Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 780]
Action Amend regulation to require each child day center to implement policies for the possession and administration of epinephrine
Stage Fast-Track
Comment Period Ended on 12/17/2025
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11/20/25  8:14 am
Commenter: Melissa West

Concerns regarding regulation
 

I am writing to express my concerns regarding the epi-pen requirement for child day centers, which would effectively require multiple epi-pens for even small centers in order for the pen to always be accessible for separate groups of children. While children with known allergies often have families whose health insurance would greatly reduce the cost of epi pens that are kept at child day centers, the same would not be true of the center purchasing the epi pens, which would need to be done continually, as this medication does expire. This direct cost is a burden for child day centers, as is the burden of training, inspection, and the cost of workers time. Required timelines for training and the availability of training has in other areas proven a high chance of misalignment, and this is almost certain to add to the high stress of onboarding staff in a timely manner, and will likely result in otherwise ready staff who would not be able to work and can disrupt continuity of care for families. Unfortunately, the child care system is already financially difficult for families, staff, and the centers themselves, and any added burden directed by law must be supported financially-- even laws designed to keep children safer and prepare for the worst "what if" situations. Otherwise, centers must either pass costs on to families or sustain cuts in other areas that can only decrease quality of care, which goes against the spirit in which this law was proposed.

CommentID: 237828