As a Virginia child care provider, I am writing to express serious concerns regarding the proposed requirement that child care programs stock epinephrine.

Child care providers are already operating under significant financial strain. Rising food costs, staffing shortages, insurance increases, and regulatory requirements make it increasingly difficult to remain sustainable. The added expense of purchasing stock epinephrine, providing staff training, and replacing expired medication would place an additional financial burden on providers. Many programs operate on thin margins, and these costs would ultimately have to be passed on to families or could force providers to reduce enrollment or close entirely.

While the intent of this proposal is to protect children, it places child care staff in an uncomfortable and unrealistic position. Providers and teachers are not medical professionals, yet this mandate would require them to assess a medical emergency and administer a powerful medication without a prescription or individualized medical direction. Epinephrine can have serious side effects, and the risk of incorrect or unnecessary administration raises significant safety and liability concerns for providers.

I am also concerned about the legal and insurance implications of this requirement. Increased liability exposure may result in higher insurance premiums or the inability to obtain coverage at all. For many small child care programs, this could be devastating and further reduce the availability of quality child care in our communities.

The current system works effectively: families of children with diagnosed severe allergies supply prescribed epinephrine along with clear instructions from a medical professional. Providers are trained to recognize signs of allergic reactions and to call 911 immediately in an emergency. Strengthening emergency response procedures and training would be a more appropriate and sustainable approach than requiring providers to stock and administer medication.

I respectfully urge you to reconsider this mandate and work collaboratively with child care providers and families to develop solutions that prioritize child safety while recognizing the operational, financial, and professional limitations of child care settings.

Thank you for considering the perspective of those who provide care to children every day.