STATE OF FLORIDA ~ DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, Petitioner, CASE NO. 2016-26915 V. ALASIA N. RAMNATH, C.N.A., Respondent. ee | 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, Alasia N. Ramnath, 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 Complaint, Respondent was a certified nursing assistant (C.N.A.) within the state of Florida, having been issued certificate number CNA 255503. 3. Respondent’s address of record is 2935 5" Avenue South, St. Petersburg, Florida 33712. 4. At all times material to this Administrative Complaint, Respondent was employed as a certified nursing assistant (C.N.A.) at Menorah Manor, a nursing center and assisted living residence located in St. Petersburg, Florida. 5. On October 20, 2016, Respondent clocked in for her assigned shift at Menorah Manor at 10:31 pm. 6. On October 20, 2016, Respondent clocked out without advising her nurse leader or other licensed nursing personnel at 10:38 pm. 7. Section 464.204(1)(b), Florida Statutes (2016), provides that intentionally violating any provision of this chapter, chapter 456, or the rules adopted by the board, constitutes grounds for disciplinary action. 8. Section 464.018(1)(h), Florida Statutes (2016), provides that unprofessional conduct, as defined by board rule, constitutes grounds for disciplinary action. 9. Rule 64B9-8.005(3), Florida Administrative Code, provides that unprofessional conduct includes leaving a nursing assignment without advising licensed nursing personnel. DOH v. Alasia Ramnath, C.N.A. 2 Case Number: 2016-26915 10. As set forth above, Respondent intentionally engaged in unprofessional conduct by leaving her nursing assignment at Menorah Manor without advising licensed nursing personnel. i1. Based on the foregoing, Respondent violated Section 464.018(1)(h), Florida Statutes (2015), by engaging in unprofessional conduct, as defined by Rule 64B9-8.005(3), Florida Administrative Code, which provides that unprofessional conduct includes leaving a nursing assignment without advising licensed nursing personnel. 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. ] DOH v. Alasia Ramnath, C.N.A. 3 Case Number: 2016-26915 SIGNED this 2\ day of WA ay { \ | , 2017, Celeste Philip, MD, MPH State Surgeon General and Secretary Avs PACs cot- Ann L. Prescott Assistant General Counsel Fla. Bar No. 0092974 FILED Florida Department of Health DEPARTMENT ‘OF HEALTH Office of the General Counsel CLERK: Angel Sanders 4052 Bald Cypress Way, Bin #C65 pare: MAR 2 1 2017 Tallahassee, FL 32399-3265 —_— Telephone: (850) 245-4640 Facsimile: (850) 245-4662 Email: Ann.Prescott@fihealth.gov /ALP PCP: March 21, 2017 PCP Members: Dr. Colin (chair) & Dr. Newman DOH v. Alasia Ramnath, C.N.A. Case Number: 2016-26915 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. DOH v. Alasia Ramnath, C.N.A. § Case Number: 2016-26915

Docket for Case No: 19-004251PL