STATE OF FLORIDA res DEPARTMENT OF HEALTH rqLe D & _ Ry DEPARTMENT OF HEALTH O1 MAR 12. Py ia: 5) S , S,. Petitioner, OV iSijy ae . ADMIN & aive vs. Case No. JeAOING MARY ELLEN WILSON, 0 Oa5tl 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, MARY ELLEN WILSON, 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. 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 2910742. 3. . Respondent's last known address is 2332 Wexford Lane, Birmingham, ” Alabama 35216, a “4, Qn or about February 14, 1996 and February 21, 1996, Respondent was employed by Columbia West Florida Regional Medical Center (Columbia) in Pensacola, Florida. 5. . On or about February 14, 1996 and February 15, 1996, Respondent was assigned to patient #295367. 6. On or about February 14, 1996 and February 15, 1996, patient #295367 had a physician's order for Solu Medral 60 mg, to be administered three times at eight hour intervals. 7. On or about February 14, 1996 and February 15, 1996, Respondent administered Solu Medral 60 mg to patient #295367 at 8:00 p.m., 4:00 a.m. and 6:00 a.m. 8. On or about February 14, 1996 and February 15, 1996, Respondent was assigned to patient #295361, 6. On or about February 14, 1996 and February 15, 1996, patient #295361 had a physician's order for the patient's Heparin drip to be weaned over a twelve hour period. 7. On or about February 14, 1996 and February 15, 1996, Respondent increased the Heparin drip and gave a bolus of 5,000 to patient #295361, Count I 8. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs one (1) through seven (7) as if fully stated herein, 9. Based on the foregoing, Respondent is subject to discipline pursuant to section 464, 018(1)(h), Florida Statutes, unprofessional conduct by violating Rule 64B9- “8. 005(1)(e)2.., F.A.C., by administering medications or treatments in a negligent manner, ~ 7 Count I 10. Petitioner realleges and incorporates by reference the allegations of fact contained in the foregoing paragraphs one (1) through seven (7) as if fully stated herein. 11, Based on the foregoing, Respondent is subject to discipline pursuant to -Section 464.018(1)(h), Florida Statutes, unprofessional conduct by violating Rule 64B9- 8.005(1)fe)12., F.A.C., by acts of negligence, gross negligence, either by omission or commission. | “WHEREF ORE, 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 probatién, costs, and/or any other relief that the Board deems appropriate. Signed thie Viray of Yor UpA , 199. Douglas M. Cook | Director . | f Nancy oe Attomey | On Behalf of the Agency for Health Care Administration | COUNSEL F PETITIONER: F | LE D Reginald D. Dixon, Staff Attorney DEPARTMENT OF HEALTH FBN: 011292 DEPUTY CLERK | | Agency for Health Care Administration CLERK on buen . | Post Office Box 14229, coe oe. : “Tallahassee, Florida 32317-4229 . . ce (850) 487-9637 - = . RDDitd PCP: _LB/LM _ DOM: 1121/97 « H: \BOARDIACSINURSING\ac96.04036.d doc

Docket for Case No: 01-000995PL