STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2015-18445 JULIA FRANCES KEIFFER, 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, Julia Frances Keiffer, 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 Administrative Complaint, Respondent was a registered nurse (R.N.) within the state of Florida, having been issued license number 9207731. 3. Respondent's address of record is 5149 Tan Street, Jacksonville, Florida, 32258. 4. At all times material to this Administrative Complaint, Respondent was employed as a registered nurse at the Mayo Clinic (Mayo), located in Jacksonville, Florida. 5. At all times material to this Administrative Complaint, Mayo utilized the Pyxis medication dispensing system. Pyxis consists of locked medication carts that secure and control access to controlled substances through a computer system. Each cart has a computer terminal on top of the cart that is linked to the pharmacy. Nurses can access Pyxis with either an individual password or through a fingerprint scan. The nurse selects the medication needed and the patient for whom the medication is intended and the specific drawer that contains that medication unlocks and opens. Activity reports can be generated from Pyxis that show all medications removed from the Pyxis cart by a specific nurse. The activity reports indicate the medication, dose, date, time, patient for whom the medication is intended, and nurse removing the medication. - 6. In order to accurately record patient care, and to accurately account for controlled substances, Mayo required nurses to document the Department of Health v. Julia Frances Keiffer, R.N. 2 Case No, 2015-18445 time each medication was administered to the patient on the patient's medication administration. record (MAR). If a dose or partial dose of a controlled substance was removed from Pyxis, but not administered to the patient, the nurse was required to discard the controlled substance in the presence of another licensed nurse. The discard of a controlled substance is referred to in Pyxis as a “waste,” PATIENT ONE 7. On or about January 7, 2015, Patient Number 213547953 (Patient One), was a patient at Mayo. 8. On or about January 7, 2015, at approximately 7:57 p.m., Respondent removed one i mg tablet of lorazepam, ostensibly for Patient One. 9. Lorazepam is prescribed to treat anxiety. According to Section 893.03(4), Florida Statutes, lorazepam is a Schedule IV controlled substance that has a low potential for abuse relative to the substances in Schedule TI and has a currently accepted medical use in treatment in the United States, and abuse of the substance may lead to limited physical or psychological dependence relative to the substances in Schedule II. Department of Health v. Julia Frances Keiffer, R.N. 3 Case No. 2015-18445 10. Respondent failed to document administering or wasting one 1 mg lorazepam tablet, ostensibly for Patient One. PATIENT TWO 11, On or about February 7, 2015, Patient Number 213684145 (Patient Two), was a patient at Mayo. 12, On or about February 7, 2015, at approximately 11:22 p.m., Respondent removed two 5 mg tablets of oxycodone, ostensibly for Patient Two. 13. Oxycodone is commonly prescribed to treat pain. According to Section 893.03(2), Florida Statutes, oxycodone is a Schedule II controlled substance that has a high potential for abuse and has a currently accepted but severely restricted medical use in treatment in the United states, and abuse of oxycodone may lead to severe psychological or physical dependence. 14, Respondent failed to document administering or wasting two 5 mg tablets of oxycodone, ostensibly for Patient Two. PATIENT THREE 15. On or about April 23, 2015, Patient Number 214100380 (Patient Three), was a patient at Mayo. Department of Health v. Julia Frances Keiffer, R.N. 4 Case No. 2015-18445 16. On or about April 23, 2015, Patient Three had a physician’s order for 5 mg of oxycodone every four (4) hours for pain rated 4-6 or 10 mg of oxycodone for pain rated 7-10. 17. On or about April 23, 2015, Respondent failed to document Patient Three’s pain score in Patient Three’s medical records. 18. On or about April 23, 2015, at 4:09 a.m., Respondent removed two 5 mg tablets of oxycodone, ostensibly for Patient Three. 19. On.or about April 23, 2015, Respondent administered one 5 mg tablet of oxycodone at approximately 4:15 a.m. and 4:17 a.m. PATIENT FOUR 20. On or about May 3, 2015, Patient Number 214216806 (Patient Four) was a patient at May. ) 21. Onor about May 3, 2015, Patient Four had a physician’s order for one 10 mg tablet of oxycodone every four hours as needed for pain. 22. On or about May 3, 2015, at approximately 3:38 a.m., Respondent removed one 5 mg tablet of oxycodone, ostensibly for Patient Four. Respondent then wasted one 5 mg tablet of oxycodone. 