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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11/19/25  1:12 pm
Commenter: Beach Day School

Opposition to Epipen Amendment
 

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.

CommentID: 237757