STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, . v. CASE NO. 2017-13719 JESSICA TEDESCHI, C.N.A., RESPONDENT. / ADMINISTRATIVE COMPLAINT Petitioner Department of Health (Department) files this Administrative Complaint before the Board of Nursing (Board) against Jessica Tedeschi, C.N.A., and in support thereof alleges: | 1. Petitioner is the state agency charged with regulating the practice of nursing assistance pursuant to Chapters 20.43, Florida Statutes (2017); Chapter 456, Florida Statutes (2017); and Chapter 464, Florida Statutes (2017). 2. At all times material to this Complaint, Respondent was certified to practice nursing within the State of Florida, having been issued certification number CNA 340163. 3. At all times material to this Complaint, Respondent’s address of record was 1700 Thomas Drive, Clearwater, Florida 33759. 4. On or about November 15, 2017, Respondent was evaluated by Lawrence Wilson, M.D., a physician specializing in addiction medicine. 5. Dr. Wilson diagnosed Respondent with sever opioid use disorder, on medication-assisted treatment; and moderate-to-severe sedative/hypnotic/anxiolytic use disorder. 6. Dr. Wilson opined that Respondent is unable to practice as a nursing assistant with reasonable skill and safety to patients. 7. Dr. Wilson recommended Respondent undergo treatment at the intensive outpatient treatment level and enter into a contract with the Intervention Project for Nursing (IPN). 8. Respondent failed to comply with Dr. Wilson’s recommendations. 9. Respondent is intentionally unable to practice as a nursing assistant with reasonable skill and safety to patients. 10. Section 464.204(1)(b), Florida Statutes (2017), authorizes the Board of Nursing to impose discipline against a nursing assistant for intentionally violating any provision of this chapter, chapter 456, or the rules adopted by the board. 11. Section 456.072(1)(z), Florida Statutes (2017), authorizes the Administrative Complaint ; Dep't of Health v. Jessica Tedeschi, C.N.A. DOH Case No. 2017-13719 Board of Nursing to impose discipline against a nursing assistant for being unable to practice with reasonable skill and safety to patients by reason of illness or use of alcohol, drugs, narcotics, or chemicals or any other type of material or as a result of any mental or physical condition. 12. Respondent is unable to practice nursing with reasonable skill and safety to patients due to one or more of the following: a. Severe opioid use disorder, on medication-assisted treatment; and/or b. moderate-to-severe sedative/ hypnotic/ anxiolytic use | disorder. 13. Based on the foregoing, Respondent violated Section 464.204( 1)(b), Florida Statutes (2017), by violating Section 456.072(1)(z). [Signature appears on following page] Administrative Complaint Dep't of Health v. Jessica Tedeschi, C.N.A. DOH Case No. 2017-13719 WHEREFORE, Petitioner respectfully requests that the Board 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 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 S4n_ day of Fevruawy _, 2018. Celeste Philip, M.D., M.P.H. Surgeon General and Secretary aummere Kristen M. Summers Assistant General Counsel FL DOH Prosecution Services Unit Deparment Health 4052 Bald Cypress Way, Bin C-65 pep le Tallahassee, FL 32399-3265 a Florida Bar Number 112206 (T) (850) 558-9909 (F) (850) 245-4662 ; (E) Kristen.Summers@flhealth.gov PCP Meeting: February 5, 2018 PCP Members: Horne & Johnson Administrative Complaint Dep't of Health v. Jessica Tedeschi, C.N.A. DOH Case No. 2017-13719 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 any other discipline imposed. Administrative Complaint Dep't of Health v. Jessica Tedeschi, C.N.A. DOH Case No. 2017-13719

Docket for Case No: 18-001645PL