Since VDOE has taken over the licensing regulations for child care centers, my non-profit has seen an increase in mandatory expenses. Adding that we will be required to have an epinephrine auto injector on site for any child who experiences an anaphylactic reaction while in our care will burden us with another mandatory expense for our non-profit child care center. If we were to administer, we would then have to replace the auto-injector... every time. This would be an additional expense which the state is mandating. Additionally, if the purchased injector expires, it would have to be replaced (most likely) annually. Therefore this is not a one-time expense for our non-profit, but an ongoing additional expense which is excessive. Mandated requirements should be covered by the state, and not by individual non-profit centers. 

Another ridiculous mandate put on childcare providers but no funds to cover it. And with it there will need to be training for it that will also have to be the responsibility of the centers, even though we already have CPR and MAT certifications. Virginia Department of Education wants affordable, quality childcare for its residents but with all the regulations and mandates we are being forced to follow we have to raise our rates to cover the additional expenses. 

My two sons have severe food allergies.  It is my responsibility as a parent to provide epi pens for them when they are in school. They are extremely expensive, and they expire annually. You have to dispose of them in a particular way if they are unused. It is like throwing away $1000s of dollars annually if they are unused. I feel that our daycare businesses are strapped as it is due to the cost of our supplies increasing and the cost of minimum wage increasing annually. I do not feel that this is best practice and should NOT be made into a law. Also, parents are sue happy, and centers could get in trouble for giving a child medication without parental permission. Also, too many mistakes could be made even with proper training. We should not be responsible for diagnosing any sort of undiagnosed allergy. We are teachers, not physicians. I understand some of the logic behind this proposed legislation as a parent with children with allergies; however, as a business owner who is already struggling, I see it as a waste of money.  Whomever decided this was a great idea obviously has never had to pay for an EpiPen and then throw it away unused. This legislation is saying that we have to stock an EpiPen for children of all ages. What is considered stock? One for each age and weight group or multiple EPI pens for each age group. I'd like to share that it would be $4,2000 just to have one for each age group on campus, and I have three centers. That's $12,600 a year to stock EPI pens for possible food allergies. Then, when they expire, I just throw away $12,600 and buy another set for each. Ridiculous! If this is something that the state wants, then they should pay for the staff to be trained, the stock of EPI pens annually, and the state should pay for the disposal of them. Our job is hard enough; please don't make it any more difficult. 

I am writing this comment in opposition to the proposed changes to required epinephrine to be available by the child care center. We are already in a time where the real costs of operating licensed facilities continue to rise for numerous reasons, where finding and retaining staffing is increasingly costly and challenging, and where the increased burdens on the child care providers is making the proposition of opening a child care center untenable. Our organization has lost money every single year since COVID hit, and we are projected to continue to do so. In order to break even we would need to increase fees to a level that would make child care unaffordable for anyone but the upper middle class. Affordability of child care is already a problem across the nation. These kinds of regulations increase the financial and administrative burden on child care organizations and add to the problem without providing a solution. For our organization this regulation would add upwards of $5,000 of annual cost. This coupled with the skyrocketing prices of liability insurance would force us to make a difficult decision to not hire an additional staff member in order to cover these administrative costs. If the state wants to solve a problem, there are other ways to do this than to increase the financial burdens on child care providers. 

If we have to keep this on hand, who is giving us a prescription for this?  I think this falls on the parents.

If a child requires an epi-pen it should be supplied by the parent, whose doctor feels it's necessary for the child to have. We are not medical professionals and should not be taking on this responsibility and liability The cost of training staff and hiring staff with this training and the cost of the pen which comes in 2 sizes with a cost of around $650.00 to $750.00 per pen every year because they expire would be a large financial loss especially for smaller centers.

I feel that parents should be responsible to provide epi pens for the children that require it. They are extremely expensive, and they also expire every year. I feel like the daycares and family home daycares are strapped as it is due to the cost of supplies increasing. We should not be responsible for diagnosing any sort of undiagnosed allergy. If a child has an allergic reaction to something and they are not a child that in the past requires and epi pen, then the daycare should call 911.  We are teachers, not physicians.

