Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Family Day Homes [8 VAC 20 ‑ 800]
Action Amend regulation to require each family day home provider or other caregiver to be trained in epinephrine administration; notification requirements to parents required
Stage Fast-Track
Comment Period Ended on 12/17/2025
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11/21/25  1:01 am
Commenter: Anonymous

STRONGLY OPPOSE - FINANCIAL SET BACK
 

The Problem:

Stock epinephrine auto-injectors (EpiPens) are expensive pharmaceutical products with limited shelf life. Unlike one-time purchases, this represents an ongoing operational cost that providers must budget for indefinitely.

 

Specific Cost Factors:

• EpiPen Junior (for children 33-66 lbs): Approximately $300-650 for a 2-pack

• EpiPen Regular (for children over 66 lbs): Approximately $300-650 for a 2-pack

• Most facilities would need both sizes to cover different age groups

• EpiPens expire after 12-18 months and must be replaced

• Annual replacement costs even if never used

 

Additional Financial Considerations:

• Small family-based providers often operate with minimal profit margins

• Many providers are already struggling with rising costs (food, supplies, insurance)

• State reimbursement rates for subsidized care haven't kept pace with costs

• Passing costs to families makes child care less affordable in an already expensive market

• Some providers may be forced to close rather than absorb these costs

 

Impact on Families:

• Increased tuition rates across the board

• Reduced access to affordable child care

• Particular burden on working families already struggling with costs

 

CommentID: 237880