STATE OF FLORIDA o 7 O° DEPARTMENT OF HEALTH Gib, Seg Wt sO, DEPARTMENT OF HEALTH 1 “Aone On GY Mii y Petitioner, s o vs. Case No. 2001-04580 PATRICIA C. PEREZ, RN, ARNP, Ot USsy AL 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, PATRICIA C. PEREZ, RN, ARNP, 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 . ADVANCED REGISTERED NURSE PRACTITIONER in the State of Florida, having been issued license number RN 1188522. TO OMe wr men rege eee or oe TERR TR re rr rae 4. ‘Respondent's last known address is 9730 SE 23rd Place, Ft. Lauderdale, Florida 33324, . 5. On or about January 31, 2001, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: Respondent negligently prescribed Brontex, an expectorant containing Guaifinisen, to Patient D.R., with knowledge that Patient D.R. had a recent medical history, which included an adverse reaction, including but not limited to uncontrolled tremors, to Humibid, an expectorant containing Guaifinisen. 6. Based on the foregoing, Respondent is subject to discipline : pursuant to section 464.018(1)(h), Florida Statutes, by unprofessional conduct by failing to conform to the minimal acceptable standards of prevailing nursing practice. ec noe ce WHEREFORE, Petitioner respecifully request that the Board of Nursing a 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, E [ E i and/or any other relief that the Board deems appropriate. Signed this (day ot_OCHbey 200. John O. Agwunobi, MD, MBA Secretary, Department of Health BY: Nancy Snurkowski, Gay f Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Reginald D. Dixpn, Senior Attorney FBN: 0112925 Agency for Health Gare Administration F. | LE D Allied Health Section DEPARTMENT of HEALT! Post Office Box 14229 DEPUTY CLenK Tallahassee, Florida 32317-4229 CLERK Yih g. Letter (850) 414 - 8576 RDD/rd POP: DOM: DATE of (Z boy MPV AM Varfer RT Ee one preee n oe

Docket for Case No: 01-004555PL