Ww Ad STATE OF FLORIDA 04 DEPARTMENT OF HEALTH 4 of f. DEPARTMENT OF HEALTH, HE PETITIONER, 5Y vs. CASE NUMBER: 96-15889 SANDRA JOHNSON 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 SANDRA JOHNSON, 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 0832871. Respondent's last known address is 4016 Penelope Rd., #127, Tallahassee, FL-32310. 3. At all times material hereto, Respondent was employed by Tallahassee Memorial Hospital (TMH). - i 7 ; U | WB 4. In or about September of 1996, three nurses at TMH, BJA, SB, and SF, witnessed Respondent document infants’ vital signs without having conducted the appropriate tests to determine these signs. 5. Each of the aforementioned nurses stated that they discovered the aforementioned falsification of documentation after reviewing the charts Respondent was responsible for. 6. Each of the aforementioned nurses stated that when they entered the nursery, they noticed in the charts that Respondent had yet to document the infants’ vital signs. Each of the aforementioned nurses then witnessed Respondent document the infants’ vital signs without having conducted the appropriate tests to determine these signs. 7. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.918(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(1), Florida Administrative Code, by inaccurate recording, falsifying or altering of patient records or nurs:ng progress records, employment records or time records. U ) ow) . WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an order imposing one or more of the following penalties: revocation or suspension of the Respondent’s 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 tis GCL day of Cirged , 1999. ‘Dr. Robert G. Brooks, M,D., Secretary - Department Af Health Nancy M. Snurkow. Chief Attorney Agency for Health Care Administration COUNSEL FOR PETITIONER: Chris Steinhaus, Attorney Florida Bar Number - 0147966 Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 850) 4414-8576 CISicjs pee: LO/AL . : ~ 2 HEALTH DATE: W24ly DEPARTS CLERK ERK cut (3° a DATE | t i

Docket for Case No: 00-003154PL