WW ‘ Q - oO STATE OF FLORIDA . os. DEPARTMENT OF HEALTH So! ie DEPARTMENT OF HEALTH ° 1 7, ms] ~ Petitioner, 9 o o vs. Case No. ENUMBER “ TONI MARIE STARLING, 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, TONI MARIE STARLING, 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 be: 1765002. en issued license number RN 4. Respondent's last known address is 4011 Kibler Lane, Holiday, Florida 34691 WG Nw) 5. At all times material hereto, Respondent. was employed by Columbia, Largo Medical Center. 6. On or about December 31, 1997, Respondent was assigned to provide nursing care to patient C.C. 7. . Patient C.C. had a physician's order for Demerol 50-100 mg. to be administered every two (2) to four (4) hours as needed. 8. On or about December 31, 1997, Respondent documented administering 250 mg. of Demerol to Patient C.C. over a three (3) hour period. 9. If the “Respondent administered the Demerol to Patient C.C." as documented, the Respondent administered the medication in a manner that was inconsistent with the physician's order for Patient C.C. . 10. ‘If the Respondent did not administer the Demerol to Patient C.C. as documented, the Respondent failed to document the wastage of the unused Demerol. Count I 11. Petitioner realleges and incorporates the allegations of fact contained in paragraphs one through ten as if fully stated herein. 12. Respondent was not qualified by licensure, education or experience, to made the determination to administer more medication to the patient than the amount required by the physician's order for the patient. 13. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by violating Rule 64B9-8.005(15), F.A.C., by practicing beyond the scope of the licensee's license, education preparation or nursing experience. Ca YU Count II 14. Petitioner realleges and incorporates the allegations of fact contained in _ paragraphs one through ten as if fully stated herein. , 15. _ Respondent's documentation was inaccurate and/or false. 16., Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by violating Rule 64B9-8.005(1), F.A.C., by inaccurate recording, altering and/or falsifying 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. Robert G. Brooks, M.D. = Ss , Department of Health &2"°° . ecretary, Dep: e! le Oo: > 2 oF 5 » & cS Nancy Snurkowski, Ghfef Attomey _ On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: DEPART! ILED Reginald D. Dixon, Senior Attorney : EPI HEALTH FBN: 0112935 CLERK Agency for Health Care Administration : Allied Health Section pare__G._/ Post Office Box 14229 . Tallahassee, Florida 32317-4229 (850) 414 - 8576 : ~ RDD/rd pcp: Co «4 DOM: 2fhi la god a S S&S oS Signed tid Waay ot_Mhane 58 RSS eo ., 2 re N leony

Docket for Case No: 00-003062PL