Apr 5 2005 10:34 APR-S-2085 18:37 AHCA/LEGAL MEDICAL 856 414 1989 P.@6718 f STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Patitlonor, vs. Case No. 2001-15358 EILEEN JOAN JERNIGAN, L.P.N., Respondent. i ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, DCPARTMENT Of HEALTH, by and through its undersigned counsel and files this Administrative Complaint betore the Board of Nursing against the Respondent, EILEEN JOAN JERNIGAN, L.P.N. and in support thereof alleges: 1. Petitioner ig 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. Raspondent is and hac been at all times material hercto, a licensed practical nurse In the State of Florida, having been issued license number PN 1261331. Apr 5 2005 10:34 APR-GS-2085 18:38 AHCA- , HCA LEGAL MEDICAL 856 414 1989 P.@8/18 4. Respondent's last known address is 9200 Richmond Road, St. Cloud, Florida 32712. 5. On or about May 30, 2001, Respondent was amployed by the Orange County Corrections Department and worked in the position of Intake Nurse. 6. As per procedure of the Orangs County Corrections Department, upon admission all physician's orders for an inmate written into medical charts are to be signed and veritied by two nurses. A second nurse is to review and confirm for accuracy orders transcribed by the nurse who initially received the orders and that the orders are accurately written in the medical charts. 7. Further as per procedure af the Orange County Corrections Department, if an admitting inmate has a prescription for a controlled substance, then the staff clinician is to be notified. 8. On or about May 30, 2001, K.J. returned to the Orange Gounty Jail from Orlando Regional Health Gare System with physician's orders, including an order to place K.J. on methadone, 9. Respondent reviewed the physiciar’s orders of patent K.J. after the orders were received and transcribed by the initial intake nurse. 8, On or about May 30, 2001, Respondent failed to assure thal all physicians’ orders as received from Orando Regional Healthcare System for K.J. were transcribed campletely and accuratcly. Apr 5 2005 10:35 APR-GS-2085 18:38 AHCA/LEGAL MEDICAL 856 414 1989 P.@9/18 o ‘ ’ a 9. Respondent failed to assure that the physician's orders for KJ. were transcribed exactly as prescribed ta include that KJ. be placed on methadone. 10. Respondent failed to assure that the staff clinician was notified that K.J. had a history of controlled substance use or that K.J, had a prescription for a controlled substance. 11. On or about June 2, 2001, KJ. exhibited signs of withdrawal symptoms and expired several days jater after removal of Ife support. 12, Respondent's failure to assure that the orders were fully transcribed and/or that the clinician was advised of K.'s prescription for methadone contributed to K.J.’s suffering and/or death. 13. Based on the foregoing, Respondent is subject to discipline pursuant to section 464.018(1)(h), Florida Statutes (2000) for unprofessional conduct including, but nut limited to inaccurate recording of patient records. negligent acts or omissions, and/or failure to conform to the minimal standards of acceptable and prevailing nursing practice, WHEREFORE, Petitioner respectiully requests 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 retiaf that the Board deems appropriate. Signed this b4Vtay of 200g. lohn O. Agwunobi, M.D., M.B.A. Secretary, Department of Health Ape 5 2005 10:45 APR-&S5-2685 18:38 AHCA“LEGAL MEDICAL 858 414 1989 P. 16-18 a © a —_ BY: Nancy Snurkowski, Chief Attorney On Behalf of the Agency for Health Care Administration COUNSEL FOR THE PETITIONFR: Michael T. Flury, Seniar Attomey Florida Bar Number: 0118590 FILED... Agency for Health Care Administration DEPARTMENT CLERE Allied Health Section Ok Past Office Bax 14279 "4 - Tallahassee, Florida 32317-4229 cen (7 oe. (850) 457-9670 pate, MTF/mf POP And? M 9 fy /p 2 TOTAL F.18

Docket for Case No: 05-001229PL