20-005438PL Department Of Health, Board Of Nursing vs. Stephanie Mccauley, R.N. Status: Closed Recommended Order on Wednesday, April 7, 2021.

Summary: The Department of Health proved that Respondent's license should be suspended pending further action by the Board of Nursing for failure to complete her impaired practitioners' program contract without good cause.

S TATE OF F LORIDA

D IVISION OF A DMINISTRATIVE H EARINGS

D EPARTMENT OF H EALTH ,

B OARD OF N URSING ,

Petitioner ,

vs. Case No. 20 - 5438PL

S TEPHANIE M C C AULEY , R.N.,

Respondent .

/

A MENDED 1 R ECOMMENDED O RDER

An administrative hearing was conducted in this case on February 23 , 202 1 , via

Zoom, before James H. Peterson , III, Administrative Law Judge with the Division of

Administrative Hearings (DOAH).

A PPEARANCES

For Petitioner: Ann L. Prescott, Esquire

Prosecution Services Unit

Department of Health

4052 Bald Cypress Way, Bin C - 65

Tallahassee, Florida 32399

For Respondent: Stephanie Paige McCauley , R.N., pro se

457 Lobelia Road

St. Augustine, Florida 32086

1 This Amended Recommended Order is entered to correct a mistake in the original

Recommended Order which erroneously stated that Respondent had not filed a Proposed

Recommended Order.

S TATEMENT OF T HE I SSUE S

Whether Petitioner should be subject to action against her Registered Nursing

license because of failure to comply with requirements of the Intervention Project

for Nurses , and if so, what is the appropriate penalty.

P RELIMINARY S TATEMENT

On October 26, 2020, the Department of Health (Petitioner or Department) filed

an a dministrative c omplaint (Administrative Complaint) alleging that Respondent

violated section 456.0172(1)(hh), Florida Statutes , 2 by being terminated from a

treatment program for impaired practitioners, overseen by an impaired practitioner

consultant as described in section 456.076, for failure to comply , without good cause,

with the terms of the monitoring or treatment contract entered into by Petitioner .

Res pondent timely filed an Election of Rights disputing the allegations of the

Administrative Complaint and requesting a hearing pursuant to section 120.57(1) ,

Florida Statutes . The case was referred to DOAH on December 17, 2020.

A t the final hearing , which was held as scheduled on February 23, 2020,

Petitioner presented the testimony of Dr. Shannon Opie and Ms. Patrice Ward from

the Intervention Program for Nurses, and introduced PetitionerÔs composite e xhibit

1 , consisting of RespondentÔs case file , Bates - s tamp ed 1 through 1660, which was

admitted into evidence as Exhibit P - 1. Respondent testified on her own behalf and

submitted a 133 - page composite exhibit which was electronically filed on the docket

on December 5, 2020, admitted as RespondentÔs Exhibit R - 1 , and three more

exhibits admitted as RespondentÔs Exhibit s 3, 3a, and 3b.

The proceedings were recorded, and a transcript was ordered. The parties were

given 10 days after the filing of the Transcript within which to file their respective

2 Unless otherwise indicated, all references to the Florida Statutes and Florida Administrative Code

are to the current versions, which have not substantively changed during the relevant time period in

this case.

proposed recom mended orders. Prior to the filing of the Transcript, Respondent

timely filed her Proposed Recommended Order. The one - volume T ranscript of the

proceedings was filed with DOAH on March 1 2 , 2021. Thereafter, PetitionerÔs

Proposed Recommended Order was timely filed on March 22, 2021. Both

Respondent and PetitionerÔs Proposed Recommended Orders have been considered

in the preparation of this Amended Recommended Order. Consideration of

RespondentÔs Proposed Recommended Order did not change the findings or

conclusions of the original Recommended Order.

On March 23, 2021, Respondent filed a document entitled ÑPro SEÔs Intent to

File Exceptions to PetitionerÔs Findings and Recommended OrderÒ (RespondentÔs

Intent to File Exceptions ), and on March 25, 2021 , filed a document entitled

Ñ RespondentÔs Exceptions to [PetitionerÔs Proposed] Recommended Order Ò

(RespondentÔs Exceptions) . Thereafter, Petitioner filed a Motion to Strike

RespondentÔs Intent to File Exceptions and RespondentÔs Exceptions. As

RespondentÔ s Intent to File Exceptions and RespondentÔs Exceptions were untimely

and not otherwise authorized, the Motion to Strike was g ranted and those

documents filed by Respondent were not considered in the preparation of this

Recommended Order.

