U oS) Onn “OD - STATE OF FLORIDA oS: : DEPARTMENT OF HEALTH 2m, SH CSO DEPARTMENT OF HEALTH eA! Q.- slay : i ! z Petitioner, c vs. Case No. 97-19261 DEBRA LYNN BRAY JURKOWICH, Respondent. / ADMINISTRATIVE COMPLAINT : 7 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, DEBRA LYNN BRAY JURKOWICH, 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. 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 35780-1. 3. Respondent's last known address is 7940 Sasser Lane, Pensacola, Florida 32506. 4. On or about September 25, 1997 and September 18, 1997, Respondent was employed by Sacred Heart Hospital. UY 1) . . 5. On or between September 25, 1997 and September 28, 1997, Sacred Heart Hospital observed several problems regarding Respondent's documentation, including but not limited to: a. Respondent withdrew a controlled substance from the narcotic drawer/Sure Med system for a patient that was no longer on her unit; b. Respondent withdrew a controlled substance from the narcotic drawer/Sure Med system for a patient who did. not have a physician's order for the medication; and . c. Respondent withdrew controlled substances from the narcotic drawer/Sure Med system without documenting administering the medication in the patient Medication Administration Record. 6. Respondent was suspended from duty pending an_ investigation. Respondent was subsequently terminated from Sacred Heart Hospital. 7. Based on the foregoing, Respondent's license to practice nursing in the State of Florida is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, for unprofessional conduct as defined by Rule 64B9-8.005(1)(e)1., by inaccurate recording, altering or falsification of patient records. 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 U Signed unis (Ay of _{ Up at yA , 1990 Douglas M. Cook Director mcy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FO E PETITIONER: Reginald D. Dixy, Staff Attorney ; FBN: 0112925 t. Agency for Health Care Administration : Allied Health Section . Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 487 - 9637 RDD/td PCP: PB/BW H:ABOARD\ACS\NURSING\ac97- 19261 .doc pom: ~7/27 /48 FILED DEPARTMENT OF HEALTH EPUTY CLERK cusmnpftiphome0. uw pate, © AL“ VY

Docket for Case No: 00-001712