STATE OF FLORIDA DEPARTMENT OF HEALTH DEPARTMENT OF HEALTH, PETITIONER, Vv. CASE NO. 2020-05733 TAMEKA S. NELSON, 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, Tameka S. Nelson, 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 certificate number CNA 250204. 3. | Respondent’s address of record is 109 Hill Greene Road, Crawfordville, Florida 32327. 4. On July 12, 2019, the Board of Nursing filed a Final Order in case number 2016-27945, ordering Respondent to submit verification of course content and course completion for four hours of continuing education in Ethics and Legal Aspects of Nursing, within six months of the order; and putting Respondent’s license on probation for one year, during which Respondent was to submit written reports to the Nursing Compliance Officer every three months; among other penalties. 5. Respondent failed to submit verification of course content and course completion for the required amount of continuing education hours by the deadline. 6. | Respondent failed to submit one or more reports due on or about October 11, 2019 and January 11, 2020. 7. Section 464.204(1)(b), Florida Statutes (2019), provides that 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)(q), Florida Statutes (2019), provides that violating a lawful order of the department or the board, or failing to comply Department of Health v. Tameka S. Nelson, C.N.A. Case Number 2020-05733 with a lawfully issued subpoena of the department, constitutes grounds for discipline. 9. As set forth above, Respondent violated a lawful order of the Board of Nursing by failing to comply with the Final Order in case number 2016-27945, filed on July 12, 2019, when Respondent failed to submit verification of course content and course completion for the required amount of continuing education hours and to submit one or more written reports to the Nursing Compliance Officer. 10. Based on the foregoing, Respondent has violated section 464.204(1)(b) by intentionally violating, section 456.072(1)(q), violating a lawful order of the department or the board, or failing to comply with a lawfully issued subpoena of the department. 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. Department of Health v. Tameka S. Nelson, C.N.A. Case Number 2020-05733 SIGNED this__14*" day of April , 2020. Scott A. Rivkees, MD, State Surgeon General /s/Tiffany McKenzie Tiffany McKenzie Assistant General Counsel Fla. Bar No. 1016697 Florida Department of Health Prosecution Services Unit 4052 Baid Cypress Way, Bin #C65 Tallahassee, FL 32399-3265 Telephone: (850) 558-9868 Facsimile: (850) 245-4662 Email: tiffany.mckenzie@flhealth.gov DEPARTMENT OF HEALTH DEPUTY CLERK CLERK: Mirus DATE: APR 1 5 2020 PCP: 4/13/2020 PCP Members: Ramos & Baumwald Department of Health v. Tameka S. Nelson, C.N.A. Case Number 2020-05733 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. Tameka S. Nelson, C.N.A. Case Number 2020-05733

Docket for Case No: 20-003982PL