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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11/24/25  6:27 am
Commenter: Monarch Montessori School

Strongly Opposed
 

At Monarch Montessori School, we do not administer medication per our school policies. We have chosen to allow parents options, which include coming into the facility to administer their child's medication if needed. Otherwise, medications are to be given at home. We do not require MAT training for our teachers. Should we be required to administer epinephrine at our facility, additional training would be needed and since we are a small school, teachers would bear the expense.

Although medications can provide life-saving assistance, it is vitally important that medically-trained personnel provide that assistance. We do not operate in a clinical setting. We would never expect educators to also perform the duties of a nurse or physician in any other context. Our policy, which has been effective thus far has been to call 911 if a child is experiencing a medical emergency. Teachers also have no legal duty to administer medication.  Teachers have a duty to:

1. Supervise students properly.

2. Respond to and prevent bullying and harassment.

3. Take steps to prevent physical injuries from faulty equipment or other hazards.

4. Intervene in situations where a student is at risk of harming themselves or others.

 The liability of administering medication incorrectly is too great. Our General Liability Insurance does not cover medication administration. Additionally, we maintaining epinephrine on campus is both cost-prohibitive and will require additional training for teachers and administration. Storage and tracking the shelf-life of medications simply isn't within the scope of our duties and should not be required as a part of routine operations. We strongly urge VDOE to reconsider this proposal.

CommentID: 237942