U Oo U \‘& yee ae of STATE OF FLORIDA PILED DEPARTMENT OF HEALTH 00 SEP 26 ANIO:43 DEPARTMENT OF HEALTH OF Petitioner, ) vs. Case No. 1999-05029 DIANE KATHERINE TREVENA, 66-37% L 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, DIANE KATHERINE TREVENA, 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 ADVANCED REGISTERED NURSE PRACTITIONER in the State of Florida, having been issued license number RN 2502892. WU Nw failing to conform to the minimal acceptable standards of prevailing nursing practice. Count Il 12. Petitioner realleges and incorporates by reference the allegations of fact contained in paragraphs one (1) through eleven (11) as if fully stated herein. 13. Pursuant to Rule 64B9-4.010, Florida Administrative Code, advanced registered nurse practitioners must practice under a protocol with a supervising physician or dentist and must maintain a copy of that protocol on file with the Board of Nursing and at each site where the advanced registered nurse practitioner practices. 14. On or about February 25, 1999, Respondent did not have a protocol on file with the Board of Nursing. , 15. On or about February 25, 1999, Respondent did not have a protocol on file with North Broward Medical Center. 16. On or about February 25, 1999, Respondent did not have a protocol on file with Dr. Lehman's office. 17. On or about February 25, 1999, Respondent practiced as an advanced registered nurse practitioner, without a current protocol on file with the Board of Nursing and/or North Broward Medical Center and/or Dr. Lehman's 18. Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. WU UY 4. Respondent's last known address is 1065 NW 50th Drive, \pano Beach, Florida 33064. Count | 5. - On or about February 25, 1999, Patient S.W. was hospitalized at h Broward Medical Center. 6. On or about February 25, 1999, Respondent was responsible for iding nursing care to Patient S.W. 7. On or about February 25, 1999, Respondent increased the amount edication, specifically Dilaudid and Marcaine, that was being administered to ant S.W. via CAD pump, to deliver a level/amount greater than that /amount ordered by the Patient $.W.'s treating physician, Dr. Lehman. 8. Dilaudid and Marcaine are controlled substances under chapter. Florida Statutes. 9. Respondent did not consult with the Patient S.W’'s treating ician prior to altering the amount of medication that was administered to nt S.W. 10. As an advanced registered nurse practitioner, Respondent is not ‘ied by licensure, educational preparation or nursing experience to iistered controlled substances to patients beyond that amount ordered by atient’s treating physician. 11.. Based on the foregoing, Respondent is subject to discipline lant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by

Docket for Case No: 00-003992PL