Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Family Day Homes [8 VAC 20 ‑ 800]
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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12/5/25  2:38 pm
Commenter: Anonymous

Opposition to Mandatory Stock EpiPen Requirement
 

I am writing as a licensed child care provider in Virginia Beach to share my concerns about the
proposed requirement to stock epinephrine auto-injectors. While I am committed to child safety,
I have serious reservations about this mandate.

First, the financial burden is significant. EpiPens are expensive and must be replaced regularly.
Training requirements for all staff members add additional costs. For small providers like myself,
these expenses are difficult to manage without raising tuition rates for families.

Second, I do not have medical training to diagnose anaphylactic shock or determine when
epinephrine is needed, especially for children without known allergies. I fear making incorrect
medical decisions that could harm a child. The potential complications from accidental injection
or unnecessary administration are frightening. The liability exposure could end my business.

I ask that you reconsider this mandate and instead work with providers on practical alternatives,
such as requiring parents of children with known allergies to provide prescribed EpiPens and
ensuring rapid emergency response. Thank you for considering my perspective.
I am a child care provider in Virginia, and I must speak out about the proposed stock EpiPen
requirement. The cost of this mandate is unsustainable for small providers. Between purchasing
EpiPens, replacing them before expiration, and paying for required staff training, this could cost
my facility thousands of dollars annually. I already struggle to keep tuition affordable for
families while maintaining quality care. This mandate would force me to either raise rates
significantly or potentially close my business. Please reconsider this requirement or provide state
funding to cover these costs.
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.

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.
To summarize,
I am a licensed Virginia child care provider, and I oppose this mandate for the following reasons:
• Financial burden of purchasing and maintaining EpiPens plus training costs
• Lack of medical training to diagnose anaphylactic shock or determine need for epinephrine
• Fear of causing serious harm through accidental injection or unnecessary administration
• Concern about dosing errors with children of different ages and sizes
• Unclear liability insurance coverage and risk of lawsuits
• Better alternatives exist, such as requiring prescribed EpiPens from parents with known
allergies

I support child safety but ask that you work with providers on practical, sustainable solutions.

CommentID: 238466