New Regulations requiring childcare centers to keep stock epinephrine creates both a liability issue for staff and centers while also putting undue pressure on educators and administrators.

The new regulations also create clear contradictions: All staff are trained either in AMAT or MAT training to safely and legally administer medications to students. We are taught that we need medication authorization paperwork signed by parents and healthcare providers, we must have allergy action plans and the ability to match medical labels with paperwork. These procedures are both mandated by licensing AND create systems that keep children with allergies and medical conditions safe. 

A regulation to keep stock epinephrine creates a contradiction in that staff are trained NOT to administer any medication to a student that does not have paperwork and authorization. Doing so creates liability issues for staff AND puts unfair expectation on educators who are NOT healthcare providers. 

VDOE licensing has not and will not provide clarity around how these contradictions are being addressed. We are not comfortable moving forward with implementation unless this clarity of procedure is created AND these liability issues and safety issues are addressed. 

Finally, there is the issue of implementation with regards to stocking epinephrine. This is not an OTC medication and needs to be purchased through a prescription from a healthcare provider. Having a stock epinephrine pen, not designated for a specific individual, is not feasible unless VDOE can provide some further guidance on how to address this.