With this mandate, the burden of expense falls on the non-profit center who already struggles to meet the ever growing costs of child care. For a program that cares for children ages birth to five-years-old, the requirement of having epi-pens designated by weight would mean that the center must have multiple epi-pens on hand for the multiple ages and sizes of the children in the center. 

• "To implement the revised regulations, licensed child day centers and unlicensed subsidy center-based programs would be required to obtain appropriate weight-based dosage of stock or undesignated epinephrine based upon market cost, which ranges from $290-$850 per device at this time."

Assuming the weight classifications would require the center to maintain three epi-pens at a time for each of the three weight groups that are cared for in the center... this could mean annual costs of $870-$2,550. This expense does not cover any training, certification or storage expenses, nor does it include the potential need for replacing an epi-pen that has been used. 

In a childcare setting, great lengths are taken to reduce the risk of allergic reactions, however it is the responsibility of the parent to track allergies and inform the center of such allergies. It should be the responsibility of the parent to procure and manage epi-pens as needed, including replacing them annually. 

I oppose this mandate and the fast-track implementation. 

Response Opposing Mandatory Stock Epinephrine and Untrained Dosage Determination in Childcare Settings

We oppose the proposed amendments to the Child Care Program regulation (8VAC20-790) that mandate the stocking of epinephrine and delegate its administration and dosage determination to non-medical personnel. While the intent to protect children during anaphylactic emergencies is commendable, these regulations introduce significant safety hazards by requiring individuals without proper medical training to manage powerful emergency medications and make critical, high-stakes decisions regarding a child’s health.

Our primary objections center on two major concerns:

1. Significant Hazards of Non-Medical Personnel Stockpiling and Administering Medication

The regulations require childcare center employees or family day home providers—individuals whose primary expertise lies in early childhood education and care, not emergency medicine—to be trained in epinephrine administration. This approach raises several critical safety issues:

• Risk of Misdiagnosis and Inappropriate Administration: Anaphylaxis can mimic other conditions, some of which do not require epinephrine. Administering epinephrine to a child who does not need it can cause serious side effects, including dangerous spikes in blood pressure, heart palpitations, anxiety, and other cardiovascular complications. Childcare staff are not qualified to make a definitive differential diagnosis in a high-stress, emergency situation.
• Liability and Training Limitations: Standardized Medical Administration Training (MAT training) for staff cannot replicate the clinical judgment and expertise of a licensed medical professional. Staff turnover necessitates continuous, costly retraining, and the inherent stress of an anaphylactic emergency increases the likelihood of human error during administration, such as injection site errors or hesitation that delays care.

2. The Inherent Dangers of Determining Weight-Based Dosages Without Medical Training

A core component of the proposal requires providers to store "an appropriate weight-based dosage of epinephrine." This places an unacceptable burden and risk on non-medical personnel:

• Dosage Complexity: Epinephrine dosing for children is highly specific and depends entirely on the child's precise weight. The difference between a safe and a harmful dose is narrow. Childcare providers are not medical professionals trained to accurately weigh children, calculate dosages, and assess contraindications.
• The Problem of "Stock" Doses: Mandating "stock" epinephrine requires providers to guess the likely weight range of the children in their care or stock multiple dosages, further increasing the complexity and potential for error. A child’s weight changes rapidly, and relying on outdated information or estimations is inherently dangerous. Using an adult dose on a small child, or an infant dose on a larger child, could have fatal consequences.
• Undermining Medical Authority: Decisions regarding which medication a child should receive and at what dosage should remain solely within the purview of the child’s parents and their prescribing physician. These regulations effectively require non-medical staff to act as pharmacists and emergency physicians, a role they are neither trained nor legally qualified to assume.

