STATE OF. FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, v. CASE NO. 2011-13421 ELIZABETH ANNE BUCHANAN, R.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 Respondent, Elizabeth Anne Buchanan, R.N. and in support thereof alleges: , 1. Petitioner is the state agency charged with regulating the practice of nursing pursuant to Section 20.43, Florida Statutes; Chapter 456, Florida Statutes; and Chapter 464, Florida Statutes. 2. At all times material to this Complaint, Respondent was a licensed registered nurse (R.N.) within the state of Florida, having been issued license number RN 1737392. i ; 3. Respondent's address of record is 2730 Ashton Road, Sarasota, Florida 34231. 4. On or about October 22, 2008, Respondent entered into a five year contract with the Intervention Project for Nurses (IPN). 5. Intervention Project for Nurses (IPN) is the impaired practitioners program for the Board. of Nursing, designated pursuant to Section 456.076, Florida Statutes. IPN is a program that monitors the evaluation, care, and treatment of impaired nurses. IPN provides for the exchange of information between the treatment providers and the Department for the protection of the public. 6. Respondent's contract with IPN required monitoring and extended through September 23, 2013. 7. On or about August 16, 2011, Respondent was dismissed from IPN for failure to comply with the terms and conditions of her IPN Advocacy contract. 8. Section 456.072(1)(hh), Florida Statutes (2011), provides that being terminated from a treatment program for impaired practitioners, which is overseen by an impaired practitioner consultant as described in s. 456.076, for failure to comply, without good cause, with the terms of the Department of Health v. Elizabeth Anne Buchanan, R.N. 2 Case Number 2011-13421 2:\PSU\Nursing\John J Truttt\Nursing\AC's\RN\Elizabeth Buchanan, RN IPN.doc cs t monitoring or treatment contract entered into by the licensee, or for not successfully completing any drug treatment or alcoho} treatment program, constitutes grounds for discipline. 9. | Respondent was terminated from IPN for failing to comply with the terms and conditions of her IPN Advocacy contract. 10.. Based on the foregoing, Respondent violated Section 456.072(1)(hh), Florida Statutes (2011) by being terminated from Q treatment program for impaired practitioners, which is overseen by an impaired practitioner consultant as described in s. 456.076, for failure to comply, without good cause, with the terms of the monitoring or treatment contract entered into by the licensee, or for not successfully completing any drug treatment or alcohol treatment.program. 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. Department of Health v. Elizabeth Anne Buchanan, R.N. 3 Case Number 2011-13421 J:\PSU\Nursing\John J Truitt\Nursing\AC's\RN\Elizabeth Buchanan, RN TPN.doc SIGNED this_\S"_ day of _Decemke , 2011. —” H, FRANK FARMER, JR., M.D., Ph.D., F.A.C.P. State Surgeon General Florida Department of Health NICHOLAS W, ROMANELLO General Counsel Florida Department of Health WM, FREEMAN MILLER ' Attorney Supervisor Prosecution Services Unit DEPARTENT OF HEALTH AS = LA ; JOHAN). TRUITT CLERIC Trae! Assistant General Counsel DATES, Fla. Bar No. 0084752 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Telephone: (850) 245-4640 Facsimile: (850) 245-4683 Email: john_truitt@doh.state.fl.us PCP: tz[\Size"! PCP Members: 2... Kemp Department of Health v. Elizabeth: Anne Buchanan, RN. Case Number 2011-13421 J:\PSU\Nursing\3ohn 3 Truitt\Nursing\AC: s\RN\Elizabeth Buchanan, RN IPN.doc 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 cali 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. Elizabeth Anne Buchanan, R.N. 5 Case Number 2011-13421 3:\PSU\Nursing\John J Truitt\Nursing\AC's\RN\ Elizabeth Buchanan, RN IPN.doc

Docket for Case No: 14-000935PL