The mandate imposes a substantial and recurring financial strain, particularly on small, home-based family daycares which often operate on thin margins.
High and Recurring Cost: EpiPens are expensive, and their shelf life is typically only 12-18 months. Requiring the purchase of multiple, weight-appropriate doses (infant/child and adult) for a center with diverse age groups would necessitate an annual, unfunded expense that diverts limited resources away from core childcare needs, such as educational supplies, facility improvements, or provider wages.
Administrative Overhead: The mandate introduces new administrative responsibilities, including:
Rigorous monthly inspections to check expiration dates.
Secure, accessible, and compliant storage (e.g., maintaining a locked, yet immediately available, container).
Managing procurement and tracking replacements, which is a major diversion of time for a sole provider.
Epinephrine is a potent, prescription-only medication. Requiring non-medical staff to administer it to a child without a known diagnosis introduces significant liability and safety risks.
Lack of Clinical Expertise: Family daycare providers are childcare educators, not medical professionals. They lack the clinical training to accurately diagnose a severe, undiagnosed allergic reaction (anaphylaxis) versus other conditions that may present similar symptoms. Administering a strong drug unnecessarily carries its own medical risks.
Legal Exposure: Administering a prescription medication without a specific, physician-written order for that child exposes the provider to increased legal liability. While "Good Samaritan" laws exist in some jurisdictions, they may not offer full protection in a regulatory setting, especially when complex decisions regarding appropriate, weight-based dosage for an undiagnosed child are involved.
Redundant to Existing Protocols: For children with known allergies, existing regulations already require parents to provide patient-specific EpiPens, along with a physician-signed action plan and appropriate staff training. This targeted, parent-physician-provider collaboration is the safest model.
