Thank you for the opportunity to provide feedback on the proposed fast-track, regulating child day centers to implement policies for the possession, storage, and administration of stock epinephrine auto-injectors. This proposal imposes unnecessary financial strain, and risks to the providers.

There are existing regulations and practices that protect children with known allergies.  The stock epinephrine requirement duplicates those safeguards. The rare undiagnosed cases are better handled by medical professionals via calling 911 as already mandated.

Epinephrine is a powerful prescription drug, requiring clinical assessment to avoid misuse, such as over-administration or incorrect dosing. Asking non-medically trained staff to make split second decisions on undiagnosed symptoms could expose staff, centers, and families to legal liability and put children at risk. This could potentially harm rather than help children.

The financial burden, especially in the current economic climate, will divert funds from essential areas like staff wages, facility improvements or expanded access for low-income families, exacerbating inequities in childcare availability.

The current system for diagnosed children fosters strong partnerships between families, physicians and providers. Very specific plans are implemented to ensure providers understand specific indicators for specific children.  For the rare undiagnosed cases, a call to 911 and basic life support suffice until EMS arrives. I am in support of additional training in recognizing the signs of anaphylactic reactions and when to call 911. 

Fast track regulating such a divisive update can lead to high risks such as program closures and reduced enrollment in underfunded areas. Following a standard process would allow time to explore cost offsets, pilot programs and ensure safe protocols.  I strongly urge the VDOE to withdraw from this fast-track consideration and commit to inclusive, evidence-based revisions.

I appreciate the VDOE's commitment to the safety of children and am hopeful that the voices of the one's with boots on the ground will be strongly considered.

Thank you for your consideration,

Stacy Bermo-Program Director HoneyTree Early Learning Centers