STATE OF FLORIDA FILED DEPARTMENT OF HEALTH oe DEPARTMENT OF HEALTH ! O1 BEC -S ANTI: 56 Petitioner, VS. FRANCIS ROSCETTI : CY- 4633 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, Francis Roscetti, 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 5147338. rer mre 4. AZ 85043. 5. 7, ce Respondent's last known address is 6302 W. McKinley, Phoenix, j On or about November 2000, while employed by Sunbelt Staffing Solutions, Inc. and assigned to Largo Medical Center, Respondent. practiced below the minimal acceptable standards of prevailing nursing practice, by inaccurately recording, altering or falsifying patient records, to wit: 6. Respondent removed Demerol for patients under her care, but the patients did not have physician's orders for Demerol or the amount of Demerol she removed to be administered. _ 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. 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 tric oay of ( bu lod , 200 . ’ Robert G. Brooks, M.D. Secretary, Department of Health BY: Nancy Snurkowski, Chief Attorney cpeme ns oF * Sgerpree eno Aa a A a oe On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: Elizabeth A. Hathaway, Staff Attorney FBN: 0413143 , Agency for Health Care Administration Allied Health Section Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 EAH/eh PCP: DOM: K¢4 87 hy af i Ee A et ce

Docket for Case No: 01-004623PL