Jun 11 2009 14:59 JUN-11-2889 15:41 AHCA P.a4 STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2007-14454 TIFFANY N. JONES, C.N.A., 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 Respondent, Tiffany N. Jones, C.N.A., and in support thereof alleges: 1. Petitioner is the state department charged with regulating the practice of nursing assistance pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Administrative Complaint, Respondent was a licensed certified nursing assistant (C.N.A.) within the state of Florida, having been issued license number CNA 120137, Jun 11 2009 14:59 JUN-11-2889 15:42 AHCA P.@S 3. Respondent's address of record is 312 N. Disston Avenue APT 3, Tavares, Florida 32778. 4. At all times material to this Administrative Complaint, Subject was employed by Advantage Medical Staffing. 5. From on or about February 22, 2007, through on or about March 24, 2007, Subject was assigned to work at Leesburg Regional Medical Center North Campus (LRMC). 6. Respondent never worked her scheduled shifts at LRMC. 7. An individual other than Respondent identified herself as Respondent and worked Respondent's scheduled shifts at LRMC. 8. Personnel at LRMC were alerted that the person working under Respondent’s C.N.A. license was not Respondent, so they contacted the Leesburg Police Department. 9. On or about April 16, 2007, the Leesburg Police Department arrived at LRMC. 10. The Leesburg Police Department attempted to locate the person that identified herself as Respondent to question her. The person left LRMC before the Leesburg Police Department could question her. Department of Health v. Tiffany N. Jones, C.N.A. 2 Case Number 2007-14454 2:\PSU\Nursing\Michael\Acs\ Drafted ACs\A-OVJones, Tiffany (CNA, helping unlicensed practice).doc Jun 11 2009 15:00 JUN-11-2889 15:42 AHCA P.@6 11. The person that identified herself as Respondent and worked under Respondent's C.N.A. license was later identified as Takisha 5. Lovett. 12. On October 7, 2008, Takisha S. Lovett entered a plea of nolo contendere to the crime of unlicensed practice of health care professional, a third degree felony in violation of Section 456.065(2)(d)1i, Florida Statutes. 13. Respondent allowed Takisha S, Lovett to practice nursing, assistance in Florida under her C.N.A. license. 14. Prior to being contacted by Advantage Medical Staffing about the allegations, Respondent never informed Advantage Medical Staffing that her Advantage Medical Staffing pay card and PIN number were stolen. 15. Prior to being contacted about the allegations, Respondent never reported the theft of her Advantage Medical Staffing pay card and PIN number to law enforcement authorities. 16. Section 464.204(1)(b), Florida Statutes (2006), provides that intentionally violating any provision of Chapter 464, Chapter 456, or the rules adopted by the board, constitutes grounds for which the board may impose disciplinary sanctions. Department of Health v. Tiffany N. Jones, CNA, . 3 Case Number 2007-14454 J:\PSU\Nursing\Michael\ACs\Drafted ACs\A-O\Jones, Tiffany (CNA, helping unlicensed practice).doc Jun 11 2009 15:00 JUN-11-2889 15:42 AHCA Pa? 17. Section 456.072(1)(j), Florida Statutes (2006), provides that aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department or the board, constitutes grounds for disciplinary action. 18. Respondent is licensed pursuant to Chapter 464, Florida Statutes, and is a health care practitioner as defined in Section 456.001(4), Florida Statutes (2006). 19. As set forth above, Respondent engaged in aiding, assisting, procuring, employing, or advising any unlicensed person or entity to practice a profession contrary Chapter 456, Florida Statutes, Chapter 464, Florida Statutes, or the rules of the department by aiding or assisting Takisha S. Lovett to practice nursing assistance when Takisha S. Lovett did not possess an active Florida C.N.A. license. 20. Based on the foregoing, Respondent violated Section 464.204(1)(b), Florida Statutes (2006), provides that intentionally violating - any provision of Chapter 464, Chapter 456, or the rules adopted by the board, by intentionally violating Section 456.072(1)(j), Florida Statutes (2006), by aiding, assisting, procuring, employing, or advising any eet ot Health v. saitany N. Jones, C.N.A. 4 Case Number 2007-1 a: APSUINursing\ Michael A¢s\ Drafted ACs\A-O\jones, Tiffany (CNA, helping unlleenged practice).doc Jun 11 2009 15:00 JUN-11-2889 15:43 AHCA P.@8 unlicensed person or entity to practice a profession contrary to this chapter, the chapter regulating the profession, or the rules of the department. WHEREFORE, the 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 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 _2 us day of Manet , 200.4, Ana M. Viamonte Rose, M.D., M.P.H. Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0011265 (850) 245 - 4640 Telephone , (850) 245 - 4683 Facsimile sO , /MGL 3/26/09 Department of Health v. Tiffany N. Jones, €.N_A, 5 Case Number 2007-14454 J:\PSU\Nursing\Michael\ACs\Drafted ACs\A-O\Jones, Tiffany (CNA, helping unlicensed practice).doc Jun 11 2009 15:00 JUN-11-2889 15:43 AHCA P.@9 PCP: PCP Members: 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. Department of Health v. Tiffany N, Jones, CNA. 6 Case Number 2007-14454 J:\PSU\Nursing\Michael\ACs\Drafted ACs\A-O\Jones, Tiffany (CNA, helping unileensed practice).doc

Docket for Case No: 09-003154PL