. YY FILER . ~ QO JUL 18 AMI0: 34 RNa five STATE OF FLORIDA HE ARIRGS DEPARTMENT OF HEALTH Ve. 90-3932) _ DEPARTMENT OF HEALTH, Petitioner, . vs. , ~CASENO.: 96-1324 DAVID ACHILLES RICHARDSON, Los Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against DAVID ACHILLES RICHARDSON, 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 (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes. 2. Pursuant to the authority of Section 20.43(3)(f), Florida Statutes (Supp. 1996), 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. 2. 3. Respondent is, and has been at all times material hereto, a Registered Nurse, having been issued license number RN 1235222. 4. Respondent’s last known address is 815 Satin Leaf Avenue, Oldsmar, . Florida 34677. 5. At all times material hereto, Respondent was,employed by Clearwater Community Hospital. 6. On or about November 24, 1995, Patient H.B- presented to the Emergency Room with a chief complaint of chest pain. The paramedic who was in charge of initial triage reported his findings, including a past history of cardiac workup that was negative two (2) weeks prior and a diagnosis of esophageal reflux, to the Respondent. Subsequently, the patient was retumed to the waiting area. 7. Upon giving the aforementioned report to the Respondent, the paramedic had fulfilled his responsibility of assessment. Subsequently, the Respondent assumed responsibility for assessment, Respondent delayed the assessment by not completing it in a timely manner. This resulted in an inappropriate triage priority assignment and a delay of treatment. . 8. Respondent did not assess the patient for two (2) hours while the patient was in the waiting room, and had not seen the patient until immediately before Patient HB. went into cardiac arrest. 9. As a result, there was a delay in performing the EKG and having the patient assessed by a physician. The Respondent failed to complete the initial assessment , ‘properly or in a timely manner, and therefore fell below minimum acceptable standards of prevailing nursing practice. COUNT I 10.~ Petitioner realleges and incotporates by reference the allegations contained in the foregoing paragraphs asif fully stated herein. , | 11. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida is subject to discipline. pursuant-to Section-- 464.018(1)(h), Florida Statutes, by unprofessional conduct, including, but not limited to, any departure from, or the failure to conform to, the minimal’standards of acceptable and prevailing nursing practice. ) | WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an Order imposing one or more of the following penalties: suspension of license, imposition of an administrative fine not to exceed $1,000 for each offense, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. | SIGNED this day of ( Nh le , 1998. Douglas M. Cook, Director F | LE D Chief Attomey * DEPARTMENT OF HEALTH On Behalf of the Agency for EPUTY CLERK Health Care Administration CLERK Q. ‘DATE q _ COUNSEL FOR AGENCY: “’ Reginald D. Dixon Staff Attorney Florida Bar Number 0112925 Agency ‘for Health Care Administration General Counsel’s Office - MQA Allied Health P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9637 RDD/SB/kmg PCP: LB\em a\30\4 ?

Docket for Case No: 00-002932PL