Can U os STATE OF FLORIDA “TILED DEPARTMENT OF HEALTH mis DEPARTMENT OF HEALTH, DIVISION *OHINISTR ATT VE PETITIONER, . TEARINGS ys. CASE NUMBER: 99-04246 ANGELA BYNUM ROBINSON o-a7o3 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 ANGELA BYNUM ROBINSON, 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; Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. Pursuant to the authority of Section 20.43 (3)(f), 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 0924951. Respondent’s last known address is 669 54th Avenue South, St. Petersburg, FL 33705. 3. Atall times material hereto, Respondent was working at Suncoast Manor Nursing Home (hereinafter “Suncoast”). Uo. Y 4. On or about April 25, through April 26, 1999, Respondent was responsible for care of resident KM. 5. On or about April 25, through April 26, 1999, resident KM began to exhibit signs consistent with suffering from a stroke. 6. Respondent failed to recognize that KM was exhibiting signs consistent with a stroke, failed to timely and properly respond to these signs, and failed to report these signs to resident KM’s physician in a timely manner. Count I 7. Respondent’s care for resident KM, or lack thereof, between April 25 and April 26, 1999, constitutes conduct that falls below the minimal standards of acceptable and prevailing nursing practice. 8. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct, which shall include, but not be limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established. 9. Petitioner realleges and incorporates by reference the foregoing paragraphs as if fully stated herein. 10. Onor about April 25, 1999, Respondent was employed as one of the Charge Nurses on duty at Suncoast. As Charge Nurse, Respondent was responsible for the supervision of other nurses and/or CNA’s. 11. Section 464.003(3)(b), Florida Statutes, does not give licensed practical nurses the authority to perform supervisory duties. Cian VY 12. Based on the fofegoing, Respondent is subject to discipline pursuant to Section — 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8. 005(15), Florida Administrative Code, by practicing beyond the scope of the licensee’s license, training, or educational preparation. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondents 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 day of \ wn da , 2000. Dr. Robert G. Brooks, M.D., D Secretary - Department of Health DEPARTMENT OF HEALTH DEPUTY CLERK ark Webi RM ane Nancy M. Snurkowski - _ OOD oate__ 9 -//-Fe0> Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITI Chris Steinhaus, Staff A Florida Bar Number - 0M Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 , CIS/cjs PCP:C2NAL = - DATE: Ya 7002 Medical records with related case # 99-04174

Docket for Case No: 00-002903PL