I am writing to express my opposition to the use of a fast-track process for this regulatory change. This amendment represents a significant shift for child care providers, yet it is being advanced without sufficient time for meaningful review, feedback, or preparation. My organization has heard widespread concerns from providers about their ability to implement, afford, and remain compliant with this new requirement, with some expressing serious fears that it could ultimately force program closures.

While I support the underlying goal of protecting children’s health and safety, substantial concerns remain including the initial and ongoing costs of medications and supplies, challenges related to access and storage, and the operational and logistical processes necessary to maintain compliance. In addition, there are significant insurance and liability implications that will require considerable time and coordination to address.

Given the scope and impact of this change, I believe this regulatory action should proceed through the standard NOIRA process to ensure adequate transparency and preparation time. Advancing this proposal through a fast-track process limits meaningful input and risks placing additional and unnecessary strain on child care providers and the families they serve.