S ‘ So : 4a 7H STATE OF FLORIDA “O eumn DEPARTMENT OF HEALTH Bt - —~y oft : ~ & DEPARTMENT OF HEALTH, ce : WwW . lon] PETITIONER, -O0-40U iPl- vs. CASE NUMBER: 98-19795 LISA LOUISE SPURLOCK 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 LISA LOUISE SPURLOCK, 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. Pursuant to the authority of Section 20.43 By, 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 REGISTERED Nurse in the state of Florida, having been issued license number RN 3114732. Respondent's last known address is 3911 India Cove, Gulf Breeze FL 32561. 3. At all times material hereto, Respondent was employed by Pensacola Health Care (PHC). 4. On or about August 11, 1998, through August 13, 1998, AHCA officials conducted a survey of PHC records. . 5. The survey revealed that Respondent documented administering medications to patients on the Controlled Drug Records but did not document administering medications on the Medication Administration Records. . 6. On or about August 12, 1998, Respondent admitted to the Director of Nursing at PHC that she was taking Percocet and Lortab because she had been ill. 7. Respondent subsequently provided prescriptions for the aforementioned medications and a letter from her physician stating that she would have to take a medical leave of absence due to recurring pancreatitis and injuries sustained from an accident. 8. Pursuant to chapter 893, Florida Statutes, Percocet and Lortab are schedule II controlled substances that have a high potential for abuse and may lead to severe psychological or physical dependence. Count I 9. Petitioner realleges and incorporates by reference the foregoing allegations of fact contained in the foregoing paragraphs as if fully stated herein. 10. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, unprofessional conduct as defined by Rule 64B9-8.005(1)(e)1., Florida Administrative Code, by inaccurate recording, falsifying or altering of patient records or nursing progress records, employment records or time records. ) Count II 11. Petitioner realleges and incorporates by reference the foregoing allegations of fact contained in the foregoing paragraphs as if fully stated herein. 12. Respondent’s illness and injuries, and subsequent use of controlled substances to. ~ combat said illness, affect her ability to practice nursing with reasonable skill and safety to patients. ) 13. Based on the foregoing, Respondent is subject to discipline pursuant to Section 464.018(1)@), Florida Statutes, for being unable to practice nursing with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. 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 this | Abiey of (Nr __, 1998 Robert G. Brooks, M.D. - Secretary, Department of Health la 7 Snurkowski Chief Attommey Agency for Health Care Administration FILED DEPARTMENT OF HEALTH COUNSEL FOR PETITIONER; ~ Chris Steinhaus, Attorney Florida Bar Number - 01479 Agency for Health Care Administration Allied Health P.O. Box 14229 Tallahassee, FL 32317-4229 (850) 414-8576 : CJS/ejs pep: PR|RO DATE: 2igla%

Docket for Case No: 00-004041PL