STATE OF FLORIDA , ze DEPARTMENT OF HEALTH es 3 " DEPARTMENTOF HEALTH 0 : ae B Petitioner, a. S vs. Case No. 2000-00152 GUY ROSS, 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, GUY ROSS, 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 3148522. 4. Respondent's last known address 3091 NW 46th Avenue apt. 201, Lauderdale Lakes, Florida 33313. G-39-0O © wh s et ene “annz 6 b Ne 5. On or about November 1999, Respondent's use of controlled substances and/or alcohol affected the Respondent's ability to practice nursing with reasonable skill and safety to patients, to wit: On or about November 6 & 7, 1999, Respondent was unable to work scheduled nursing shifts at Ft. Lauderdale Hospital due to his relapse | on controlled substances and/or alcohol. 6. On or about November 8, 1999, Respondent reported to Ft. Lauderdale Hospital; Respondent was not scheduled to work on this date. Respondent was observed to be exhibiting characteristics of being under the influence of drugs, alcohol or narcotics and was subsequently transported to Highpoint, a drug and alcohol treatment center. - 7. Respondent was referred to the Intervention Project for Nurses, a referral and monitoring program for impaired nurses. J 8. Respondent failed to follow through with treatment and/or monitoring through IPN. 9. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(), Florida Statutes, by being unable to practice nursing with reasonable skill and safety to patients due to the use of alcohol, drugs, narcotics or any other substance or as a result of a mental or physical condition. 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 this Lay of. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for : Health Care Administration DEPARTMENT OF HEALT+ DEPUTY CLERK . CLER thi Agency for Health Care Administration K Ueki eton Allied Health Section DATE Zl J- Revo Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 . RDD/td — PCP:tatang. DOM: Sk y/d 00 U

Docket for Case No: 00-003894PL