F INDINGS OF F ACT

1. Petitioner is the state agency charged with the regulation of the practice of

nursing pursuant to section 20.43, chapter 456, and chapter 464, Florida Statutes.

2. Respondent is a licensed registered nurse (RN) in the state of Florida,

currently holding license number RN 9473971, issued in November of 2017.

Respondent was first licensed as an RN in Florida in 1990, under license number

RN 2166302.

3. The Intervention Project for Nurses (IPN) is the consultant contracted by

Petitioner to operate an impaired p ractitioner program for nurses, in accordance

with section 456.076.

4. The mission of IPN is to protect public health and safety and to provide

education, support, and monitoring to nurses throughout the State of Florida.

5. IPN acts as a facilitator, assisting nurses by providing monitoring,

coordinating evaluations, and if necessary, treatment.

6. Participants are referred to IPN in a variety of ways, including self - r eferral

(e.g. voluntary contact directly from the nurse), employer referrals (e.g. hospitals or

c linics who have concerns about safe practice), and Board of Nursing (Board)

referrals (either through conditional licensure or through the disciplinary process).

7. Dr. Shannon Opie has been the c hief e xecutive o fficer for IPN since 2018;

Patrice Ward is currently a senior case manager with IPN.

8. As c hief e xecutive o fficer, Dr. Opie provides clinical expertise to IPN staff and

other leadership, assists with consultative services to the Department on issues of

nursing impairment, provi des education about IPN and potential impairment, and

acts as liaison between IPN and the Department.

9. Dr. Opie testified credibly and consistently as to the mission and purpose of

IPN, the terms and requirements for most participants, and some specifics o f

RespondentÔs participation, including reasons for her termination from the program.

10. Ms. Ward has worked as a case manager at IPN for over 18 years .

11. In her role as a senior case manager, Ms. Ward monitors nursesÔ compliance

with their monitoring contracts to ensure public safety and provides case

consultation, memo and contract review, and mentorship to other case managers.

12. All IPN contracts are composed of two parts. Part 1 consists of the

individualized requirements for monitoring for that specific parti cipant. Part 2 is

the ParticipantÔs Manual, which outlines the general requirements, guidelines, and

protocols of the IPN program.

13. T he Part 1 individualized contract requirements are designed to protect

public safety by ensuring that the participant receiv es proper monitoring and

treatment and by enabling the participant to demonstrate safe nursing practice.

14. The contract requires the participant to demonstrate safe clinical nursing

practice for 12 months, as determined by work performance evaluations comple ted

by the participantÔs direct supervisor and submitted quarterly to IPN.

15. Depending on the nature of the participantÔs issues, this requirement may be

modified by the addition of a controlled - substance restriction prohibiting the

participant from handling or administering controlled substances to patients for a

period of 12 months, to facilitate the recovery process and as a safety measure

within the clinical setting. This was the case for Respondent.

16. After demonstrating safety to practice clinical nursing without handling

controlled substances, this restriction would be lifted to allow the nurse participant

to demonstrate safe nursing practice while being allowed to administer controlled

substances.

17. The total time required for demonstration of safe nursing practice is outlined

in Part I of each participantÔs contract.

18. If a nurse participant is unable to complete all requirements of the contract

within the projected active monitoring period, IPN will offer a contract extension to

allow enough time for the participant to complete those requirements and prove

that he or she was able to practice nursing safely and that the public could be

protected absent further monitoring. Contracts remain in effect until a participant

meets all completion crit eria.

19. IPN communicates with participants through a system called Affinity.

Records of Affinity communications are kept as notes in each participantÔs file,

along with any clinical consultation notes regarding participation.

20. It is each participantÔs respon sibility to provide IPN with updated contact

information for communication purposes.

21. In May of 2000, Respondent first contacted IPN to self - report possible

impairment issues. She signed a contract (Contract #1) for monitoring with IPN,

which was terminated on or about September 30, 2004.

22. In about April of 2005, Respondent re - engaged with IPN, undergoing an

evaluation in August of 2005, and subsequently signing a second Contract (Contract

#2) with IPN. Contract #2 was terminated in May or June of 2007.

23. In June of 2008, a Final Order was filed by the Board against RespondentÔs

previous R.N. license in case number 2007 - 19353, suspending her license for a

specific time prior to her reappearance before the Board and imposing terms for

reinstatement to include p sychiatric evaluation, re - entry plans, proof of counseling

and treatment, if recommended, and documented sobriety.

