Thank you for the opportunity to provide public comment on the fast?track regulatory actions related to stock or undesignated epinephrine for child day programs.

As the leader of one of only two licensed Family Day Systems in the Commonwealth, I oversee and support system-approved family day homes, of which may transition into subsidy-approved status under 8VAC20?790. Because these changes directly affect home?based early childhood programs, I would like to respectfully raise several important considerations.

1. Current practice already requires parents to supply all emergency medications.

In family day homes, including those within our System, parents provide EpiPens or other prescribed medications for their own child. Providers are trained to administer medication only to the child for whom it was prescribed, with written parent and physician authorization.

Introducing a requirement to maintain stock or undesignated epinephrine shifts the responsibility and liability to the provider—and in the home setting, this creates significant complexity.

2. Undesignated epinephrine carries high risk of misuse or misdiagnosis.

Family day home providers are not medical practitioners. Requiring them to determine whether a child is experiencing an anaphylactic reaction without prior diagnosis—especially a child with no known allergies—creates:

• A high risk of misdiagnosis

• The potential for administering medication unnecessarily

• A significant increase in liability exposure for providers and systems

Even with training, this expectation may exceed what should reasonably be required of home?based child care providers.

3. Clarification is needed on implementation and responsibility for oversight.

Family Day Systems are responsible for approving, monitoring, and supporting member homes. If undesignated epinephrine becomes a requirement:

• Who is responsible for ensuring compliance—the provider, the System, or VDOE?

• Will Systems be expected to purchase, store, train, track, or verify epinephrine administration?

• How will Systems be expected to manage documentation and liability?

Clear guidance is critical before implementation.

4. Cost and storage responsibilities may burden small home-based providers.

Stock epinephrine must be:

• Purchased

• Stored properly

• Replaced when expired

• Maintained securely but accessibly

For home-based providers—many of whom operate on very tight margins—this may be cost?prohibitive without dedicated funding.

Recent data released by Southeastern Ready Region Minus 9–5 underscores the seriousness of the current childcare crisis. Virginia is already facing childcare deserts, significant workforce shortages, and widening supply-and-demand gaps. New mandates—especially those that require providers to purchase costly medical supplies outside their start-up budgets—may discourage new home openings and further destabilize the early childhood landscape at a time when access is already shrinking.

5. Request for consideration or exemption for family day homes.

Given the unique nature of home?based programs, and the fact that parents already provide prescribed emergency medication, I respectfully request that VDOE:

• Consider exempting family day homes from the stock epinephrine requirement, or

• Provide clear alternative options that do not increase liability or financial burden.

Closing Request

Please consider conducting an additional review period or convening a stakeholder workgroup—including Family Day Systems—before finalizing this requirement. This will help ensure safety, feasibility, and clarity across all program types, without adding undue burden to the most vulnerable segment of Virginia’s early childhood infrastructure.

Respectfully,
Mrs. Nicole Ahmad
Founder & Director of Operations, U?LAUNCH: Childhood Development Homes
cdha@ulaunchit.com | www.ulaunchit.com