STATE OF FLORIDA ar) DEPARTMENT OF HEALTH 97 yee 10 DEPARTMENT OF HEALTH Aotije,. hy MSW on 82 Petitioner, CAB Rg oe NGS /, ve vs. . Case No. 1999-01959 GEORGINA SERRA, A.R.N.P., O | - aweciea 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, GEORGINA SERRA, A.R.N.P., and ins 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 oy the Division of Medical Quality Assurance, councils or boards, as appropriate, - including the i iss ince of. emergency orders of suspension or restriction. . 3. ‘Respondent is and has been at all times material hereto, a licensed _ ADVANCED REGISTERED NURSE PRACTITIONER NURSE in the State of Florida, having been issued license number RN 89721-2. 4. Respondent's last known address is Rainbow Drive, Hollywood, . Florida 33021. © 5. On or about January 9, 1999, Patient G.P., who had a history of hypertension and s/p resection of melanoma presented to Jackson Memorial Hospital (JMH) with complaints of pain and instability. Patient G.P. was evaluated in the emergency room an admitted to JMH for neurologic evaluation. 6. On or about January 9, 1999, Respondent accessed Patient G.P.' s medical chart, and based on her licensure, education and training, entered orders for the medical/nursing treatment of Patient G.P. 7. The orders entered by Respondent on Patient G.P.'s medical chart were counter to orders given by the physician that evaluated Patient G.P. ‘earlier 4 that day. — 8. The orders entered by Respondent, if followed, could have caused harm to Patient G.P. 9. On or about January 9, 1999, the Respondent was not an employee of JMH or credentialed at JMH to work as a nurse practitioner, and therefore should not have been accessing or making changes to Patient GP.s oe medical charts. utes. ‘conduct that falls below the ‘minimal acceptabie standards of prevailing nursing practice. 1 the forego 9, Respondent i bject to. “discipline pursuant to section 464. 018(1)(h), Florida Statutes, by unprofessional conduct by _ ..,. Allied Health Section ~_. Post Office BoX.14229 pate_lo | 8/et _ ~~ Tallahassee, Florida : 32317-4229 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 thid OU ray of Alas h. ,2001. 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: Reginald D. Dixon, Senior Attoney FBN: 0112925 Agency for Health Care Administration Allied Health Section Post Office Box 14299 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDDid PCP: DOM: MGA My / seep ee mse geen mpm pipe

Docket for Case No: 01-002709PL