WU v | ‘STATE OF FLORIDA LED DEPARTMENT OF HEALTH OOWUL 14 PH 3:39 DEPARTMENT OF HEALTH aivisi VISION OF Petitioner, sO RS TRATIVE vs. ; Case No. 1999-61326 TOMASA NANCY DEL VAL, 00-2 90 yf - Respondent. ! » ADMINISTRATIVE COMPLAINT 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, TOMASA NANCY DEL VAL, 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. Pursuant to the authority of Section 20.43(3)(g), Florida Statutes, the Petitioner has contracted with the Agency for Health Care Administration to provide consumer complaint, investigative and prosecutorial services required by the Division of Medical Quality Assurance, councils or boards, as appropriate, including the issuance of emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, a licensed REGISTERED NURSE in the State of Florida, having been issued license number RN 387802. VU Nw 4. Respondent's last known address is 1090 Quail Avenue, Miami, Florida 33166. 5. On or about October 6, 1999 or October 7, 1999, Respondent was convicted, found guilty or entered a plea of nolo contendere to, regardless of adjudication, a crime which directly relates to the practice of nursing or the ability to practice nursing, to wit: . Respondent pled guilty to conspiracy to defraud the 2 ’ United States by obtaining and aiding to obtain the , payment and allowance of false, fictitious and fraudulent Medicare claims. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(c), Florida Statutes, by being convicted or found guilty of, or entering a plea of nolo contendere to, regardless of adjudication, a crime in any jurisdiction which directly relates to the practice of nursing or to the ability to practice nursing. 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. Signed thisAlgl day of (VW. 4 , 2008, Robert G. Brooks, M.D. Secretary, Department of Health ‘Nancy Snurkowski, Gre On Behalf of the Agency for Health Care Administration orney COUNSEL FORIJHE PETITIONER: Reginald D. DixdAy Senior Attorney Florida Bar Number04 12925 Agency for Health Care Administration Practitioner Regulation Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8437 - RDDitrd = PCP: £as Vat pom<7h rf.009 FILED lea OF HEALTH CLERK. Date Gyo! ZS DATE Co fey >

Docket for Case No: 00-002904PL