fa) a STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH Petitioner, v8. Case No. 1999-62163 KATHIE ROSENBERG, Ol- UG re Respondent. ; ADMI NISTRATIVE 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, KATHIE ROSENBERG, 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)(9), 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 oe ~~ number RN 2226372 sehen veer Lr gi 4, Respondent's last known address ‘is 1636 140th Street North, Seminole, Florida 33776. 5. On or about January 29, 1998, at approximately 7: 00 a.m., "Respondent assumed care for patient P.D. 6. Patient P.D. was a three-year old male with a history t that classified _ him as high risk for respiratory arrest. 7. Onor about January 29, 1998, between approximately v: 00 a.m. ‘and 8:30 a. m., Respondent was responsible for the monitoring and care of patient P. D. 8. On or about January 29, 1998, at approximately 8:30 a.m., patient P.D. was found pulseless and without respirations; CPR was initiated, 914 was . calle, but patient P.D. expired, 9. On or about January 29, 1998, between approximately 7:00 a.m. and 8:30 a.m., Respondent either: did not perform or did not document performing a physical assessment or examination of pationt P.D. 10. On or about January 29, 1998, between approximately 7:00 a. m. and 8:30 a. m., Respondent did not place a pulse oxymeter on patient P.D. See 11. On or about January 29, 1998, patient P.D.'s medical condition was such’ that the minimal acceptable standards of prevailing nursing practice ; required tha that a physical assessment and a physical examination be done upon assuming care for Patient P. D. a vot ; Pa aoe . On or ‘about ut January 2¢ 29, 1 998, patent P. D.'s medical condition was ee required that a pulse oxymeter be t used to monitor patient P.D.'s > condition. 13. On or about January 29, 1998, Respondent's care and montring of patient P.D. fell below the minimal =I acceptable standards of prevailing nursing, ie Sane 2, EES Sse coRE ae ARSE SS com 2 ___Pract 14. Based on. the foregoing, Respondent is subject to. disciping pursuant to section 464.01 8(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 i 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 Bd day of gut , 200. ; ; DEP, Robert G. Brooks, M.D. DEN QrHEALTH: . Secretary, Department of Health CLERK Yahi Keren DATE 1E2 BY: Nancy Snurkows Ki, Chief Attomey oo On Behalf of the Agency for Health Care Administration — oe COUNSEL FOR THE PETITIONER: ‘Reginald D. Dixon, Senior Attorney FBN: 0112925 ’ Agency for Health Care Administration _ Allied Health Secti ‘DOM: erretncpekt cern antebtiistr anata ee

Docket for Case No: 01-001846PL