Kim’s Home Daycare

Centreville, VA 20121

11/26/2025

 

RE: Public Comment on Proposed Mandatory Stock Epinephrine Requirement

 

To Whom It May Concern,

 

My name is Kim, and I am a licensed child care provider in Fairfax County, Virginia. I am writing to express my concerns regarding the proposed requirement that all child care programs maintain stock epinephrine auto-injectors (EpiPens) for emergency use.

 

I have been providing child care for 30 years and currently care for five children ranging in age from 16 months to 5 years old in a small, family-based program. I am deeply committed to the safety and well-being of every child in my care. While I fully support measures that protect children, I have serious concerns about this proposed mandate that I believe must be addressed before implementation.

 

FINANCIAL CONCERNS

 

The cost of purchasing and maintaining stock EpiPens is a significant burden for a small child care program like mine. As a small provider, I operate on an extremely tight budget, and stock epinephrine would likely expire before ever being used.

 

For my facility, this requirement would cost approximately $800 per year. I would have no choice but to raise tuition by about $150 per family to cover the expense. Families are already struggling with rising costs, and this additional financial burden would be unfair to both providers and parents.

 

LACK OF MEDICAL TRAINING

 

I am an educator—not a medical professional. Although I have received basic EpiPen training through Medication Administration Training (MAT) and CPR/First Aid, I have never been required to use one. I do not feel confident diagnosing anaphylaxis without clear, documented symptoms from a doctor.

 

Expecting child care providers to make a split-second life-or-death medical decision without advanced medical training puts both providers and children at risk. I am uncomfortable being placed into a role that requires medical judgment beyond our training and licensing.

 

FEAR OF CAUSING HARM

 

I am genuinely worried about unintentionally harming a child who does not have a known allergy or who is not under a doctor’s care.

 

What if an auto-injector accidentally injects into a child’s finger?

 

What if I administer epinephrine to a child who does not need it and cause heart complications?

 

What if a child has an underlying heart condition that a provider is unaware of?

 

These are real medical risks that could occur when administering medication without a prescription and without a doctor’s direction.

 

DOSAGE UNCERTAINTY

 

EpiPens come in different strengths based on age and weight. I care for children of various sizes—from toddlers to preschoolers. Without a prescription for a specific child, how would I know which dose is correct?

 

As a licensed provider, I am not permitted to administer medication like an EpiPen unless it is prescribed for that specific child and accompanied by proper medical authorization forms. This mandate contradicts existing medication regulations and places providers in a legally and medically unsafe situation.

 

LIABILITY CONCERNS

 

I contacted my insurance company for guidance. They could not confirm whether I would be covered for administering stock epinephrine and indicated that my premiums would likely increase. They also could not provide clear information about liability protection.

 

I cannot afford the financial risk of a lawsuit—one incident could destroy my business and end my ability to care for families. The legal uncertainty alone is frightening.

 

SUGGESTED ALTERNATIVES

 

I believe the same child-safety goals can be met through approaches that are safer, more practical, and more financially reasonable:

 

Require parents of children with known allergies to provide prescribed EpiPens specific to their child

 

Improve emergency response times in our area

 

Provide additional training for providers on recognizing allergic reactions and when to call 911

 

Create a voluntary program with state funding, full liability protection, and optional participation

 

COMMITMENT TO SAFETY

 

I want to emphasize that I take children’s safety extremely seriously. I work closely with families when introducing new foods. Parents must introduce all new foods at home before I serve them at daycare. Families of children with allergies review recipes and weekly menus in advance to ensure safety.

 

I am fully committed to preventing emergencies before they happen. However, I respectfully ask that you reconsider making stock epinephrine mandatory for all providers.

 

REQUEST

 

I urge the state to:

 

Delay implementation until concerns around cost, training, and liability are addressed

 

Provide adequate funding, clear legal protection, and insurance guidance

 

Make participation voluntary, not mandatory

 

Work collaboratively with child care providers to create practical, safe solutions

 

Thank you for considering my concerns. I appreciate the opportunity to provide input on this important issue and am happy to discuss this further.

 

Sincerely,

Kim

Licensed Family Child Care Provider

Centreville, VA