Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Child Care Program [8 VAC 20 ‑ 790]
Action Amend regulation to require each child day center that participates in the Child Care Program to implement policies for the possession and administration of epinephrine and each family day home provider or at least one other caregiver employed by such pro
Stage Fast-Track
Comment Period Ended on 12/17/2025
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12/11/25  10:50 am
Commenter: Alex Rabung

Concerns
 

As a Virginia parent with 2 children in child care, I am writing to express
serious concerns about the proposed mandatory stock epinephrine requirement.

Financial Impact:
Child care already represents a significant portion of my family's budget. The costs
associated with this mandate—purchasing EpiPens, training requirements, and ongoing
replacement—will inevitably be passed on to families. Many working families, including
mine, are already struggling with child care affordability. This mandate could price some
families out of quality care or force parents to leave the workforce.

Medical Safety Concerns:
While I appreciate the intention to keep children safe, I am uncomfortable with the idea
of child care providers—who are not medical professionals—making decisions about
administering powerful medication to my child without a prescription or specific doctor's
guidance. Epinephrine can cause serious side effects, and the risk of administering it
unnecessarily or incorrectly worries me as a parent.

Impact on Child Care Availability:
I am concerned that this mandate could force some providers to close or reduce
enrollment due to costs and liability risks. Losing quality child care providers would be
devastating for working families in our community. The child care shortage is already a
crisis—policies that might reduce availability should be carefully considered.

Better Alternatives:
I believe the current system works well: parents of children with known severe allergies
provide prescribed EpiPens with clear doctor's  s instructions. I would support
improvements to emergency response times and training providers to recognize allergic
reactions and call 911, but I do not support requiring providers to stock and administer
medication without prescriptions.

I respectfully ask that you reconsider this mandate and work with providers and families
to develop more practical solutions that balance child safety with financial sustainability
and appropriate professional boundaries.

Thank you for considering a parent's perspective on this important issue.

CommentID: 238557