STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2017-14929 BETTE J. SANDLER, 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, Bette J. Sandler, R.N., and in support thereof alleges: 1. Petitioner is the state agency charged with regulating the practice of practical 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 licensed within the state of Florida and was issued license number RN 1062952. 3. Respondent's address of record is P.O. Box 530347, Debary, Florida 32753. 4. Respondent may be located at 5514 Edgewater Avenue, Orlando, Florida 32810. 5. On or about May 31, 2018, the Department received confirmation that Respondent defaulted on a student loan provided by the state or federal government on or about July 14, 2016. 6. Section 456.072(1)(k), Florida Statutes (2018), provides that failing to repay a student loan issued or guaranteed by the state or the Federal Government in accordance with the terms of the loan or failing to comply with service scholarship obligations shall be considered a failure to perform a statutory or legal obligation, and the minimum disciplinary action imposed shall be a suspension of the license until new payment terms are agreed upon or the scholarship obligation is resumed, followed by probation for the duration of the student loan or remaining scholarship obligation period, and a fine equal to 10 percent of the defaulted loan amount. Department of Health v. Bette J. Sandler, RN 2 Case No, 2017-14929 7. As set forth above, Respondent failed to perform a statutory or legal obligation when she defaulted on a student loan provided by the state or federal government on or about July 14, 2016. 8. Based on the foregoing, Respondent has violated Section 456.072(1)(k), Florida Statutes (2018), by failing to perform any statutory or legal obligation placed upon a licensee. 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. [Signature page follows. ] Department of Health v. Bette J. Sandler, RN 3 Case No. 2017-14929 SIGNED this FILED DEPARTMENT OF HEALTH DEPUTY CLERK CLERK: Maus pate:___ APR 2.3 2019 /ALP PCP: 4/23/19 23rd [t/ Aun L. Prescott Ann L. Prescott Assistant General Counsel Fla. Bar No. 0092974 Florida Department of Health Office of the General Counsel 4052 Bald Cypress Way, Bin C-65 Tallahassee, FL 32399-3265 Telephone: (850) 558-9886 Facsimile: (850) 245-4662 Email: Ann.Prescott@flhealth.gov PCP Members: Dr. McDonough (chair) & Dr. Glymph Department of Health v. Bette J. Sandier, RN Case No, 2017-14929 day of April , 2019. 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. Bette J. Sandler, RN Case No. 2017-14929

Docket for Case No: 19-003731PL