Willowcreek Academy

Excellence in Early Childhood & Education

Willowcreek Academy

6100 Redwood Square Ctr.

Centreville, Virginia 20121

703-815-3000

willowcreekacademycentreville@gmail.com

November 20, 2025

To Whom It May Concern,

I am writing to provide public comments on the proposed regulatory changes related to the possession and administration of stock or undesignated epinephrine in licensed child day centers and family day homes. While I appreciate the intention to enhance child safety on a broad level, I have significant concerns regarding the expectations these changes would place on childcare providers.

1. Expectations for childcare staff to diagnose an allergic reaction. The proposed regulations would require staff who are not trained professionals to determine whether a child is experiencing an allergic reaction or anaphylaxis. Diagnosing the cause and severity of symptoms is a medical responsibility and requires clinical expertise. Placing this burden on childcare staff increases the risk of misdiagnosis delayed treatment, or unnecessary administration of medication, which may cause harm.

2. Requirements for non-medical personnel to administer the correct medication and weight-based dosage. Administering epinephrine, particularly determining, or selecting an appropriate weight-based exceeds the scope of typical childcare training. Epinephrine is a prescription medication with serious medical implications, and its administration should be directed by a licensed prescriber or clearly outlined in an individualized care plan or FARE form. Currently, FARE (Allergy & Anaphylaxis Emergency Care Plan), are required to be completed and signed by a licensed healthcare provider. This plan gives specific, individualized instructions for when and how to administer epinephrine for each child. Expecting staff to make these decisions without physician specific guidance created unnecessary risk for both children and providers.

3. Legal liability for administering prescription medication without parental or physician consent. The proposed changes require administration of epinephrine without prior parent or physician authorization. This created significant legal and ethical liability for childcare centers and staff. Administering a prescription drug without consent, even with positive intentions, could expose staff and childcare centers to complaints, legal action, or violations, which would undermine established standards for medication administration in childcare settings.

For these reasons, I respectfully urge the Department of Education to reconsider or revise the proposed regulations to ensure that childcare providers are not placed in positions that require medical judgement or carry unreasonable legal risks. Clearer guidance, stronger protection, and increased reliance on individualized health plans & FARE forms would better support both child safety and realistic practice in early childhood settings.

Thank you for the opportunity to provide input on this important matter. I welcome continued discussion and collaboration to support the well-being of all children in care.

Sincerely,

Samira Jouhar

Program Director