STATE OF FLORIDA bing DEPARTMENT OF HEALTH =F NE D 00. ,SEP-27 PH 3: 24 DEPARTMENT OF HEALTH, bly DIV SOM Or Petitioner, ADMINIST R OVE, HEARINGS vs. CASE NO. 96-16503 2a. LINDA DUDLI, ” OO M 02 Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against LINDA A. DUDLI, 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 practical nurse, having been issued license number PN 0954851. 4. Respondent’s last known address is 221 N.E. 17" Avenue, Cape: Coral, Florida 33909, 5. At all times material hereto, Respondent was employed by Metro Home Care, Inc.. . 6. On or September 30, 1996 by working as a home health nurse, Respondent falsified nurses notes on a patient under her care. 7. Tt was called to Respondent's attention that on September 30, 1996, there was a missing nurses note for 1 patient who was under her care. 8. Upon notification of the missing nursing note Respondent fabricated a missing nursing note for the date of care which was September 25, 1996. Subsequently, it was determined that another nurse had seen the patient on September 25, 1996 and that the other nurse had the valid nursing note. COUNT I 10. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. 11. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florid is subject to discipline pursuant to Section 464.018(1Xh), 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)(1), Florida Administrative Code, by inacurate recording, altering or falsifying patient records. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an Order imposing one or more of the following penalties: suspension of license, imposition yam of an administrative fine not to exceed $1,000 for each offense, issuance of a reprimand, placement of the Respondent on probation, and/or any other relief that the Board deems we dal appropriate. 1998. SIGNED this’ | day of _\, “ N ouglas M. Cook Director ; 4 _—T a oy / ‘ = SR Sa aT ee By: Nancy M. Snurkowski Chief Attorney . On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: Reginald ixon , FI LE D DEPARTMENT OF HEA Staff Attor DEPUTY CLERK Florida B. . 0112925 CLERK AC: Agency for'Health Care Administration General Counsel’s Office - MQA DATE UU Allied Health : P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9697 RDD/SB/mt 03/03/98 . PCP: ee | bu G-(9~ 48

Docket for Case No: 00-004022PL