24. RespondentÔs R.N. license subsequently went to null and void status in 2013

due to nonrenewal between approximately 2007 and 2011.

25. In June of 2015, Respondent reapplied for licensure with the Board.

26. Respondent was required to appear before the Board to discuss her pending

application for licensure by endorsement on June 5, 2015, as her previous license

had gone null and void.

27. When Respondent ap peared , the Board issued a Notice of Intent to Approve

with Conditions (Notice of Intent), approving her application for licensure and

granting a conditional license.

28. The Notice of Intent also required Respondent to complete a remedial course

in nursing, w hich is not an issue in this matter.

29. By the terms of the Notice of Intent, Respondent was required to undergo an

evaluation coordinated by IPN and comply with all terms and conditions imposed by

IPN because of the evaluation prior to her nursing license being approved.

30. Respondent underwent an evaluation with Scott Teitelbaum, M.D.,

(Dr. Teitelbaum) a physician specializing in addiction medicine and psychiatry, on

or about July 2, 2015, after which Dr. Teitelbau m opined that Respondent could not

currently practice nursing with reasonable skill and safety to patients and

recommended IPN monitoring.

31. On or about July 30, 2015, Respondent entered a third contract (Contract)

with IPN pursuant to Dr. TeitelbaumÔs recom mendations.

32. RespondentÔs Contract had a projected active monitoring period from on or

about March 3, 2014, through on or about March 2, 2019.

33. To complete her Contract, Respondent was required to comply with the

terms of completion outlined in Part 1 of the Contract to include the following :

a. Compliance with all terms of this Monitoring Contract;

b. Negative drug screens;

c. Minimum of six (6) consecutive months of

negative/normal toxicology screens;

d. If participant submitted an abnormal/dilute drug scre en

within the last 12 months, a negative 14 panel hair test

and PETH will be required before completion;

e. Satisfactory work performance in a nursing clinical

position for a minimum of one year;

f . Satisfactory recommendation for completion by the

Facilitated Support Group leader and treatment provider,

if applicable.

34. The employment expectations section of the Contract provided in its

pertinent part:

1. Upon entry into practice:

a) Prior to accepting a position, you are required to inform

your immediate supervisor that you are an IPN

participant.

b) [RespondentÔs] position must include direct supervision

by another licensed healthcare professional who is:

1) Aware of your IPN participation;

2) Working on the premises or same unit with periodic

observation;

3) Readily available to provide assistance and intervention;

4) Willing to complete required employer report each

quarter.

35. The Contract employment parameters also included guidelines for shift times

to include a minimum of 12 eight - hour shift s per quarter, but not more than 40

hours per week and/or more than 84 hours bi - weekly, if working 12 - hour shifts.

36. T he Contract further provided that , upon being approved to return to

nursing, Respondent would be prohibited from Ñaccess to or administer[ing] any

controlled/locked (Schedules I - V) medications that are mood/mind - altering for a

period of one year after [you] return to clinical nursing.Ò

37. The Contract also provided that i f Respondent performed successfully in a

clinical nursing capacity under th e controlled substance restriction for a minimum

of one year, that restriction would be lifted. After that, t he Contract required

Respondent to work successfully for six additional months .

38. IPNÔs employment requirements did not dictate the specific type of work

setting required for satisfactory completion of the C ontract, but only the duration of

time required and the supervisory requirements , which in cluded the requirement

that RespondentÔs supervisor be a licensed healthcare professional .

39. When Respondent signed her Contract on Ju ly 30, 2015, she was not

approved to engage in nursing practice. When she was approved to return to the

clinical practice of nursing, on June 15, 2017, she was notified by a letter detailing

general employment expectations and directing her to Part 1 of her Contract or her

IPN Case Manager for details or clarification.

40. Ms. Ward communicated with Respondent as her case manager r egarding

employment expectations and requirements throughout the duration of

RespondentÔs Contract.

41. On April 10, 2018, Respondent submitted to a random toxicology screen

which returned a positive result for alcohol on April 18, 2018.

42. Per the terms of her C ontract, Respondent was required to refrain from the

practice of nursing and to participate in an IPN - facilitated substance use

disorder/mental health/fitness for duty evaluation.

