STATE OF FLORIDA DEPARTMENT OF HEALTH © 2 DEPARTMENT OF HEALTH Petitioner, vs. Case No. 1999- OD -ONDPL LAURA DROSOS-CUBAS, 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, LAURA DROSOS-CUBAS, 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 3006002. 4s Respondent's last known address 2464 N.E. 12th Avenue, Margate, Florida 33064. 5. On or between March and August 1999, Respondent practiced below the minimal acceptable standards of prevailing nursing practice by failing to properly document the administration and/or wastage of medications, including controlled substances, to patients under her care, to wit: On multiple occasions Respondent removed controlled substances from the Pyxsis narcotic dispensing machine for patients, but failed to subsequently document administering the controlled substances or alternatively wasting the controlled substances. 6. Based on the foregoing, 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. 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 licerise, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Boarcl deems appropriate. -) Signed thisd1A day of ( Lu guot- : , 2000_ . Robert G, Brooks, M.D. Secretary, Department of Health iy On Behalf of the Agency for Health Care Administration ] COUNSEL FOR THE PETITIONER: Reginald D. Dixon, Senior Attomey DEPARTMENT OF HEALTH FBN: 01129 DEPUTY CLERK n Agency for Héalth Care Administration CLERK Vchi R. Kenm Allied Health Section 2900 Post Office Box 14229 DATE. Tallahassee, Florida 32317-4229 (850) 414 - 8576 , RDDird = PCP:évé DOM:?/t4/;0 © |

Docket for Case No: 01-000118PL