STATE OF FLORIDA . DEPARTMENT, OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 99-0464] DEBORAH B. MCCOY, O! OSH PL 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, DEBORAH B. MCCOY, 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: PRACTICAL NURSE in the State of Florida, having been issued license number PN . 127104. ne . Ltn 4, Respondent's last known address is 13770. McGregor Blvd., Ft. Myers 4 5. At all times material hereto, Respondent was employed by Shell Point Retirement Community (hereinafter referred to as "Shell Point"). 6. While employed by Shell Point, Respondent practiced nursing below the minimal acceptable standards of prevailing nursing practice, to wit: a. Respondent failed to timely report or properly document ulcers/wounds/bedsores on patients under her care; b. Respondent withheld patient(s) medications in violation of the physician orders for the patient(s); and c. Respondent documented administering patient(s) medications when in fact she did not administer the medications. 7. 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 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| day of -~ 4. Robert G. Brooks, M.D. oe wee Secretary, Department of Health . FILED DEPARTMENT OF HEALTH ae . DEPUTY CLERK : CLERK Yebi RBion ° BY: Nancy Snurkowski, Cy ief Attorney. : - On Behalf of the Agency for. “Health Care Administration WP/EO /\ [ COUNSEL FOR THE PETITIONER: Reginald D. Bixon, Senior Attorney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 , RDD/rd PCP: ALN 477 A:\ac-mccoy, deborah.doc Do: ’2" ? - 7

Docket for Case No: 01-000254PL