Thank you for the opportunity to provide feedback on the proposed regulation requiring all child care centers to maintain a stock supply of epinephrine auto-injectors (EpiPens) and administer them in emergency situations. While I strongly support policies that protect children’s health and safety, I do not support this proposed mandate for several reasons:

1. Existing medication and health-plan regulations already cover children with known allergies.

Virginia licensing already requires centers to follow individualized health care plans, obtain physician-signed action plans, maintain emergency medications on site, and train staff according to each child’s medical orders. Children with diagnosed allergies are already fully protected through this established system.
A duplicative “stock” requirement adds regulatory burden without providing additional benefit for the children most at risk.

2. Mandating medical judgment and medication administration without diagnosis creates liability concerns.

Epinephrine is a life-saving medication—but it is also a prescription medication that requires clinical judgment to determine when administration is appropriate.
Requiring non-medical child care staff to administer prescription medication without a diagnosis or physician’s order places centers and staff in a legally vulnerable position and exceeds the scope of typical child-care training.

3. The cost burden is significant and recurring.

EpiPens have short shelf lives, high replacement costs, and require ongoing expiration monitoring. Mandating multiple sets for all classrooms or areas is financially burdensome for programs, especially small centers, nonprofit centers, and community-based early childhood programs.
Many programs already face tight margins, and this mandate would divert resources away from salaries, training, and quality improvements.

4. The proposed regulation shifts medical responsibility from licensed health professionals to child-care educators.

Child-care providers are not medical personnel. The proposed rule effectively converts early-childhood staff into first responders for a medical emergency they cannot diagnose with certainty.
This shift in responsibility is not aligned with best-practice boundaries between child-care services and healthcare services.

5. Universal stock epinephrine policies are better suited for K–12 settings, not early childhood programs.

Many K–12 districts use school nurses to oversee medication storage, training, and emergency protocols. Child care centers do not have medical staff on site, and their staffing structures are fundamentally different.
Regulations designed for K–12 environments do not translate directly to early childhood settings.

6. A collaborative, family-driven approach is safer and more appropriate.

For children with known allergies, families already partner with pediatricians and centers to provide required medications and safeguards.
For children without known allergies, emergency medical services are the proper mechanism for rapid response—staff are already required to call 911 immediately for any suspected anaphylactic event.