wi STATE OF FLORIDA riLeEN DEPARTMENT OF HEALTH 00 JUL 18 AM 10: 33 DEPARTMENT OF HEALTH, ADMINS GN Sve HEARINGS” Petitioner, vs. . O O- dl y 43S BARBETTE SARDAM CASE NO.: 96-17932 Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against BARBETTE SARDAM 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. 3. Respondent is, and has been at all times material hereto, a licensed PRACTICAL NURSE, having been issued license number PN 1069561. Alannah 4. Respondent’s last known address is 5558 Regal Oak Circle, Orlando, Florida 32810. 5. On or about June 22, 1992, Respondent was hired by Columbia Park Medical Center (“Columbia”) as a graduate nurse, while holding a practical nursing license. 6. Respondent was licensed as a practical nurse on or about June 8, 1992. 7. On or about December 4, 1992, Respondent presented to her employer a copy of a congratulatory notice from the Board of Nursing for successful passage of the nursing license exam. Respondent signed the bottom of this notice as a registered nurse. 8. On or about December 4, 1992, Respondent was promoted to registered nurse at Columbia. 9. Respondent worked from December 4, 1992, to October 1, 1996, as a registered nurse at Columbia. 10. Onor about July 7, 1993, through July 8, 1993, Respondent participated in the registered nursing licensure examination and subsequently failed. 11. Onor about September 13, 1994, Respondent participated in the registered nursing licensure examination and subsequently failed. 12. Onor about October 1, 1996, Respondents employment at Columbia was terminated after failing to provide Columbia with a copy of the 1996 renewal of her alleged registered nursing license. 13. On or about August 11, 1997, Respondent became licensed to work as a Registered Nurse in the State of Florida. COUNT I oe WY 14. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs one (1) through thirteen (13) as if fully stated herein. 15. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida is subject to discipline pursuant to. Section 464.016(1)(a), Florida Statutes, by practicing advanced or specialized, professional or practical nursing, without holding an active license to do so. COUNT II 16. Petitioner realleges and incorporates by reference the allegations of fact contained in paragraphs one (1) through thirteen (13) as fully stated herein. 17. Based on the foregoing, Respondent 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, specifically, by violating Rule 64B9- 8.005(1)(e)15, Florida Administrative Code, by practicing beyond the scope of the licensee’s license, educational preparation or nursing experience. COUNT Jil 18; . Petitioner realleges and incorporates by reference the allegations of fact contained in paragraphs one (1) through thirteen (13) as if fully stated herein. 19. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(2)(a), Florida Statutes, for using the name or title “Registered Nurse” or any other name or title which implies that a person was licensed or certified as same, unless such person is duly licensed or certified. A. WY 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, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. SIGNED this day rad, wf , 1998. Douglas M. Cook Director By: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: Reginald D. Dixon D Staff Attorney D . Florida Bar Number 0112925 EP ABIMENT OF HEALTH Agency for Health Care Administration CLERK CLERK General Counsel’s Office - MQA Allied Health CATE didal7g P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9637 RDD;jeb . . PCP: f6| BA pom: 3/23/5¢

Docket for Case No: 00-002933PL