Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Voluntary Registration of Family Day Homes - Requirements for Providers [8 VAC 20 ‑ 850]
Action Amend regulation to require each voluntarily registered 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
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10 comments

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11/17/25  6:38 pm
Commenter: Patricia Maryinez / Family Day Home Providers

Family Day Home Perspective on Proposed Epinephrine Rule
 

I am a licensed Family Day Home provider. Unlike centers, we do not have nurses on site, and epinephrine is a serious medical treatment that normally requires a doctor’s prescription. It is also very costly for small home programs. It would be safer and more appropriate for parents to provide the prescribed epinephrine for their own child. Please consider these concerns for Family Day Home providers.

 

CommentID: 237650
 

11/19/25  2:05 pm
Commenter: Kimberly Mruk, Bon Secours Family Center at SMH

Strongly Opposed
 

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.  

CommentID: 237770
 

11/19/25  4:58 pm
Commenter: Bright Horizons Vienna

proposed epinephrine rule
 

Opposed to proposed epinephrine rule

CommentID: 237787
 

11/20/25  10:09 am
Commenter: Anonymous

Opposed
 

Child care centers have budgets that are already stretched too thin. Please do not require one more thing that we are expected to pay for. Allow us to continue to choose if this is a service we will offer and then parents can choose the center that best matches their needs.

CommentID: 237849
 

11/20/25  4:23 pm
Commenter: Jeremy R. Bennett

Voluntary Registration of Family Day Homes - Requirements for Providers [8 VAC 20 ? 850]
 

Thank you for the opportunity to comment on Action 6384 regarding regulatory amendments to 8 VAC 20-850 for voluntarily registered family day homes. While I fully support strong child-safety standards across the Commonwealth, I have concerns about this specific regulatory proposal due to issues involving feasibility, access, and proportionality for the subset of small, home-based providers affected.

CommentID: 237873
 

11/21/25  10:52 am
Commenter: Anonymous

Epi-Pen
 

I do not support this. Please do not fast track this.

CommentID: 237887
 

11/21/25  10:57 am
Commenter: Anonymous

Opposed
 

I strongly oppose this. Do not fast track this. This would put too much stress on already stressed child care providers.

CommentID: 237890
 

11/23/25  8:05 am
Commenter: FOREST HILL DAYCARE

EPI PEN
 

Strongly opposed. We do not give any medication in our daycare. Having to have an Epi pen will not be useful.

CommentID: 237928
 

11/23/25  8:14 am
Commenter: AG

Epi-pen
 

As a small Licensed day home provide having a Epi pen dose not serve a purpose since all medications should be given to our kids only by their own parents. this law is not for every one.

CommentID: 237929
 

11/25/25  11:56 am
Commenter: Susan Gallier, Susan;s Day Care

EipPen
 

I see many potential concerns with the use of epinephrine in childcare settings. Having been in this field 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.

 
Susan Gallier
CommentID: 238037