Child Care Aware of Virginia opposes the fast-track process for this very complex and controversial regulatory change. We have received numerous concerns from child care providers about their ability to implement, afford and comply with this new law. Providers have even expressed fears of shutting down as a result of this requirement. While we are supportive of the general concept of this safety measure to protect children and of VDOE's efforts to seek training resources to assist providers with meeting the specific medication administration requirements, there are far greater concerns regarding initial and ongoing access to and costs of the medication, supplies and the logistical processes that will be required to maintain safety and compliance. There are also enormous potential insurance and liability implications that we do not believe have been properly researched or resolved prior to approval, which is a process in itself that will take significant time to address.  

We believe this regulatory action should follow the standard NORA process to provide all involved with adequate time to respond to and prepare for this burdensome change. The fast-track process does not allow for this and will cause further undue stress for child care business owners and families.