Conclusion

While rapid response to anaphylaxis is vital, the solution should not introduce new, significant hazards. The current proposal shifts complex medical decision-making from trained professionals to laypersons, creating substantial risks of misadministration, incorrect dosing, and accidental exposure. The focus should remain on rapid access to emergency medical services (911) and clear communication protocols between parents and providers, rather than mandating the dangerous practice of non-medical individuals managing potent emergency drugs.

Licensed centers are already overwhelmed with understaffing, and too many regulations.  We are facing significant insurance price hikes due to unnecessary violations which we receive, allowing insurance companies to deny us for literally no reason, or double our premiums.  This would be a huge financial burden, as well as liability issue.  The standards already allow provisions that would cover these issues.  There is no need for revision.  Strongly Oppose,

As an Early Childhood Educator, I am concerned over the recent proposal to require preschools to have (and pay for) epi-pens that are not assigned to a child. We have been trained that we are to have all medication assigned to children, with parent and doctor signatures. This would be against the current standards that are set for licensing requirements.  We have also been trained we are not allowed to administer any prescription medicine or treatment without authorization from the child's doctor. Epi-pens are specific to a child's allergy and are specific to a child's weight-- requiring us to have this, evaluate if it is needed, administer without doctor or parent approval, and use the correct one for the child's weight seems like a huge liability. I want the centers to be able to keep the children safe, but I don't feel this is the right way to offer that care for our children. 

I am in disbelief that this would even be considered. Use of an epipen is the absolute last route anyone would go in treating a child who may be experiencing an allergic reaction. We follow a very strict action plan that has been issued to our staff by the individual child's physician. Where is the legal protection going to come from when someone incorrectly administers an epipen to the wrong weight or when a child isn't truly experiencing a reaction? Where is the money going to come from in order to pay for these ever-expiring pens and the training for staff to administer them? Also just the amount of pens that would be needed to cover the vast amount of weight discrepancies that a school with two year olds-five year olds would have is mind boggling.  We are a small school and our budget is already tight. We paid over $1000 dollars to have our staff MAT certified, another $1500 for CPR/first aid, both of which have to be renewed every couple of years and anytime a staff member is replaced or added. The very idea of having the enormous amount of pens purchased by all of the preschools and other childcare facilities is not only not cost-effective and wasteful, but would also create a burden on pharmacies to be able to keep it in stock for people who truly need it. Who is benefiting from putting this cost and liability on the people who care for young children? It certainly isn't the childcare facilities who are already doing everything they can to hire the best staff and provide the highest level of care. Take this burden off of us please. 

I understand the potential need for schools and childcare centers to maintain a supply of stock epinephrine. It can be critical in situations involving a first-time allergic reaction, an undiagnosed allergy, or when a family is uninsured or unable to afford personal EpiPens.

However, I strongly oppose the proposed amendment that would place the significant, ongoing financial responsibility for purchasing these devices on the schools themselves. If the Commonwealth of Virginia is prioritizing the safety and well-being of its youngest citizens—a goal I fully support—then the state should also commit to funding 100% of the associated costs.

Most preschools and childcare programs in Virginia operate with extremely limited revenue streams. The majority of us rely solely on tuition to cover every operating expense: rent, utilities, staff salaries, insurance, curriculum, furniture, and consumable supplies. Asking programs to raise tuition to shoulder thousands of dollars in annual epinephrine costs puts families in an impossible position and risks pricing out those who already struggle to afford quality childcare.

Very few people enter early childhood education for financial gain. Since COVID, many programs have closed because they faced an untenable choice: increase tuition to levels that families cannot meet, or continue paying educators wages that are already far too low. Only the largest and most financially insulated programs are operating with any substantial margin.

Requiring already-fragile childcare programs to absorb yet another substantial expense is short-sighted and counterproductive. If Virginia believes this measure is essential—and many would agree it is—it should identify state-level funding to support it. Our childcare and preschool programs form the backbone that allows parents to work and local economies to function. They deserve support, not additional financial strain.

Strongly Oppose!

