tS Son ssn SSRN ee Received Event (Event Succeeded) Date: 3/20/02 Time: 12:50 PM Pages: 12 Sender: 850 488 1855 Remote,GS!B4-2850 488 4855 AHCA ALLIED HEALTH . 858 488 1855 P9812 STATE OF FLORIDA DEPARTMENT OF HEALTH . = weds, = DEPARTMENT OF HEALTH, = Petitioner, 02-1\2 | Py- mo vs. _ CASE NO. 96-10230 LAURA L. HENDRICKS CROSBY, . Respondent. / ADMINISTRATIVE COMPLAINT Petitioner, DEPARTMENT OF HEALTH, hereinafter referred to as “Petitioner,” files this Administrative Complaint before the Board of Nursing against LAURA L. HENDRICKS CROSBY, hereinafter referred to as “Respondent,” and alleges: 1. Effective July 1, 1997, Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes (Supp. 1996); Chapter 455, Florida Statutes; and Chapter 464, Florida Statutes, 2, Pursuant to the authority of Section 20.43(3)(f), Florida Statutes (Supp. 1996), 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 registered nurse, having been issued license number RN 1701342. 4. Respondent’s last known address is 1412 Henry Balch Drive, ‘Orlando, Florida 32810-4511. > =. SS ess assassins ssn Received Event (Event Succeeded) Date: 3/20/02 Time: 12:50 PM Pages: 12 Sender: 850 488 1855 Remote St): 29850 488-4855 AHCA ALLIED HEALTH 858 488 1655 P.99/12 5. At all times material hereto, Respondent was employed by Memorial Hospital West Volusia in Deland, Florida. . 6. From on or about January 1996 through March 1996, numerous incidences involving the Respondent's administration, monitoring, recording of patient medication included but are not limited to the following: . a. On or about January 13, 1996, Respondent failed to have wastage of Demerol 25 mg signed by another nurse. Demerol is a schedule controlled substance pursuant to Chapter 893, Florida Statutes. b. On or about February 24, 1996, the Respondent administered a Seconal without a doctor’s order and failed to have a wastage of Seconal co-signed by another nurse. Seconal is a schedule controlled substances pursuant to Chapter 893, Florida Statutes, ¢. In February 28, 1996, Respondent failed properly label an LV bag. d. On or about March 9, 1996, Respondent failed to monitor a patient after placement of an epidural anesthesia as Tequired by hospital policy. €. On or about March 22, 1996, Respondent failed to accurately record dosage of Narcan on medication administration Tecords (MAR) £ On or about March 23, 1996, Respondent failed to sign out 30 mg of Dalmane and failed to notify doctor of patient status change. Dalmane is a schedule controlled substance pursuant to Chapter 893, Florida Statutes. a a 2 ee nse SNS comes Received Event (Event Succeeded) Date: 3/20/02 Time: 12:50 PM Pages: 12 Sender: 850 488 1855 Remote SH): 29850 488-4855 AHCA ALLIED HEALTH 858 488 1855 P.19/12 g. On or about March 23, 1996, Respondent failed to witness a patient taking two (2) Percocet tablets that were subsequently found lying on the bed side table and failed to document them in the medication administration record (MAR). Percocet - is -a schedule controlled substance pursuant to Chapter 893, Florida Statutes. ; 7. Respondent was subsequently suspended from work and referred to the Intervention Project for Nurses (IPN). The IPN is a program for monitoring, treating and rehabilitation of nurses who are impaired from drugs, alcohol or any mental or physical condition. 8. Respondent has failed to follow through with the IPN program, COUNTI EB Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. 10. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida is subject to discipline pursuant to Section 464.018(1)(h), Florida Statutes, by unprofessional conduct, including, but not limited to, any departure from, or the failure to conform to, the minimal standards of acceptable and prevailing nursing : practice. COUNT D 11. Petitioner realleges and incorporate by reference the allegations contained in the foregoing paragraphs as if fully stated herein. nee 10 >= SSS sess NSS ness Received Event (Event Succeeded) Date: 3/20/02 Time: 12:50 PM Pages: 12 Sender: 850 488 1855 _ Remote aS): 2850 489-4855 AHCA ALLIED HEALTH 858 488 1855 P1112 12, Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida is subject to discipline pursuant to Section 464. O18(1)(h), by violating Rule 59S-005(1)(e)(1), Florida Administrative Code, inaccurate, false records, COUNT 13. Petitioner realleges and incorporates by reference the allegations contained in the foregoing paragraphs as if fully stated herein. : 14. Based on the foregoing, the Respondent’s license to practice nursing in the State of Florida is subject to discipline pursuant to Section 464.018( 1G), Florida Statutes, by engaging or attempting to engage in the possession, sale, or distribution of controlled substances as set forth in chapter 893, for any other than legitimate purposes. WHEREFORE, Petitioner respectfully requests the Board of Nursing enter an Order imposing one or more of the following penalties: suspension of license, imposition of an administrative fine not to exceed $1,000 for each offense, issuance of a reprimand, wore 11 —_— ee eee SSNS Sb eam Received Event (Event Succeeded) Date: 3/20/02 Time: 12:50 PM Pages: 12 Sender: 850 488 1855 _ Remote @S19: 29850 488-4855 AHCA ALLIED HEALTH 858 488 1855 P.12/12 placement of the Respondent on probation, and/or any other relief that the Board deems appropriate. , SIGNED thigzjid_ day of __\yCu 1998, Douglas M. Cook Director By: Nancy M. Snurkowski Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR AGENCY: Reginald D/ Dixon F | LE D Staff Atto DEPARTMENT OF HEALTH Florida Bar Number 0112925 DEPUTY CLERK Agency for Health Care Administration CLERK Lipa: NM. Gam General Counsel’s Office - MQA Allied Health DATE UB P.O. Box 14229 Tallahassee, FL 32317 - 4229 (850) 487-9697 RDD/SB/mt 03/03/98 PCP: A2/Bu) 6/5/98 3 TOTAL P.12 12

Docket for Case No: 02-001121PL