STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, vs. Case No. 2000-11157 6-16 SFL DIANNE MCKEOWN, R.N. 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, DIANE MCKEOWN, R.N., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice . of nursing pursuant to Chapters 20, 456, 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 ij issuance of emergency orders of suspension or restriction. 3. , Respondent i is and has been at all times material hereto, a licensed PRACTICAL NURSE i in the State of Florida, having been issued license number 1187101. 4. Respondent's last known address is 309 Glenview Drive, Tallahassee, Florida, 32303. 5. On or about February 29, 2000, Respondent was alleged to have not properly notified the charge nurse of the change in condition of an elderly resident, who had reportedly suffered a fall and a head injury. While employed at Tandem Health Care, located at 1650 Phillips Road, in Tallahassee, Florida, as a licensed Registered Nurse, Respondent was alleged to have failed to adequately assess the condition of a Resident, Lw., and failed to notify the charge nurse of a change in the condition of the Resident, who had suffered a fall in the bathroom which resulted in a head injury. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct, which shall include, but not be limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing practice, in which case actual injury need not be established. 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 Ut }eay of VY wh , 200 |. Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Fi LED 4 Michael E. Duclos, Senior Attorney DEPARTMENT OF HEALTE a Florida Bar Number: 0274046 DEPUTY CLERK Agency for Health Care Administration abi Rn Esa) Practitioner Regulation CLERK Nehi R. Post Office Box 14229 pate 2/410 Tallahassee, Florida 32317-4229 (850) 410-0622 MED/med pcp: ©¢% 7 pom: */24/2 /

Docket for Case No: 01-001648PL