“STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, OO-WBB vs. CASE NO. 98-14534 Petitioner, JANICE FRANZO, Respondent. ADMINISTRATIVE COMPLAINT COMES NOW the Petitioner, , Department of Health, and files this Administrative Complaint before the Board of Clinical Laboratory Personnel, against the Respondent, JANICE FRANZO and i in support thereof would state: 1. Petitioner is the state agency charged with regulating the practice of Clinical Laboratory Personnel, pursuant to Section 20.43, Florida Statutes; Chapter 455, Florida Statutes; and Chapter 483, 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, hereinafter referred to as "the "Agency," to provide consumer complaint, investigative, and prosecutorial services required by the Division of Medical Quality Assurarice, councils or board, as appropriate, including the issuance of emergency orders of suspension or restriction. eae ek Meath UV. ae 3. Respondent has beén at all times pertinent hereto, a duly licensed clinical laboratory technician pursuant to Chapter 483, Florida Statutes, having been issued license number JC 0014150. 4, Respondent's last known address is 4324 Woodlynne Lane, Orlando, Florida 32812. 5. Petitioner is informed and believes, and based upon information and belief alleges that the Respondent was the Hematology Supervisor at Colombia Park Medical Center, now known as the Lucerne Medical Center, 818 Main Lane, Orlando, Florida 32801, from January 1, 1994 to December 31, 1994, from November 1995 to March of 1996; and again from May of 1996 until January of 1998. 6. Petitioner is further informed and believes, and based upon said information and belief alleges that the Respondent was the laboratory supervisor at the same facility from January 1995 until November 1995. Hematology Supervisor 7. The conduct of the Respondent as aforesaid is contrary to the provisions of Section 483.825 (2), Florida Statutes, by engaging in, or attempting to engage in, a clinical laboratory function not authorized by, and beyond the scope of her license, as the Respondent is - licensed as a clinical laboratory technician, and not a Supervisor. _ WHEREFORE, Petitioner respect Fequests the Board of Clinical Laboratory Personnel to enter an Order i imposing one or more of the penalties proscribed by law, together with any other and further relief deemed just under the circumstances. _ SIGNED thif | Pbeday of uick.d ~ , 1999. ~ Robert G. Brooks, M.D. Secretary, Department of Health ae teas en die —Ree ny AGA Sia MR By: Nancy M. Snurkow: Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: - Lawrence F. Kranert, Jr. ‘Senior Attorney Florida Bar No. 0171063 ’ Agency for Health Care Administration General Counsel's Office - MQA Allied Health P.O. Box 14229 Tallahassee, Florida 32317-4229 (850) 487-2225 “LFK/Ik PCP: eke MELLO . FILED DEPARTMENT OF HEALTH EPUTY CLERK crm piphanr9, Dim © DAT he Aa lok ee ae

Docket for Case No: 00-001183