This is not a safe option to be required of all childcare facilities.  It is a much higher risk/liability to have stock epinephrine on site and making the determination if a CHILD (most of which cannot express their symptoms due to younger age) needs it.  

There will be many questions from licensed child care programs. This should be moved to a standard notice-and-comment process. There will be questions:

• Training for a stock epi-pen - all the logistics of it; will this be added to MAT training in the future
• Parent/guardian consent for us to administer
• Insurance - for liability, not covering the cost
• Cost and covering the cost of epi-pens (especially if they are unused and then they expire)

I do not believe it is safe for child care centers to purchase and use Epi-pens that have not been prescribed by a doctor for a specific child.

Please do not fast track this. I don't support this!!

What you are asking of early childcare centers is unacceptable. We are already barely able to get insured, and this is only going to make that more challenging. We also CANNOT AFFORD to dedicate funds to buying and constantly replacing expired epinephrine, training staff, and staffing the building to always have those with the training on hand. Rededicate some time to the REAL ISSUES please.

If a daycare chooses not to administer medication, it isn't fair to impose a mandate that we cannot afford.  

Thank you for the opportunity to provide feedback on the proposed fast-track regulation requiring child day centers to implement policies for the possession, storage, and administration of stock epinephrine auto-injectors. As a child care provider, I strongly support measures that prioritize children's health and safety, including robust responses to allergic emergencies. However, I oppose this mandate in its current form, as it imposes unnecessary regulatory burdens, financial strain, and risks without commensurate benefits. Additionally, I oppose advancing this via the fast-track process, which bypasses the thorough public deliberation needed for such a resource-intensive policy.

Reasons to Oppose the Proposed Regulation

1. Existing regulations and practices already adequately protect children with known allergies.  

Virginia's child care licensing standards require centers to maintain individualized health care plans, secure prescribed medications (including epinephrine for diagnosed children), and train staff on administration per physician orders. These targeted protocols ensure that children at highest risk—those with documented allergies—receive immediate, appropriate care. A blanket "stock" epinephrine requirement duplicates these safeguards, adding complexity without addressing undiagnosed cases, which are rare and better handled by calling 911 (as already mandated).

2. Mandating administration of prescription medication by non-medical staff raises serious liability and safety risks.  

Epinephrine is a powerful prescription drug requiring clinical assessment to avoid misuse, such as over-administration or incorrect dosing. Requiring child care providers—many of whom lack medical training—to make split-second judgments on undiagnosed symptoms could expose staff, centers, and families to legal liability and put children at risk. Even with free VDOE training, this exceeds the scope of child care roles and could lead to errors in high-stress emergencies, potentially harming children rather than helping them.

3. The unfunded financial burden is prohibitive, especially for small and low-income providers.  

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. Licensed child day centers—particularly nonprofit, rural, or community-based ones—operate on thin margins. These costs would inevitably divert funds from essential areas like staff wages, facility improvements, or expanded access for low-income families, exacerbating inequities in child care availability.

4. This policy inappropriately shifts medical responsibilities from healthcare professionals to child care educators.  

Child care providers are trained in basic first aid and emergency response, not advanced diagnostics or pharmacology. Designating them as de facto first responders for potential anaphylaxis blurs critical boundaries between child care and healthcare, potentially overwhelming staff and eroding focus on developmental activities. True medical oversight, such as through school nurses in K–12 settings, is absent in early childhood programs, making this a mismatched solution.

5. The requirements are ill-suited to the diverse structures of early childhood settings.  

Unlike K–12 schools with on-site medical staff and centralized protocols, child care centers vary widely in size, staffing, and hours. Requiring secure storage, constant access, and parental notifications for family homes operating in private residences introduces privacy concerns and logistical challenges. These one-size-fits-all rules overlook the unique needs of smaller programs, where implementation could disrupt daily operations without proportional safety gains.

