Dear Virginia Department of Education,

Thank you for the opportunity to provide public comment on the proposed fast-track regulations regarding stock or undesignated epinephrine for child day programs.

I am a licensed family day home provider, and I fully support efforts to keep children safe. However, I am concerned about several aspects of the proposed requirements as they relate specifically to small, home-based programs like mine:

1. The cost of stock epinephrine is prohibitive.
   With devices ranging from $290 to $850 each and no available federal or state funding, this places a disproportionate financial burden on small programs that operate with narrow margins. Providers should not be required or pressured to absorb the cost of medical devices that expire annually without state financial support.
2. Clarification is needed on liability.
   If family day home providers store epinephrine or administer it to a child without a prescription, we need clear guidance on liability protections, documentation requirements, and emergency procedures to ensure we are acting safely and legally.
3. Training timelines and accessibility must be clear.
   While I appreciate that training will be offered at no cost, small providers need training delivered in formats that are accessible around our operating hours, such as virtual modules or flexible scheduling.
4. The requirement to notify parents about whether epinephrine is stored is reasonable, but providers should not face penalties for choosing not to store stock epinephrine due to cost.

I respectfully request that the Department consider:

• Providing funding or negotiated reduced-cost devices for small programs
• Clarifying liability protections
• Creating flexible, accessible training options
• Ensuring that providers who choose not to store stock epinephrine are not disadvantaged in licensure or compliance

Thank you for considering the viewpoint of family day home providers as you finalize this regulation. I am committed to maintaining a safe, healthy environment for children and appreciate thoughtful, practical guidance that supports programs of all sizes.

Sincerely,

Cimbria Peterson

Licensed Family Day Home Provider

Fairfax, VA