23. On or about May 3, 2015, Respondent documented administering one 5 mg_ table of oxycodone to Patient Four at Department of Health v. Julia Frances Keiffer, R.N. 5 Case No. 2015-18445 approximately 3:40 a.m. 24. On or about May 3, 2015, at approximately 10:06 am., Respondent administered one 5 mg tablet of oxycodone to Patient Four. 25, On or about May 3, 2015, at approximately 11:21 a.m., Respondent removed one 5 mg tablet of oxycodone, ostensibly for Patient Four. Respondent then wasted one 5 mg tablet of oxycodone. Respondent documented administering one 5 mg table of oxycodone to Patient Four. PATIENT FIVE 27. On or about May 12, 2015 through May 13, 2015, Patient Number 214212979 (Patient Five), was a patient at Mayo, 28. On or about May 12, 2015 through May 13, 2015, Patient Five had a physician's order for one 5 mg tablet of oxycodone every four hours as needed for breakthrough pain. 29. On or about May 12, 2015, at approximately 8:03 p.m., Respondent documented administering two 5 mg tablets of oxycodone to Patient Five. Department of Health v. Julia Frances Keiffer, R.N. 6 Case No. 2015-18445 30. On or about May 13, 2015, at approximately 12:31 a.m., Respondent documented administering two 5 mg tablets of oxycodone to Patient Five. 31. On or about May 13, 2015, at approximately 5:57 a.m., Respondent documented administering two 5 mg tablets of oxycodone to Patient Five. COUNT ONE 32. Petitioner realleges and incorporates paragraphs one (1) through thirty-one (31) as if fully set forth herein. 33. Section 464.018(1)(h), Florida Statutes (2014), provides that unprofessional conduct as defined by board rule constitutes grounds for disciplinary action. 34. Rule 64B9-8.005(12), Florida Administrative Code, provides that unprofessional conduct includes practicing beyond the scope of the licensee's license, educational preparation or nursing experience. 35. As set forth above, Respondent practiced beyond the scope of her license in one of the following ways: Department of Heaith v. Julia Frances Keiffer, R.N. 7 Case No, 2035-18445 a. By failing to follow a physician’s orders by administering 5 mg of oxycodone to Patient Four instead of 10 mg of oxycodone on or about May 3, 2015; and/or, b. By failing to follow a physician’s orders by administering 10 mg of oxycodone to Patient Five instead of 5 mg of oxycodone on or about May 12, 2015; and/or, c. By failing to follow a physician’s orders by administering 36. 10 mg of oxycodone to Patient Five instead of 5 mg of oxycodone on or about May 13, 2015; and/or, d. By failing to follow a physician’s orders by administering 10 mg of oxycodone to Patient Five instead of 5 mg of oxycodone on or about May 13, 2015. Based on the foregoing, Respondent violated Section 464.018(1)(h), Florida Statutes (2014), by engaging in unprofessional conduct as defined by Rule 64B9-8.005(12), Florida Administrative Code, by practicing beyond the scope of her license, educational preparation or nursing experience. Department of Health v. Julia Frances Keiffer, R.N. 8 Case No, 2015-18445 COUNT TWO 37. Petitioner realleges and incorporates paragraphs one (1) through thirty-one (31), as if fully set forth herein. 38. Section 464.018(1)(h), Florida Statutes (2014), provides that unprofessional conduct as defined by board rule constitutes grounds for disciplinary action. 39. Rule 64B9-8.005(1), Florida Administrative Code, provides that unprofessional conduct includes inaccurate recording, 40. As set forth above, Respondent engaged in unprofessional conduct in the following ways: a. By failing to document administering or wasting one 1 mg lorazepam tablet, ostensibly for Patient One, on or about January 7, 2015, and/or; b. By failing to document administering or wasting two 5 mg tablets of oxycodone, ostensibly for Patient Two, on or about February 7, 2015, and/or; c. By failing to document Patient Three’s pain score in Patient Three’s medical records, on or about April 23, 2015, and/or; Department of Health v. Julia Frances Keiffer, R.N. 9 Case No, 2015-18445 d. By documenting administration of one 5 mg tablet of oxycodone instead of 10 mg to Patient Four on or about May 3, 2015, at approximately 3:40 a.m., and/or; @. By documenting administration of one 5 mg tablet of oxycodone instead of 10 mg to Patient Four on or about May 3, 2015, at approximately 11:23 a.m. 41. Based on the foregoing, Respondent violated Section 464.018(1)(h), Florida Statutes (2014), by engaging in unprofessional conduct as defined by Rule 64B9-8.005(1), Florida Administrative Code, to include inaccurate recording. [This space intentionally left blank] Department of Health v. Julia Frances Keiffer,.R.N. Case No. 2015-18445 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 | qi day of ‘Now 2016. Jenna jPartin Assistant General Counsel DOH Prosecution Services Unit 4052 Bald Cypress Way, Bin C-65 Tallahassee, Florida 32399-3265 Florida Bar Number 0028242 Telephone: (850) 245 - 4640 Facsimile: (850) 245 - 4662 Email: jenna.partin@flhealth. gov /JDP . FILED Department Of Health PCP: April 19, 2016 Deputy Clerk RK A: el Sanders Date APR 19 2016 oo PCP Members: Trybulski (Chair) and Hubbard Department of Health v. Julia Frances Keiffer, R.N. 11 Case No. 2015-18445 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. A request or petition for an administrative hearing must be in writing and must be received by the Department within 21 days from the day Respondent received the Administrative Complaint, pursuant to Rule 28-106.111(2), Florida Administrative-Code.—If-Respondent-fails-to-request-a_hearing-—— within 21 days of receipt of this Administrative Complaint, Respondent waives the right to request a hearing on the facts alleged in this Administrative Complaint pursuant to Rule 28- 106.111(4), Florida Administrative Code. Any request for an administrative proceeding to challenge or contest the material facts or charges contained in the Administrative Complaint must conform to Rule 28-106.2015(5), Florida Administrative Code. Mediation under Section 120.573, Florida Statutes, is not available to resolve this Administrative Complaint. 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. Julia Frances Keiffer, R.N. 12 Case No. 2015-18445

Docket for Case No: 16-003884PL