6. A targeted, collaborative approach—centered on families and medical providers—is more effective and equitable.  

For children with known allergies, the current system fosters strong partnerships between families, pediatricians, and providers to supply and train on personalized epinephrine. For rare undiagnosed cases, immediate 911 activation and basic life support suffice until EMS arrives. We support additional training in recognizing the signs of an anaphylactic reaction and need to call 911. Mandating universal stock epinephrine overlooks this proven model, ignoring input from child care stakeholders who could help refine less burdensome alternatives, such as voluntary stockpiling or subsidies.

Reasons to Oppose the Fast-Track Process

While fast-track regulations are intended for non-controversial updates, this proposal is inherently divisive due to its significant costs, liability implications, and uneven impact on Virginia's diverse child care ecosystem. Rushing it forward without dedicated funding or broader stakeholder engagement—such as town halls with small providers, rural representatives, and allergy experts—risks unintended consequences, like program closures or reduced enrollment in underfunded areas. A standard rulemaking process would allow time to explore cost offsets (e.g., state grants), pilot programs, or amendments to align with existing allergy protocols, ensuring the policy truly enhances safety without harming accessibility. I urge the Virginia Department of Education and Board of Education to withdraw this from fast-track consideration and commit to inclusive, evidence-based revisions.

I appreciate the VDOE's commitment to free training and invite further dialogue to strengthen child health protections in a sustainable way. Please feel free to contact me at cuddlebugscdc@gmail.com for additional input.

Thank you for your consideration.

Sincerely,

Sara Carroll, Owner/Director

Cuddlebugs Child Development Center, CDC 1107061

Warsaw, VA

Thank you for the opportunity to comment on the proposed fast-track regulation mandating that child day centers possess, store, and permit administration of stock epinephrine auto-injectors.

As a licensed child care provider, I strongly support protecting children from severe allergic reactions. However, I respectfully but firmly oppose this mandate in its current form and urge its removal from the fast-track process.

1. Existing regulations already adequately protect children with known allergies through required individualized health care plans, parent-provided epinephrine, staff training, and physician-authorized administration.

2. Mandating non-medical child care staff to assess symptoms and administer a powerful prescription drug to children without a diagnosed allergy significantly increases liability exposure. In an industry already struggling with skyrocketing liability insurance premiums, this new risk will drive premiums even higher — further threatening the financial viability of small, rural, nonprofit, and family child care programs.

3. The regulation imposes substantial unfunded costs ($290–$850 per device + frequent replacements every 12–18 months), diverting scarce resources from staff wages, facility needs, and serving low-income families.

4. It inappropriately shifts medical decision-making and pharmacological responsibilities onto early childhood educators who lack clinical training and oversight (unlike K-12 settings with school nurses).

5. A one-size-fits-all mandate fails to account for the extreme diversity of Virginia’s child care settings — from large centers to small family homes — creating logistical, storage, privacy, and operational burdens with minimal added safety for the rare undiagnosed case.

6. Current protocols — parent/physician-provided epinephrine for known allergies + immediate 911 activation for any suspected reaction — are proven, targeted, and sufficient. Voluntary programs, subsidies, or enhanced recognition training would achieve the same goal without punishing providers.

This proposal is highly controversial due to its significant cost, liability, insurance-premium, and equity implications. Fast-tracking bypasses the thorough stakeholder engagement, cost-mitigation exploration, and standard rulemaking process that such a resource-intensive mandate requires. Rushing forward risks program closures and reduced access in underserved communities.

I urge you to withdraw this proposal from fast-track consideration, pursue standard rulemaking, and work collaboratively with child care providers, insurers, and medical experts to develop sustainable, fully funded, or voluntary alternatives that enhance safety without jeopardizing the stability of Virginia’s child care system.

I welcome continued dialogue and can be reached at 703-726-9306

Thank you for your consideration.

Sincerely,  
Rachel Pariroo 

Primrose School at Moorefield Station 

Ashburn, Va

I see many potential concerns with the use of epinephrine in childcare settings. Having been a home child care provider for over 30 years, I worry that inexperienced or frightened providers may administer it unnecessarily, especially to children. This could create serious complications that would be extremely difficult to address afterward.

