STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH : Petitioner, vs. . Case No. 2000-14058 KAREN TIMMS, L.P.N., Ol-3i!Z PL 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, KAREN TIMMS, 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 issuance of emergency orders of suspension or restriction. 3. Respondent is and has been at all times material hereto, a licensed PRACTICAL NURSE in the State of Florida, having been issued license number PN 1194951. 4. Respondent's last known address is RR 5, Box 5841, Monticello, Florida 32344, . 5. - On or about 10/03/2000, while employed by the Capital Health Care Center, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: ) a. On 10/03/2000, the Respondent was the charge nurse assigned to C.W. CW. had orders to be turned every two (2) hours. At approximately ) 1:30p.m. on said date, C.W. was left, by family members, to be lying on her left side. . b. At approximately, 5:00 p.m. on said date, Dr. Thacker made rounds and noted that C.W. was lying on her left side. c. At approximately 10:30 p.m. on said date, the family members returned to C.W.’s room. At that time, C.W. was found to be lying on her left side with her face compressed into her chest and wet with perspiration and drool. It was also noted that C.W. was lying in excrement which had dried to her skin and bed. These two incidents amount to a diagnosis of left sided aspiration pneumonia and severe rash and sores, respectively. d. Although medication is noted as being given to C.W. on said date, it appears from the nursing notes that the last notation was at 11:46 a.m. and therefore, this administration or any subsequent action was not noted. 6. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by a : . par practice. S WHEREFORE, Petitioner respectfully request that the Boards Nursig enter an Order imposing one or more of the following penalties: Refgtsiong 3 Pom a suspension of Respondent's license, imposition of an administrative fi i issuance of a reprimand, placement of the Respondent on probation, costs, and/or any other relief that the Board deems appropriate. signed thi Quay of ath uf 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: DEP. Michael J. Kapperman, Senior Money ARTMENT or HEALTH FBN 879721 be “Agency for Health Care Administratio CLERK iki -_" . Allied Health Section ” DATE 2A le Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 MJK/mk ROre DY : POM Lye a/

Docket for Case No: 01-003112PL