To whom it may concern: 

On behalf of Primrose Schools, I am writing to respectfully request that the Virginia Department of Education pursue the standard rulemaking process rather than the fast-track process for the proposed amendments related to stock or undesignated epinephrine for licensed child day centers and family day homes. We fully support the intent to protect children. However, these proposed changes carry significant operational and financial implications for providers. 

As a franchise company, Primrose Schools supports over 550 independently owned and operated early education schools across 36 states, including 23 schools in Virginia where they are licensed to serve over 4,300 children aged 0-5. Should this rule or any version of it move forward, we will need to update our internal policies and provide comprehensive training for our employees who in turn support Primrose school Franchise Owners on the ground in the Commonwealth. This work is essential to ensure compliance and maintain the highest standards of safety and care for children. 

The fast-track timeline does not allow sufficient opportunity for thoughtful implementation. More time is needed to: 

• Align our operational policies with any new requirements. 

• Develop training for Franchise Owners to deliver to their teams. 

• Support Franchise Owners in assessing and mitigating potential impacts on insurance coverage and operational costs. 

A standard rulemaking timeline would allow for broader stakeholder engagement, careful consideration of implementation challenges, and the development of practical solutions that prioritize child safety without imposing unintended burdens on early childhood programs. 

Thank you for considering this request. We appreciate the Department’s commitment to child health and safety and look forward to collaborating on a process that ensures effective and sustainable implementation. 

Sincerely, 
Kristin Bernhard 
Executive Director, Corporate Social Responsibility and Public Advocacy 
Primrose School Franchising Company LLC