The cost of EpiPens is also prohibitive for many providers. Even if they are supplied at no charge initially, they expire regularly and would need to be replaced. That creates an ongoing financial burden. From what I understand, providers would be responsible for maintaining these pens, and that would be an undue hardship for me.

Although I am MAT trained, I am not comfortable keeping an EpiPen in my home or administering it to a child who has not been previously diagnosed by a doctor. Certain medical conditions can mimic allergy symptoms, and giving epinephrine in those situations could make the emergency worse. For these reasons, I believe this approach is risky, reckless, and ultimately irresponsible.

In my opinion, our efforts should focus on increasing allergy education in daycares rather than placing this level of medical responsibility on providers. In the event of an emergency, the safest course of action is to call 911 and allow trained medical professionals to handle the situation.

Parents partner with day care providers to help share the love and care of their children. I do not partner with day care to provide EMT level care to my child without my knowledge in an emergency. Day care providers are caregivers, not EMTs and I do not understand the relevance or benefit of this recommendation. I don’t have EpiPens at home as my child does not have an allergy, why should daycare have one? I do not know the exact dosage appropriate for my child for an EpiPen, why should daycare need to calculate this dose, ensure they stock multiple doses for various children, and then be expected to assess an emergency is in fact an allergic reaction and then find the appropriate EpiPen. This is simply asking for a lawsuit. Parents who have children with allergies know that they need to provide EpiPens and the centers need to be capable of being trained and providing equal care to children. They also need adequate training on how to recognize an emergency to call 911. But administering an EpiPen to a child of no known allergies is honestly stupid and will certainly lead to child death. 

I would never expect, nor do I want, my daycare provider to make a medical decision and administer Epinephrine to my child in a suspected allergy attack. My daycare provider can call 911 and allow a medical professional to make that decision and administer an epi-pen on the spot. Wrongful administration could lead to a whole other layer of issues that I do not want to lay in the hands of my daycare provider. I strongly oppose.  

Willowcreek Academy

Willowcreek Academy

8171 Linton Hall Rd.

Gainesville VA, 20155

703-754-7767

To Whom it may concern,

This letter is in response to the recent proposed changes regarding Child Care Centers and the use of epinephrine. Specifically, that Child Care Centers should stock epinephrine on hand for children with an undiagnosed allergy.

The proposed changes are creating an unreasonable expectation for childcare centers and staff who are already dealing with a variety of state changes that have yet to show benefit to childcare centers or the families they serve.

The proposed regulation would require that non-physicians diagnose an allergic reaction correctly within seconds.  The proposed regulation would require that non-pharmacists administer the correct dosage of a prescription medication without a parent’s consent.

There are multiple court cases such as Van Horn v. Watson (2008) or Carter v. Reese (2016) discussing how jumping in medically is not always the best practice.

While the Good Samaritan law can be argued, it is only used as a defense when you are already going to court. This means that an action has already been taken and multiple lives turned upside down.  In the current political climate, where citizens are more eager to sue for monetary gains, versus except black and white facts, this proposed regulation I fear will be impacting the lives and decisions of many childcare providers.  Childcare providers and owners will be forced to live with the fear of being sued for doing the right thing or the wrong thing.  This in turn could make the heartbreaking decision for many dedicated child care workers, who (through no fault of their own) may choose to leave due to the looming fear of being sued for trying to do what they thought was right. 

For the companies running these childcare centers, it means insurance rates will go up or insurance companies will drop coverage all together considering it to risky.  This will create a domino effect where childcare centers will either be forced to close or no longer accept children on governmental assistance who are identified as some of the most ask risk children.

This proposed regulation exposes Child Care centers and center staff to Legal Liability for administering a non-prescription drug to a child without a physician or parent consent regardless of outcome. Not to mention  impacts various Standards For Child Day Centers: 8VAC20-780-510 B.2. Only with written authorization from the parent, G. Medication shall be labeled with the child’s name, name of medication, dosage amount, and time to be given...and almost two more pages of standards.

