Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Child Care Program [8 VAC 20 ‑ 790]
Action Amend regulation to require each child day center that participates in the Child Care Program to implement policies for the possession and administration of epinephrine and each family day home provider or at least one other caregiver employed by such pro
Stage Fast-Track
Comment Period Ended on 12/17/2025
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12/12/25  10:00 am
Commenter: Daniel B. Kiddie Academy

Opposed to Epi Pen Requirement
 

Mandating providers to have epi pens on hand for students with undiagnosed allergies is a bad idea for a variety of reasons.

First, the burden on providers to diagnose anaphylactic reactions in non allergy students. There could be misdiagnosis, leading to unnecessary administration. 

Second, the cost of maintaining a variety of dosages and the upkeep required as epi pens have a short shelf life. Epi pens cost $650-$800 dollars for a two pack. Having to store just two different dosages would be a very high initial cost as well as replacements.

Third, the liability that providers would incur for providing medications to students without prescriptions nor written permission from parents. This is a significant liability for providers.

There are not enough pros to outweigh the cons for this law, especially one that is fast tracked.

CommentID: 238574