43. On April 27, 2018, Respondent submitted to an evaluation with William M.

Gre ene, M.D., a physician specializing in addiction medicine and psychiatry, after

which Dr. Greene opined that the positive alcohol screen did not indicate relapse

behavior and that Respondent should continue to comply with her Contract .

44. On November 26, 2018 , Respondent began working in a clinical nursing

position at Halifax Health Care (Halifax) in Daytona, Florida.

45. In January of 2019, she received a satisfactory workplace evaluation at

Halifax, and no work issues were reported.

46. On March 19, 2019, Respondent told Ms. Ward she had concerns about work.

As a result, Ms. Ward contacted RespondentÔs supervisor, who indicated a concern

about the safety of patients under RespondentÔs care.

47. When a supervisor reports safety to practice concerns about an IPN

participan t, the issue goes before the IPN clinical team to see if an evaluation is

warranted .

48. On March 22, 2019, because of her employerÔs concerns, Respondent was

required to refrain from practice and undergo an evaluation.

49. On April 15, 2019, Respondent underwent an evaluation with

Dr. Teitelbaum, who recommended that Respondent engage in further assessment

with psychological evaluation and neuropsychological testi ng.

50. On May 27, 2019, Respondent underwent neurocognitive psychometric

testing with Gregory Van Dam, Ps y.D., coordinated through IPN, who provided a

new diagnosis of autis m spectrum disorder and recommended additional therapy.

51. Respondent also submitted to a neuropsychological evaluation on April 29,

2019, with Beth K. Rush, Ph.D. (Psychology), which was not coordinated through

IPN, after which Dr. Rush diagnosed Respondent with nonpsychiatric cognitive

deficit.

52. On June 13, 2019, Dr. Teitelbaum issued an addendum to his prior opinion,

incorporating Dr. Van DamÔs evaluation and recommending that Respondent

eng age in a course of individual dialectical behavioral therapy (DBT), complete a

course in professionalism and disruptive behavior, and remain engaged in and

compliant with her Contract.

53. On June 25, 2019, Respondent was notified of these additional

recommend ations and given a list of course options, with an option to submit any

additional courses for consideration.

54. Between June 26 and July 1, 2019, Respondent corresponded with IPN

regarding an alternate professionalism and disruptive behavior course. IPNÔs

me dical director reviewed the course description and, after consultation with the

evaluator, indicated that it did not cover the requisite topics and was , therefore , not

approved.

55. On July 11, 2019, Respondent returned a Contract addendum with

handwritten com ments and annotations expressing questions about its

requirements.

56. On or about July 12, 2019, Ms. Ward, Dr. Opie, Elizabeth Tuerk (IPN clinical

coordinator) , and Respondent had a phone call to discuss these concerns.

Thereafter, Respondent returned a properly executed Contract addendum.

57. On October 9 through 11, 2019, November 15, 2019, and January 17, 2020,

Respondent attended and completed the Program for Dis tressed Physicians and

related follow - up courses at the University of Florida as recommended by Dr.

Teitelbaum.

58. In the meantime, RespondentÔs employment with Halifax ended in about

May of 2019, after approximately six months.

59. IPN did not credit this term of employment as Ñsuccessful employment,Ò per

IPN Contract terms.

60. Respondent admittedly did not meet the requirement listed above in Part 1

of her Contract as a term of completion , (e) satisfactory work performance in a

nursing clinical position for a mini mum of one year.

61. On May 28, 2020, IPN provided the Board with a memo to be considered with

RespondentÔs request at the June 4 and 5, 2020, Board meeting that she be released

from IPN without fulfilling the employment requirement of her Contract. IPN noted

that the Board denied that request.

62. On June 1, 2020, IPN offered Respondent a Contract extension through

May 28, 2022, to allow for completion of the one - year clinical nursing employment

requirements and to demonstrate safety to practice.

63. On June 4, 2020, Respondent returned the Contract extension with ÑVCÒ

annotated before her signature, by which Respondent intended to indicate that she

had signed the Contract under duress. IPN considered the notation as an

invalidat ion of RespondentÔs signature and it was not accepted.

64. On June 6, 2020, Respondent returned the Contract extension with an

ellip sis before her name. As with the ÑVCÒ notation , Respondent intended the

ellips is to indicate that she signed under duress , which also invalidated her

signature and it w as not accepted.

65. Based upon these annotations, the Contract extensions were not properly

executed and were not accepted by IPN.

