STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2019-51023 LIZA B. WILLIAMS, C.N.A., 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, Liza B. Williams, C.N.A., 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 certified nursing assistant (C.N.A.) within the state of Florida, having been issued license number CNA 117618. 3. Respondent’s address of record is 808 Lake Cummings Boulevard, Lake Alfred, Florida 33850. 4. Respondent may be found at 299 Winter Ridge Boulevard, Winter Haven, Florida 33881; 3950 Country Place, Apt. 11, Winter Haven, Florida 33880; 2807 Shumard Street, Winter Haven, Florida 33881; or 710 New Hope Street, Apt. 1, Auburndale, Florida 33823. 5. On or about February 21, 2020, in the Circuit Court of the Tenth Judicial Circuit, in and for Polk County, Florida, Respondent entered a plea of guilty to one count of Public Assistance Fraud, a third-degree felony violation of section 414.39, Florida Statutes. 6. Public Assistance Fraud is a crime which relates to the practice of, or ability to practice, licensee’s profession; nursing assistance. 7. Section 464.204(1)(b), Florida Statutes (2019), provides intentionally violating any provision of chapter 464, chapter 456, or the rules adopted by the board, constitutes grounds for disciplinary action. 8. Section 456.072(1)(c), Florida Statutes (2019), provides that being convicted or found guilty of, or entering a plea of guilty or nolo contendere to, regardless of adjudication, a crime in any jurisdiction which Department of Health v. Liza B. Williams, C.N.A. 2 Case Number 2019-51023 relates to the practice of, or the ability to practice, a licensee's profession, constitutes grounds for disciplinary action. 9. As set forth above, on or about February 21, 2020, Respondent entered a plea of guilty to one count of Public Assistance Fraud, a third- degree felony violation of section 414.39, a crime which relates to the practice of, or the ability to practice, nursing assistance. 10. Based on the foregoing, Respondent violated section 464.204(1)(b), by intentionally violating section 456.072(1)(c), for being convicted or found guilty of, or entering a plea of guilty or nolo contendere to, regardless of adjudication, a crime in any jurisdiction which relates to the practice of, or the ability to practice, a licensee’s profession. [Remainder of page intentionally left blank\ Department of Health v. Liza B. Williams, C.N.A. 3 Case Number 2019-51023 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. _6th _dayof____ May _, 2020. Scott Rivkees, MD State Surgeon General EiLED /s/Judson Searcy DEPARTMENT OF HEALTH JUDSON SEARCY DEPUTY CLERK Assistant General Counsel CLERK: Nor — Fla. Bar No. 98772 DATE: MAY 0 6 2020 Florida Department of Health Prosecution Services Unit 4052 Bald Cypress Way, Bin #C65 Tallahassee, FL 32399-3265 Telephone: (850) 558-9898 Facsimile: (850) 245-4662 Email: judson.searcy@flhealth.gov PCP: 05/06/2020 PCP Members: Baumwald & Ramos Department of Health v. Liza B, Williams, C.N.A. 4 Case Number 2019-51023 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. Liza B, Williams, C.N.A. 5 Case Number 2019-51023

Docket for Case No: 20-003283PL