acceptable standards of prevailing nursing practice. 7. Based on the foregoing, Respondent is subj ect to discipline pursuant to Section . 464. 0181), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8. 005(13), Florida Administrative Code, by failure to conform to the minimal standards of acceptable prevailing nursing practice. 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, i imposition of an administrative fine, issuance of a a reprimand, placement o of the ne Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this is} aay, of Dignan om. 1999, ...- Robert Brooks, MD . _ Secretary- Department of Health Nancy M. Snurkowski F ! L E D Chief Attorney PARTMENT OF HEALTH Agency for Health Care Administration EPUTY CLERK RNR eg meee ee ee re Soren oe meee COUNSEL FOR PETITIONER: Chris Steinhaus, Atto: “ Florida Bar Number 966 - Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 CJS/cas pcp: #L~ CO DATE: e/n7/9 7 tet ee ee serene ip nee ie penta ne pete cope et perme caper gene

Docket for Case No: 00-001054