TATE OF FLORIDA ART! AENT OF HEALTH hn a I ITN NA. ay Wasco SESE RESINS Be BESS = VS. i 4. * Respondent. a / ADMINISTRATIVE COMPLAINT COMES Now, Petitioner, DEPARTMENT OF | HEALTH, by and through its : “undersigned counsel and fi les this administrative complaint before the Board of : Nursing against the Respondent, Michelle Steacham, ‘andi in suppor thereof alleges: ency charged with regulating the practice of : nursing pursuant t0 Chapters 20, 456, "and 464, Florida Statutes. ~~ 2 - Pursuant to the autho of Section 20. 43(3)(9), Florida Statutes, the Petitioner ‘has contracted with the Agency for Health Care Administration to provide consumer r complaint “investigative and ‘Prosecutor services required by the At all times material to the Complaint, Respondent was working i ina : nursing ‘capacity at supiter Medical Center Pavilion. 6. “On| or about September 40, 2000, Respondent ‘obtained Capillary Blood Glucose readings from patients PM and EM. via | Use of a device commonly referred to as an Accucheck. On or ‘about September 1 0, 2000, Respondent reported ‘the results of the Accue ecl cadre the oncoming nurse. ber 10 2000, Respc t was assigned to patient RD, who was being feed through a gastic tube. On or abou Sept 10, 2000, Respondent reported the results of her treatment tc to ‘the oncoming nurse. COUNT 1 sree 1 9 as if set forth below. ‘oncoming nurse did not match the readings she had documented in PM's S Medication oo Administration Record, . il a RR Re lk Ml el lt i i a al ll iia Hel rl i 13. Petitioner realleges Faregraphs 1- 12 as if set forth below. dng medica ions or treatments ina a negligent __ Manner, and failing to ‘conform to the minimal standards of f acceptable ° prevailing “‘Bememeer erry ere: eormer er: 97 caperereerernpenernpeneer PUTeNTEINTreennr s memesrernerenisrrertnmeremerne erreur rere , Rules 6489. 8.005(1 no manner, and fai to the ‘minimal standards acceptable prevang " sustained, respectively. il il i i ii. iii, a A Nn i a lk a il . WHEREFORE, Petitioner rspectuly requests that the Board of Nursing enter an “Orde Robert G. Brooks, M. D. cI retary, Department of Health Nancy Snurkowski, Chief Attorney ARTMENT OF HEALTH (DEPUTY CLERK Cenk chi Re fever owe [2 Mes an 410: at NoVA e Yaiface ae , Florida Statutes, by ¢ engaging in Unprofessional : (2) and (13), Florida a - “nursing ‘practice, regardless of ‘whether or not actual injury to a patient was

Docket for Case No: 01-002469PL