66. Consistent with IPN policy and the express terms of the Participation

Manual, on June 8, 2020, Respondent was advised that she n eeded to return a

properly executed contract addendum on or before June 15, 2020, or her Contract

would be terminated. Respondent did not comply.

67. As a result, on June 16, 18, and 22, 2018, IPN sent Respondent letter s

notifying her that she had been dismiss ed from IPN effective immediately for

failure to return an executed contract addendum. She was also notified that her file

would be forwarded to the Department.

68. Respondent did not successfully complete her Contract .

69. At the final hearing, in explaining her reason that she could not sign a valid

extension of the Contract, Respondent testified that, because of her diagnosis of

autism, the only suitable place for her to be employed would be a health

department, and that health departments could not provide lice nsed health

professionals to serve as her supervisors. While that may be RespondentÔs belief,

Respondent did not back up that testimony with credible evidence and otherwise

failed to provide evidence that IPN prevented her from obtaining any job . In fact,

there is documentation in the IPN file that shows constant communication and

encouragement in finding employment to fit the work parameters.

70. Respondent cited instances and examples of jobs that she did not want to

pursue for her own personal reasons.

71. Respondent also failed to provide credible evidence that she was restricted to

work in only a health department environment. Respondent failed to provide a

workplace or occupational evaluation. Instead, Respondent repeatedly testified to

what made her Ñcom fortable,Ò not what IPN was requiring her to do or preventing

her from doing.

72. It is apparent tha t Respondent elected to not seek employment based on her

own personal requirements, not IPNÔs contract requirements.

C ONCLUSIONS OF L AW

73. DOAH has jurisdiction over the subject matter of this proceeding and of the

parties thereto pursuant to sections 120.569 and 120.57(1), Florida Statutes .

74. Petitioner, as the party asserting the affirmative in this proceeding, has the

burden of proof . See , e.g., Balino v. DepÔt of Health & Rehab. Servs . , 348 So. 2d 349

(Fla. 1st DCA 1977). Because Petitioner seeks to suspend, revoke, or impose other

discipline upon a license , this proceeding is penal in nature , see State ex rel. Vining

v. Fla. Real Estate CommÔn , 281 So. 2d 487, 491 (Fla. 1973) , and must prove the

allegations in the Complaint by clear and convincing evidence. Ferris v. Turlington ,

510 So. 2d 292 (Fla. 1987).

75. C lear and convincing evidence:

[r]equires that evidence must be found to be credible; the

facts to which the witnesses testify must be distinctly

remembered; the testimony must be precise and explicit

and the witnesses must be lacking confusion as to the facts

in issue. The evidence mus t be of such weight that it

produces in the mind of the trier of fact a firm belief or

conviction, without hesitancy, as to the truth of the

allegations sought to be established.

In re Henson , 913 So. 2d 579, 590 (Fla. 2005), quoting Slomowitz v. Walker , 429 So.

797, 800 (Fla. 4th DCA 1983).

76. Disciplinary statutes and rules Ñmust be construed strictly, in favor of the

one against whom the penalty would be imposed.Ò Munch v. DepÔt of ProfÔl Reg . , Div.

of Real Estate , 592 So. 2d 1136, 1143 (Fla. 1st DCA 1992) .

77. I n determining whether Petitioner has met its burden of proof, the evidence

presented should be evaluated in light of the specific factual allegations in the

Administrative Complaint. Disciplinary actions against licensees may only be based

upon tho se offenses specifically alleged in the charging document. See , e.g.,

Trevisani v. Dep't of Health , 908 So. 2d 1108 (Fla. 1st DCA 2005).

78. The Administrative Complaint charged Respondent with violating Section

456.072( 1)( hh), which provides in pertinent part:

(1) The following acts shall constitute grounds for which

the disciplinary actions specified in subsection (2) may be

taken:

* * *

(hh) Being terminated from an impaired practitioner

program that is overseen by a consultant as described in s.

456.076, for failure to comply, without good cause, with the

terms of the monitoring or participant contract entered

into by the licensee, or for not successfully completing any

drug treatment or alcohol treatment program.

79. T he Department p roved the allegations in the Administrative Complaint by

clear and convincing evidence. The terms of RespondentÔs IPN C ontract require d ,

among other things, successful employment in a nursing position , supervised by a

licensed healthcare professional, for at least 12 months, subject to a controlled

substance restriction, with successful nursing employment , supervised by a licensed

healthcare professional, for an additional six months without a controlled substance

restriction.

80. These terms are reasonable, necessary, and related to RespondentÔs ability to

practice safely.

