| Action | Amend regulation to require each family day home provider or other caregiver to be trained in epinephrine administration; notification requirements to parents required |
| Stage | Fast-Track |
| Comment Period | Ended on 12/17/2025 |
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I am writing to oppose the mandatory stock EpiPen requirement due to serious liability concerns. My insurance company cannot confirm coverage for claims arising from stock epinephrine use. If I incorrectly administer or fail to administer epinephrine, I could face devastating lawsuits that would destroy my business and financial security. Without clear liability protection, this mandate exposes providers to unacceptable legal risk. Please provide comprehensive liability protection or make this program voluntary rather than mandatory.
Additionally As a child care provider with no medical background, I am deeply concerned about the proposed EpiPen requirement. I am not qualified to diagnose anaphylactic shock or make split-second medical decisions about when to administer epinephrine. I fear accidentally harming a child through incorrect diagnosis, improper injection technique, or unnecessary administration. This mandate places medical responsibilities on educators that should remain with healthcare professionals. Please reconsider requiring providers without medical training to make these critical medical decisions.