Registered nurses at UC Davis Medical Center filed a formal complaint Thursday with state regulators accusing the hospital of routinely violating state laws requiring minimum nurse-to-patient ratios.

"We have staffing problems in all UC hospitals, but there is no hospital in the UC system that has this gross and deliberate understaffing," said Beth Kean, director of the University of California division for the California Nurses Association. "We've tried to work with the administration at UC Davis, and they have been resistant."

The complaint is similar to one filed in 2004, the same year the state nursing-ratio law went into effect. After an investigation, the state Department of Health Care Services sided with the nurses union.

A spokesman for the UC medical system welcomed another state review of staffing levels.

"Suffice to say, we think CNA's calculations are inaccurate," said Robert Hulteng, a San Francisco attorney who is representing the University of California in contract negotiations with nurses at its medical centers across the state. Staffing levels have been a sticking point.

"They made clear that it's their view that all the medical centers need to hire more nurses," Hulteng said. "It's a position that has an element of self-interest in it."

He said officials at the University of California, Davis, Medical Center "have no hesitation about making all records available" to state regulators. "They are sure they are in compliance," he said.

The state Department of Public Health said it received the complaint, but a spokesman could not immediately discuss its merits.

"We will investigate the complaint, as we investigate every complaint we receive," spokesman Ralph Montaño said Thursday.

The UC system employs 11,000 registered nurses, 2,000 of them at the UC Davis Medical Center.

In its 2005 investigation, the Department of Health Care Services, which then had jurisdiction of hospital staffing, interviewed hospital staff, visited the hospital and reviewed staffing records.

"Through this process, we were able to substantiate your complaint," the department told the CNA in an April 2005 letter.

As a result, state regulators directed the hospital to take corrective action. The medical center said it would review its staffing levels to comply with the law that required minimum nurse-staffing ratios.

"Some of the things the hospital promised to do were never done," Kean said.

In the complaint filed Thursday, the nurses union alleges that there was insufficient RN staffing 39 percent of the time throughout the hospital, based on its review of staffing levels in March 2009. In some cases, according to documents submitted to state regulators, some shifts at the intensive care unit for newborns were understaffed by as many as 13 nurses.

"It's a patient safety issue that we're talking about," said Karen Brown, a registered nurse at the hospital's intensive care unit.

"We've had a persistent staffing issue in our unit," said Brown. State law prohibits her from caring for more than two ICU patients. But at times, she said, some nurses cannot – or should not – handle more than one patient because the patient is in such serious condition.

Nurses and hospitals have been sparring over staffing levels for years.

Under pressure from the CNA, the state Legislature in 1999 passed Assembly Bill 394, which set minimum nurse staffing levels at hospitals statewide. The law was implemented in 2004.

Call The Bee's Bobby Caina Calvan, (916) 321-1067.