This proposed regulation does not currently offer any protection for child care centers and staff and poses numerous risks to the operation and safety of all of those involved in the care and guidance of young children.  I hope that the state will reevaluate this proposed change and take in to consideration all of the aspects listed above.

Sincerely,

Lisa Livermore, M.A. Ed.

Director

There are far too many liability issues with this proposal. It would be best to leave decisions of medical treatment to trained professionals. Parents should be responsible for the medical care of their children, and this includes epipens that are prescribed to their children in case of medical emergency. They can inform the daycare employees of their child's personal needs in case of a severe allergic reaction and how they prefer it to be handled. I am sure that most parents would prefer that their children's medical care is in the hands of licensed medical professionals and is individualized to meet their child's own needs. 

In urban areas, emergency personnel are readily available and carry epi pens.  Paramedics would be better at assessing a child's anaphylactic reaction and knowing if epinephrine was necessary.  Therefore, unless centers are in a rural area, this is not necessary.

How would centers obtain the epinephrine since it is by prescription.  How would centers pay for this medication.  How would this cost be continuously absorbed into the budget?

When referencing weight based administration, how would that dosage be determined by staff?

How would parents be informed of this change and the administration of epinephrine in the event staff determined it was needed by a child?

Strongly opposed to this. Requiring us to fund having an epipen on site when we already require parents to provide it is costly for any center. 

I think it would be fine to purchase the epipen and keep updated for God safety of the child or children needing it.

Centers are already overburdened and passing this will add to it.  You mandate something and make sure we know there’s no funding for it.  In the last couple of years we have struggled to meet competitive wages with rising demands from CLASS Observations.  The state dangles incentives in front of our staff and took them away without warning.  Insurance companies looking for any reason to drop us and you want to throw in a huge liability?! We are not medical professionals.  Parents need to be responsible for providing the medical care their children need and this is no different.  MAT tells us to follow the 5 rights and state standards require us to have plans on specific children when needed- how does stock epinephrine fit into that mold?  It doesn’t!

There are many problems with this. First we are not medical professionals and should not be charged with making this determination. We are held responsible if this goes wrong. We are trained with strict policies when we do administer medications, this would take physicians authorization and parental authorization away and ultimately leave it up to early childhood professionals to determine if and when it is needed. We would be responsible for having multiple doses depending on age and weight and replacing them every year with no funds from the state. These prices are outrages. Insurance companies are already dropping childcare centers left and right and this will only increase those issues.

Opposed

strongly opposed 

Strongly opposed

Opposed!

Opposed 

Opposed 

Strongly oppose. We currently require parents to provide the exact medication that’s prescribed by their doctor. At times the school may have several students with allergies and at times none. 

Opposed

Opposed

Reading another comment, where we will have to have multiple epis depending on weight of the child those are multiple very costly expenses. Having centers spend a considerable amount of money when they are already pinching corners. It should be the parents responsibility for keeping an Epi  and must renew it each year l, that or the state should providing the funding and to get them renewed each year.

In urban areas, emergency personnel are readily available and carry epi pens.  Paramedics would be better at assessing a child's anaphylactic reaction and knowing if epinephrine was necessary.  Therefore, unless centers are in a rural area, this is not necessary.

How would centers obtain the epinephrine since it is by prescription.  How would centers pay for this medication.  How would this cost be continuously absorbed into the budget?

When referencing weight based administration, how would that dosage be determined by staff?

How would parents be informed of this change and the administration of epinephrine in the event staff determined it was needed by a child?

the irresponsible use of any drug could be lethal to children. Why would anybody suggest that. Not to mention the liability and cost to providers the are already bearly making it. This could very easily put us all out of Business which leaves families without providers in their community. I say no to this terrible idea. 

The mandate imposes a substantial and recurring financial strain, particularly on small, home-based family daycares which often operate on thin margins.

