Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Family Day Homes [8 VAC 20 ‑ 800]
Action Amend regulation to require each 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
spacer
Previous Comment     Next Comment     Back to List of Comments
11/29/25  4:16 pm
Commenter: Shelly

Oppose EpiPen mandate
 

I am a longtime licensed VA child care provider and oppose the proposed mandatory stock EpiPen requirement. Even though I am MAT trained (Medicine Administration Trained), which includes EpiPen training, I am not comfortable making the complex decision to administer epinephrine to children unless under the instruction of a heath care provider; or the Epipen and allergy action plan has been prescribed by the child's doctor, which would include the parents consent. CPR/First Aid is mandatory for licensed providers and we are trained to observe and assess children upon arrival and throughout the day for any unusual symptoms, and to contact parents or 911 if needed. As a parent and grandparent myself, I would be opposed to non-medical staff making a medical decision for my child when it may of not been needed. Cost, liability, risk if the meds were not needed, dosage uncertainty as licensed providers often have children from infancy to 12 year olds enrolled, are some of the reasons to reconsider this mandate. Recently the 18 month old that I watch developed a substantial red rash after a meal. I immediately contacted the parent, who contacted their pediatrician, and was instructed to administer a small dose of Benadryl and to observe the child in case the rash did not subside; which it did. She hadn't had anything to eat that she hadn't had before. The child had a follow up appointment and no allergies were discovered. Even Benadryl, generally labeled for the use in children aged 6 and older, requires the supervision and explicit direction of a healthcare provider. As well as MAT requires us to have a form signed from the child's doctor to administer Benadryl. Better alternatives already exist. Is this a child that would potentially be unnecessarily injected with epinephrine by some provider? I urge you to please reconsider or fine tune this potential EpiPen mandate without these risks and costs. Thank you.

CommentID: 238120