I am submitting this comment to express my absolute and unwavering opposition to any proposal that requires child care providers to administer EpiPens or epinephrine auto-injectors to children for whom these medications are not prescribed.

This expectation is not only unreasonable—it is dangerous, irresponsible, and completely unacceptable.

As a licensed child care facility owner, I already carry enormous responsibility for the safety and well-being of the children in my program. But the state is now attempting to place medical responsibilities on providers who are not medical professionals, are not licensed to administer prescription medication, and who would be held personally and financially liable for any adverse outcome. This is an outrageous burden.

Let me be clear:

• I will not take on medical liability for a child who does not have a prescription and an established medical plan.

• I will not allow the state to impose medical expectations on child care professionals who are not trained or legally protected to act in that capacity.

• I will not absorb the financial cost, the risk, or the legal exposure associated with this requirement.

This proposal fundamentally oversteps the role of a child care provider. We are caregivers, educators, and mandated reporters. We are not doctors, nurses, or emergency medical personnel. The state cannot simply assign us these responsibilities without proper licensure, authority, or liability protections, and expect us to comply.

Requiring us to administer a high-risk emergency medication to a non-prescribed child is a breach of professional boundaries, a violation of common sense, and a direct threat to the sustainability of private child care programs. It places every provider in the state in an impossible position—and it endangers both children and staff.

I strongly urge the state to withdraw this proposal. If the goal is to protect children, then regulations must be developed that do not expose child care providers to catastrophic liability and do not force us into medical roles we are neither trained for nor obligated to perform.

This requirement is unacceptable on every level. I oppose it fully and without reservation.

Robin Boling