- . STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH ~ Petitioner, vs. Case No. 2001-08975 YADIRA PENA, L.P.N., 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, YADIRA PENA, L.P.N., and in support thereof alleges: : 1. Petitioner is the state agency charged with regulating the practice mm ~~ of nursing pursuant to Chapters 20, 456, and 464, Florida Statutes. = 2. Pursuant to the authority of Section 20.43(3)(g), Fiorida 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 1312211. we rege ETE nee 4.._ Respondent's last known address is 808 SE Fifth Avenue, Cape Coral, Florida 33990. . ! 5. On or about July 9, 2001, while employed by Rehabilitation and Health Care Center of Cape Coral, Respondent practiced below the minimal acceptable standards of prevailing nursing practice, to wit: Respondent pre-documented the administration of nursing care, including but not limited to, the administration of medications and nutritional _ supplements, for multiple patients under her care, when in fact she had not provided the nursing care at the time Respondent actually made the entries in the records. 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. 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. corse Reginald D FBN: 011 Agency fo: Allied Heal Post Office Box 14229 Tallahassee, Florida 32317-4229 (850) 414 - 8576 RDD/rd PCP: DOM: _ Cov dy ps J o/ 4 aoe 2) Signed this Ad Bay of Naw Ex 200 . a | John O. Agwunobi, MD, MBA Acting Secretary, Department of Health BY: Section Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONER: ixon, Senior Attorney iLED ealth Care Administration veneer

Docket for Case No: 01-004937PL