• High and Recurring Cost: EpiPens are expensive, and their shelf life is typically only 12-18 months. Requiring the purchase of multiple, weight-appropriate doses (infant/child and adult) for a center with diverse age groups would necessitate an annual, unfunded expense that diverts limited resources away from core childcare needs, such as educational supplies, facility improvements, or provider wages.

• Administrative Overhead: The mandate introduces new administrative responsibilities, including:

  • Rigorous monthly inspections to check expiration dates.

  • Secure, accessible, and compliant storage (e.g., maintaining a locked, yet immediately available, container).

  • Managing procurement and tracking replacements, which is a major diversion of time for a sole provider.

?? Liability and Medical Scope of Practice Concerns

Epinephrine is a potent, prescription-only medication. Requiring non-medical staff to administer it to a child without a known diagnosis introduces significant liability and safety risks.

• Lack of Clinical Expertise: Family daycare providers are childcare educators, not medical professionals. They lack the clinical training to accurately diagnose a severe, undiagnosed allergic reaction (anaphylaxis) versus other conditions that may present similar symptoms. Administering a strong drug unnecessarily carries its own medical risks.

• Legal Exposure: Administering a prescription medication without a specific, physician-written order for that child exposes the provider to increased legal liability. While "Good Samaritan" laws exist in some jurisdictions, they may not offer full protection in a regulatory setting, especially when complex decisions regarding appropriate, weight-based dosage for an undiagnosed child are involved.

• Redundant to Existing Protocols: For children with known allergies, existing regulations already require parents to provide patient-specific EpiPens, along with a physician-signed action plan and appropriate staff training. This targeted, parent-physician-provider collaboration is the safest model.

No to Epi Pen.

Huge Liability

Very Costly.

Prescription Drug we can only keep for 10 days.

As an in-home daycare provider, I believe that requiring me to supply and maintain an EpiPen creates significant financial, medical, and legal risks. The cost of purchasing and carrying the proper insurance for an EpiPen is high, and the liability is even higher. If an EpiPen is administered incorrectly, or if a child has an unknown allergy to the medication itself, it could cause serious harm or even death. In such a situation, the responsibility would fall directly on me as the provider, which is an unfair and overwhelming burden for a small in-home childcare program.

Additionally, mandating that I supply an EpiPen would increase my operating costs. This would force me to raise tuition, which would make my small in-home daycare less competitive compared to large childcare centers. In-home providers already care for a very limited number of children, and our budgets and ratios are very different from centers. If I were responsible for 20 or more children, I might understand the requirement—but with very small group sizes, it is not reasonable to place this level of responsibility on an in-home provider.

For these reasons, I do not believe that supplying or maintaining an EpiPen should be required for in-home daycare providers. Each child’s parent or guardian should remain responsible for providing their child’s prescribed EpiPen when medically necessary, along with the proper documentation and individualized care plan. Thank you

As an in-home daycare provider, I believe that requiring me to supply and maintain an EpiPen creates significant financial, medical, and legal risks. The cost of purchasing and carrying the proper insurance for an EpiPen is high, and the liability is even higher. If an EpiPen is administered incorrectly, or if a child has an unknown allergy to the medication itself, it could cause serious harm or even death. In such a situation, the responsibility would fall directly on me as the provider, which is an unfair and overwhelming burden for a small in-home childcare program.

Furthermore, mandating that I supply an EpiPen would increase my operating costs. This would force me to raise tuition, which would make my small in-home daycare less competitive compared to large childcare centers. In-home providers already care for a very limited number of children, and our budgets and ratios are very different from centers. If I were responsible for 20 or more children, I might understand the requirement but with very small group sizes, it is not reasonable to place this level of responsibility on an in-home provider.

For these reasons, I strongly opposed and I do not believe that supplying or maintaining an EpiPen should be required for in-home daycare providers.

As a childcare provider. I don't feel comfortable to give medication to someone's child. So I have to so no to the EIPPIN.