| 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 |
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My name is Andrea Cotman and I am writing as a licensed child care provider in Arlington, Virginia to voice my concerns about the proposed requirement that childcare providers stock epinephrine auto-injectors. While I am committed to child safety, I have serious reservations about this mandate.
First, the financial burden is significant. EpiPens are expensive and must be replaced regularly. Training requirements for all staff members add additional costs. For small providers like myself, these expenses are difficult to manage without raising tuition rates for families.
Second, I do not have medical training to diagnose anaphylactic shock or determine when
epinephrine is needed, especially for children without known allergies. I fear making incorrect medical decisions that could harm a child. The potential complications from accidental injection or unnecessary administration are frightening. The liability exposure could result in a lawsuit and put an end to my 18-year-old business.
I strongly suggest you reconsider this mandate and instead work with providers on practical alternatives, such as requiring parents of children with known allergies to provide prescribed EpiPens and ensuring rapid emergency response. Thank you for considering my perspective.