81. Respondent admittedly failed to complete the required nursing employment

monitoring in the time initially provided in her Contract.

82. When IPN gave her an opportunity to have additional time to comply with

these terms rather than referring her to the Department, Respondent refused to

execute a monitoring Contract extension.

83. Because of her refusal, RespondentÔs Contract was terminated due to her

failure to complete the Contract requirements or to return an executed Contract

extension.

84. After considering her employment options, Respondent chose not to comply

with IPNÔs requirements without good cause.

85. RespondentÔs unsupported assertion s that her only viable job opportunities

were in health departments, and that health departments do not have enough

licensed healthcare professionals to provide supervision , is unsubstantiated.

Respondent failed to present credible evidence of IPN obstructing any employment

opportunity. To the contrary, IPN offered Contract extensions to enable Respondent

to successfully complete the program.

86. The employment requirements under the Contract , including direct

supervision by a licensed healthcare profes sional , were clearly stated in the

C ontract that Petitioner signed in July o f 2015 , as well as in the C ontract addenda

and extensions she signed in 2016, 2017, and 2018.

87. Respondent later determined, on her own, after signing the Contract, that

she did not wish to pursue employment fitting those requirements.

88. T he Board relies on IPN as the designated, contracted impaired practitioner

consultant under section 456.076 to advise the Board on whether participants can

practice nursing with safety to patients for any reason.

89. I PN contracts directly with the referred licensees for monitoring according to

IPNÔs expertise . The BoardÔs contract with IPN does not contemplate entering those

contract negotiations with participants. Terms of the monitoring contract are

strictly between IPN and the licensee/nurse participant.

90. The Board of Nursing has adopted Florida Administrative Code Rule 64B9 -

8.006, which identifies the range of penalties for violations of chapters 456 and 464.

The rule also identifies aggravating and mitigating circumstances to consider in

determining the appropriate penalty to be imposed. The minimum recommended

penalty for a first violation of section 456.072(1)(hh) is a $250 administrative fine,

suspension, and IPN evaluation ; the maximum recommende d penalty is a $500

administrative fine and suspension. For a second violation, the penalty ranges from

a $500 administrative fine and suspension to revocation.

91. S ection 456.072(4) provides that in addition to any other discipline imposed

for violation of a practice act, the board shall assess costs related to the

investigation and prosecution of the case.

92. The Board should therefore also assess the costs of the DepartmentÔs

investigation and prosecution of Respondent in this matter.

R ECOMMENDATION

Based on the foregoing Findings of Fact and Conclusions of Law, it is

R ECOMMENDED that the Board of Nursing enter a final order finding that

Respondent has violated section 456.072(1)(hh); suspending RespondentÔs license to

practice nursing until Responden t appears before the Board of Nursing with an IPN

evaluation and complies with any and all recommendations; and imposing

PetitionerÔs reasonable costs incurred during the investigation and prosecution of

this case.

D ONE A ND E NTERED this 7 th day of April , 2021 , in Tallahassee, Leon County,

Florida.

S

J AMES H. P ETERSON , II I

Administrative Law Judge

1230 Apalachee Parkway

Tallahassee, Florida 32399 - 3060

(850) 488 - 9675

www.doah.state.fl.us

Filed with the Clerk of the

Division of Administrative Hearings

this 7 th day of April , 2021.

C OPIES F URNISHED :

Stephanie Paige McCauley , R.N. Ann L. Prescott, Esquire

457 Lobelia Road Prosecution Services Unit

St. Augustine, Florida 32086 Department of Health

4052 Bald Cypress Way , Bin C - 65

Joe Baker, Jr., Executive Director Tallahassee, Florida 32399

Board of Nursing

Department of Health Louise St. Laurent, Gen eral Counsel

4052 Bald Cypress Way, Bin C - 02 Department of Health

Tallahassee, F lorida 32399 - 3252 4052 Bald Cypress Way, Bin C - 65

Tallahassee, F lorida 32399 - 3265

Deborah McKeen, BS, CD - LPN

Board Chair

Board of Nursing

Department of Health

4052 Bald Cypress Way, Bin D - 02

Tallahassee, F lorida 32399 - 3252

N OTICE OF R IGHT T O S UBMIT E XCEPTIONS

All parties have the right to submit written exceptions within 15 days from the date

of this Recommended Order. Any exceptions to this Recommended Order should be

filed with the agency that will issue the Final Order in this case.