Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 780]
Action Amend regulation to require each child day center to implement policies for the possession and administration of epinephrine
Stage Fast-Track
Comment Period Ended on 12/17/2025
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11/18/25  9:46 am
Commenter: Samantha

Concerns Regarding Proposed Change
 

The state already requires providers to have someone trained at all times on site to administer epinephrine. If that state wants to revise and re-word that policy, great, but it's already there. 

But to require a provider to purchase and possibly administer a drug that has not been prescribed by a medical professional is irresponsible and a massive liability. Our programs are already struggling trying to find insurance coverage for typical things that happen in our setting, and now we are going to need a childcare version of medical malpractice insurance? We can't even administer tylenol without a doctor's note with specific instructions, but the state wants to allow us to administer an epi pen when we "think" someone is having a reaction? 

I fully understand wanting to have something on hand in the event a child has a reaction, as providers we of course would always want to help. But we do not have the structure, the medical training, the liability coverage, or the funding to take on such a task. Those epi pens expire every few years and we would have to have more than 1 on hand to span the weights of children that we service. 

At a time when SO much is being put on providers plates with little to no support, the state is playing a dangerous game and risking too much to keep high quality facilities in business. 

CommentID: 237662