| 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 |
![]() |
Thank you for hearing my perspective and considering my opinion. I have read the proposed mandate twice and I fail to understand why childcare providers should be saddled with the amount of liability it proposes. This mandate puts all the weight on childcare providers. They would bear the cost, the liability, and the responsibility of this mandate without actually making children any safer.
Please take the time to come together and find a more amicable solution. Childcare providers work long hours and take on a tremendous responsibility without a great deal of gratitude or respect, please don't compound an already tenuous situation by asking them to take on the responsibility of administering powerful drugs to a child who may or may not need them. Subsequently you're asking providers to incur the costs of these drugs, which can run upwards of $600 to $800. The cost could be staggering for a provider with a mixed age group, and let me remind you, they can't use insurance to cover the costs of the Epi-Pens.
Additionally, you're putting the cart before the horse and tying their hands. Mandating that the EpiPens must be in-house, then they'll be sited if they aren't available, and putting them at risk legally if they don't administer the correct EpiPen or they do administer the EpiPen and it wasn't needed. Is there a mandate to protect providers under these conditions?
My wife has been a childcare provider for 20 years and I've been her assistant for over 8 of those years. Neither of us has ever seen a child go into anaphylaxis nor need an Epi-Pen. She has however, performed the Himelick maneuver twice when a child choked. If you just need suggestions on something to mandate, how about making it mandatory that all providers have a Life Vac Home Kit. Something they would be more likely to use AND something they wouldn't have to spend additional time in professional development and money to maintain annually. How bout that?
Thank you for listening and considering.
James L. Cotman
Full-time Assistant at Andy's Room Childcare