Thursday, September 24, 2015

James McGovern's Ohio Board of Nursing Enforcement Update for September 2015



The Ohio Board of Nursing met on September  17-18, 2015.  James McGovern of Graff & McGovern, LPA, attended and otherwise participated as legal counsel for numerous nurses.  His report is as follows.

Fortunately, the Board voted to approve Consent Agreements to resolve the charges pending against numerous nursing clients of Graff & McGovern.  Those Consent Agreements involved negotiated and reasonable resolutions of the charges that required some level of compromise by both the licensees and the Board.  Most of the Consent Agreements took 4-6 months from the issuance of the Notice to be negotiated with and ratified by the Board.

At the September 2015 Meeting, the Board also deliberated upon 4 Reports and Recommendations to address charges against nursing clients of Graff & McGovern whose cases went to hearing instead of having the charges resolved through a Consent Agreement.  Given the fact that all 4 of those cases involved repeat offenders, the Board was unwilling to settle through a Consent Agreement and instead forced the licensees to hearing where they were at serious risk of having their licenses permanently revoked.  As of this posting, we are still waiting for word upon the final outcomes of those cases.

Given that the Board has now completed 5 of its 6 Board Meetings for 2015, I can safely comment that this version of the Board is by far the strictest and least forgiving that I have seen since I started representing nurses in 1999.  That by no means suggests that they are bad Board Members.  It simply means that nurses who violate the Nurse Practice Act are at high risk of being harshly sanctioned. 

That said, I am beginning to have some concerns regarding the demeanor of the Board’s President during the presentations of licensees and their legal counsel, which occur after the issuance of the Hearing Examiner’s  Report and Recommendation and before the Board’s closed session deliberations upon whether to adopt the recommendations of the Hearing Examiner.  In particular, I found it troublesome that the Board’s President became visibly upset when a licensee and or his / her counsel exceeded the 5 minute time limit by no more than 10 seconds to conclude a point that was being made.  To me, that type of behavior is a disservice to the nursing profession given that the licensees at issue were facing the permanent revocation of their licenses and this was their one and only opportunity to address the Board.

The current take away from the recent cases is that nurses who are being investigated by the Ohio Board of Nursing and/or who are facing pending disciplinary charges brought by the Board must be prepared to fight for fair and reasonable settlement terms.  Regardless of their efforts, some of those nurses may eventually find themselves in a position where they are forced to either accept the harsher settlement terms being insisted upon by the Board’s Secretary or take their case to hearing so that the full Board can consider the defense and/or mitigation evidence being presented.

With respect to the newest batch of cases, at the September 2015 Board Meeting, the Ohio Board of Nursing voted to issue 117 Notices of Opportunity for Hearing charging nurses with violations of the Nurse Practice Act.  This is 37 less Notices than were issued at the July 2015 Board Meeting, but still a very large number of licensees who now face being sanctioned by the Board for alleged violations of the Nurse Practice Act.  

Of the 117 Notices, 16 were Notices of Automatic Suspension and 12 were Notices of Immediate Suspension.  All of the Notices were mailed to the respective nurses via certified mail this week. 
All 12 of the Notices  of Immediate Suspension and Opportunity for Hearing involved drug related felonies / Intervention in Lieu of Conviction.  The 16 Notices of Automatic Suspension and Opportunity for Hearing break down as follows:


Failure to Submit to CD Evaluation
9
Failed Drug Screen
2
  Failure to Follow License Restriction                        5

The remaining Notice of Opportunity for Hearing break down as follows:


Misdemeanor Drug Offense
6
Felony Offense (Non - Drug Related))
5
Medication Administration
5
Theft of Medications
4
Substance Abuse
7
Felony Offense (Drug Related)
3
Fraud in The Application
6
Reciprocal / Sister State Discipline
18
Profanity / Disorderly Conduct
1
Failure to Practice Within Safe Standards
4


Operating a Vehicle Under the Influence
2
Positive Drug and/or Alcohol Screen
7
Fraudulent Billing
2


Fitness to Practice / Mental Health
1
Medication Discrepancies
10
Misdemeanor Offense (Non - Drug Related)
2




Failure to renew License
6

Any nurses receiving a Notice of Opportunity for Hearing  from the Board should strongly consider consulting with experienced legal counsel to protect their interests and they should be mindful of the need to submit a written hearing request to the Board no later than 30 days from the date the Board mailed the Notice.  The failure to comply with the 30-day deadline will leave a nurse with none of the rights afforded by Ohio Revised Code Chapter 119, and it will enable the Board to sanction the nurse’s license without obtaining any input and/or agreement from the nurse.

At least once per month I receive a call from a nurse who has missed the hearing request deadline.  Although there may still be things I can do to help a nurse who has missed the hearing request deadline before deciding to contact legal counsel, any nurse has a much better chance of defending his or her interests when I timely hearing request is submitted.

For nurses who now face pending disciplinary charges by the Board, this means you will be engaged in a struggle with the Board to obtain the most lenient sanction possible through a Consent Agreement and you may be forced to take your case to hearing to try to obtain a better outcome than is being offered through Consent Agreement.  To make it through that struggle and obtain a positive outcome for your nursing license, you will need to know who to communicate with, who to avoid communicating, what information to share and how to leverage positive facts in presenting your defense to the Board.   You will also need to be patient in negotiating the terms of a Consent Agreement with the Board, since the Board’s first offer is usually not its best offer.  Finally, you need to be willing, if necessary, to take your case to hearing if the Board is being unreasonable in negotiating a Consent Agreement. 


James M. McGovern, Esq.   
Phone:  614-228-5800 Ext. 2
Fax:  (614) 228-8811 
E-mail: jmcgovern@grafflaw.com


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