| 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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For a child day center with children that fall into all three weight groups and uses the FDA-authorized generic epinephrine from CVS, it would cost approximately $330 annually to maintain non-expired epinephrine on hand.
Although DOE's plan is for the training to be offered at no cost to the child day centers, there is no guarantee.
Unfunded Costs Threaten Program Viability: High device prices, short shelf lives, and storage requirements strain budgets. This mandate could also pose the risk of higher insurance rates for the Childcare Center.
At $290–$850 per device, plus recurring replacement costs due to short shelf lives (typically 12–18 months), this mandate would strain already under-resourced programs. These costs would inevitably take away funds from other areas like staff wages (payroll), facility improvements, education, supplies and site necessities.
This policy in my opinion shifts medical responsibilities from healthcare professionals to child care educators and this could be dangerous because of lack of training.