MAY-B1-2888 14:28 May 1 2008 13:53 _ ARCA STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, _ PETITIONER, v. CASE NO. 2006-35421 TAMARA WATSON, R.N., RESPONDENT..- ee / . ADMINISTRATIVE COMPLAINT COMES NOW, Petitioner, Department of Health (hereinafter “Petitioner”), by and through its undersigned counsel, and files this Amended Administrative Complaint before the Board of Nursing against the Respondent, Tamara Watson, R.N., (hereinafter “Respondent’), and in support thereof alieges: . 1. Petitioner is the state department charged with regulating the Practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes, Department of Health v. Tamara Watson, R.N, Case Number 2006-35421 J;\PSU\Nursing\Maja $, Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc £002 8 2 ony May 1 2008 13:53 MAY-B1-2688 14°28 AHCA P.a4 2. At all times material to this Complaint, Respondent was a Registered Nurse (hereinafter “R.N.”) within the state of Florida having been issued license number 9212666. 3. Respondent’s current address of record is 221 Mango Street, Bradenton, Florida 34207. 4. On or about October 8, 2006, the Respondent was employed as an Rim at- Healthsouth Rehabilitation Hospital of Sarasota ( Healthsouth”) in Sarasota, Florida. 5. On or about October 8, 2006, Respondent was assigned to provide Care to Healthsouth Resident, E.N an 81 year-old male. 6, On or about October 9, 2006, the Doctor ordered E.N. be given a Normal Saline bolus and a Levophed drip to maintain systolic blood pressure greater than 90. 7. Responcient properly documented the order for the Levophed drip. 8. Respondent recorded the physician’s orders for the normal saline to infuse at 100 ml per hour which is inaccurate and does not meet the “bolus” standard. A bolus of fluid is a significant amount infused in a short period of time usually a few hours. Department of Health v. Tamara Watson, R.N, 2 Case Number 2006-35421 J:\PSU\Nursing\Maja S$, Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc May 1 2008 13:54 MAY-@1-2888 14:28 AHCA 9. Respondent administered the Normal Saline at rate inconsistent with the doctor's orders. 10. Respondent stated that she administered a normal Saline bolus as ordered which is not reflected in E.N.’s records. 11. Respondent failed to properly document the fluid bolus on the patient’s medication administration records (MAR). 12. Respondent failed to administer“ €97“Levophed _ after administering the normal saline bolus. 13. Respondent never gave E.N. the Levophed in order to raise E.N.’S blood pressure, | 14. E.N. was found at 7:15 a.m. on or about October 9, 2006 unresponsive, diaphoretic and ashen in color. 15. The morning shift nurse had to administer Levophed to E.N, immediately as well as to keep the crash cart nearby as his blood pressure was dangerously low. COUNT ONE 16. Petitioner realleges and incorporates paragraphs one (1) through sixteen (15) as if fully set forth herein. Department of Health v, Tamara Watson, R.N. . 3 Case Nurnber 2006-35421 J:\PSU\Nursing\Maja 5. Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc May 1 2008 13:54 MAY-B1-2888 14:28 AHCA 17, Section 464.018(1)(h), Florida Statutes (2005), provides that unprofessional conduct, as defined by Board rule, constitutes grounds for disciplinary action by the Board of Nursing. : | 18. Rule 64B9-8.005(1)(a), Florida Administrative Code, provides that unprofessional conduct shall include inaccurate recording. 19. As set forth above, the Respondent engaged in inaccurate recording by failing to document thatrésident E.N. received the fluid bolus on the MAR and by further recording the doctors orders incorrectly. 20. Based on the foregoing, Respondent is in violation of Section 464.018(1)(h), Florida Statutes (2005), by engaging in unprofessional conduct, as defined by Rule 64B9-8.005(1)(a), Florida Administrative Code, to include inaccurate recording. COUNT TWO 21. Petitioner realleges and incorporates paragraphs one (1) through fifteen (15) as if fully set forth herein. 22, Section 464.018(1)(n), Florida Statutes (2005), provides that failing to meet minimal standards of acceptable and prevailing nursing practice, including engaging in acts for which the licensee is not qualified Department of Health v. Tamara Watson, R.N. 4 Case Number 2006-35421 J:\PSU\Nursing\Maja S. Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc May 1 2008 13:54 MeY-E1-2aRe8 14:29 AHCA by training or experience, constitutes grounds for discipline by the Board of Nursing. 23. Rule 64B9-8.005(2)(b), Florida Administrative Code, (2005), provides that failing to meet minimal standards of acceptable and prevailing nursing practice. includes administering medications in a negligent manner. | 24, Respondeni-engaged in negligent medication administration by documenting a doctor’s order for medication of a patient and then failing to administer the medication. Respondent's actions put the resident at risk for unnecessary complications and discomfort and indicated to other caregiver's that the patient had been stable all night, 25. Based on the foregoing, Respondent is in violation of Section 464,018(1)(n), Florida Statutes (2005), by failing to meet the minimal standards of acceptable and prevailing nursing practice, as defined by Rule '64B9-8,005(2)(b), Florida Administrative Code (2005), to include administering medications in a negligent manner. WHEREFORE, Petitioner respectfully requests that the Board of Nursing enter an Order imposing one or more of the following penalties: Permanent revocation or suspension of Respondent's license, restriction of Department of Health v. Tamara Watson, R.N.. 5 Case Nurnber 2006-35421 J:\PSU\Nursing\Maja 5. Holman\RNs\ACs\Tamara Watson, RN\AC-Watson,doc May 1 2008 13:55 MAY-B1-2688 14:29 AHCA P.@8 practice, imposition of an administrative fine, issuance of a reprimand, placement of the Respondent on probation, corrective action, refund of fees billed or collected, remedial education and/or any other relief that the Board deems appropriate. SIGNED this 2007, Ana M. Viamonte Ros, M.D.,.M.P.H. State Surgeon Genera}, Department of Health mk Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 CLERK: Tallahassee, FL 32399-3265 pate__ 2200} Florida Bar # 0674648 (850) 245-4640 (850) 245-4683 FAX Department of Health v. Tamara Watson, R.N. : 6 Case Number 2006-35421 J:\PSU\Nursing\Maja 5, Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc May 1 2008 13:55 MAY-G1-2888 14:29 AHCA P.@9 NOTICE OF RIGHTS Respondent has the right to request a hearing to be conducted in accordance with Section 120.569 and 120,57, Florida Statutes, to be represented by counsel or other qualified representative, to present evidence and argument, to call and cross-examine witnesses and to have subpoena and subpoena duces tecum issued on his or her behalf if a hearing is requested. NOTICE REGARDING ASSESSMENT OF COSTS Respondent is placed on notice that. Petitioner has incurred costs related to the investigation and prosecution of this matter. Pursuant to Section 456.072(4), Florida Statutes, the Board shall assess costs related to the investigation and prosecution of a disciplinary matter, which may include attorney hours and costs, on the Respondent in addition to any other discipline imposed. D.O.H. v. Tamara Watson, R.N. 2006-35421 Department of Health v. Tamara Watson, R.N. 7 Case Number 2006-35421 : : J:\PSU\Nursing\Maja S. Holman\RNs\ACs\Tamara Watson, RN\AC-Watson.doc

Docket for Case No: 08-002162PL