Q. Who should be notified when epinephrine is administered? 
A. Administration of emergency epinephrine should be reported to school administration, school health personnel, and the student’s parent/guardian in accordance with district policies. Refer to page 15 in the Guidelines for Managing Allergies and Anaphylaxis in Schools.

Patient specific

Q. What is required for a student to be considered ‘independent’ and able to self-carry and self-administer their own epinephrine?
A. For a student to be considered ‘independent’ and able to self-carry and self-administer their own epinephrine, the school must be provided with a health care provider order and an attestation along with written parent/guardian consent. The attestation by the health care provider confirms the following:

1. the student’s diagnosis of an allergy for which epinephrine is necessary; and
2. the student has demonstrated that they can self-administer the prescribed epinephrine effectively.  See the Guidelines for Medication Administration in Schools and the Guide to Determining Levels of Assistance in Medication Delivery.

Q. What should a school nurse (RN) do if they receive a patient specific order for epinephrine, but the parent/guardian does not supply the emergency medication? 
A. If the parent/guardian fails to supply the emergency medication for a student, the student should not be excluded from school or school-sponsored activities. If the school does not have non-patient specific orders from the district’s medical director permitting the school nurse to administer emergency epinephrine, the school should communicate in writing to the parent/guardian that, in the absence of the medication, emergency medical services (EMS) will be called per district policy.  The district’s director of school health services (a.k.a., medical director) or school nurse should also communicate this information to the prescriber.

Schools should be cognizant of the financial constraints a family may face in obtaining the medication.  Information on obtaining health insurance or reduced cost medications from manufacturers should be provided in order to ensure the safety of their child while at school.

If all attempts to have the parent/guardian provide the medication fail, the school may need to consider notifying Child Protective Services (CPS).  Refer to page 31 in the Guidelines for Medication Administration in Schools.

Non-patient specific

Q. Who can follow non-patient specific orders for epinephrine administration?
A. Non-patient specific orders can only be followed by school nurses (RNs).
For details, see the Options Chart for Administration of Epinephrine in Schools. 

Q. May an LPN administer emergency epinephrine under a non-patient specific order from a medical director?
A. No. An LPN cannot administer emergency epinephrine under a non-patient specific order. LPNs cannot administer any medication under a non-patient specific order.  LPNs may only administer emergency epinephrine following a patient-specific order or as directed by an RN, the medical director, or other appropriate licensed health professional (e.g., PA, NP). (Assuming the LPN is appropriately trained and competent to provide the service.) 

Q. Can a school nurse (RN) administer epinephrine to any person experiencing signs and symptoms of anaphylaxis at school or school-sponsored events under a non-patient specific order from a medical director?
A. Yes, a school nurse (RN) can administer epinephrine to any person experiencing signs and symptoms of anaphylaxis at school or school-sponsored events under a non-patient specific order from a nurse practitioner or physician.

Q. Can a school medical director order a second dose of epinephrine in their non-patient specific order for school nurses?
A. Yes, a school medical director can order a second dose of epinephrine when writing a non-patient specific order for the school nurse (RN).

Q. Does the school nurse (RN) need to take the approved NYSDOH/NYSED training to administer epinephrine under a non-patient specific order?
A. No, a school nurse (RN) does not need to take the NYSDOH/NYSED training to administer a non-patient specific order of epinephrine. The RN's scope of practice permits the administration of medications in accordance with a provider order.

Q. How can the district obtain epinephrine auto-injectors for use at school?   
A. A school district may obtain epinephrine auto-injectors for use at school by obtaining a non-patient specific order for epinephrine from their director of school health services (medical director) or from a NYS licensed physician or nurse practitioner. The order may be submitted directly to a medical supply company, local pharmacy, or the EPIPEN4SCHOOLS program.

Q. How often do schools need to check the epinephrine expiration date and the location security?
A. Schools storing student and stock medications should have a method to track the expiration dates of medication.  The tracking method should be clearly outlined in the school‘s health services policies and protocols. The expiration date of the epinephrine may be entered on the student’s Medication Administration Record (MAR) or the NYSCSH’s Medication Expiration Tracking Tool may be used.

A stock epinephrine auto-injector (EAI) may be stored with the automatic external defibrillator (AED), and the EAI expiration date may be entered on the daily NYSCSH’s Epinephrine-AED Maintenance Checklist.

Q. Is there a document available to monitor epinephrine location, type, dose, and expiration date?
A. NYSCSH created a Sample Epinephrine Auto-Injector Log, which is found on our Samples I Forms page and may be modified and utilized by school districts.

Q. Must students provide two doses of epinephrine for use at school?
A. There is no requirement for a student’s parent/guardian to provide a second dose of epinephrine to the school unless the provider order requires a second dose.

Guidelines I Memos I Laws
Guidelines for Managing Allergies and Anaphylaxis in Schools (NYSED 4/2024)
Guidelines for Medication Management in Schools (NYSED 10/22)

Education Law Article 19
§921 - On-site epinephrine auto-injectors
§921-a - Training of unlicensed school personnel to administer certain medications.

Education Law Article 139 §6909

Commissioner’s Regulations
Commissioner's Regulations CR 136.6-Authorized Use of Epinephrine Auto-Injector
Commissioner's Regulations CR 136.7-Self-administration of Certain Medications by Students

Public Health Law 3000c Epinephrine Auto-injectors 

Epinephrine Resource Page
    Options Chart for Administration of Epinephrine in Schools (NYSCSH 8/2024)

Medication Resource Page
    Guide to Determining Levels of Assistance in Medication Delivery (NYSCSH 7/23)

Samples I Forms

Hazardous Waste Resource Page - Disposal of Medications 

Q. How does stock epinephrine need to be stored? 
A. Schools that have chosen to stock emergency medications allowed by state laws (epinephrine auto-injectors and opioid antagonists) should store these medications in a manner specified in the laws and regulations governing their use. Stock emergency medications should be stored in a secure location that is readily accessible to unlicensed trained school personnel. AED cabinets are commonly used since the AEDs need to be checked at the same frequency as the medications are to be inventoried, are centrally located, and can be secured with plastic break away locks are recommended to be used. For details, see page 43 in the Guidelines for Medication Administration in Schools.

Q. Can bus drivers administer epinephrine via auto-injector to a student with a patient specific order?
A. Trained unlicensed school personnel or contractors of the school, including bus drivers, may be trained to administer epinephrine via auto-injector to a student with a patient specific order in accordance with Commissioner’s regulation section 136.7. For details, see page 24 in the Guidelines for Medication Management in Schools. The trained unlicensed school personnel should receive a copy of the ECP and know the location of the epinephrine auto-injector (e.g., student’s backpack).

Q. What are the requirements a school district must have in place to permit trained unlicensed school personnel to administer stock epinephrine via auto-injector to students and staff having anaphylactic symptoms in a school building?
A. The requirements to permit trained unlicensed school personnel to administer stock epinephrine via auto-injector to students and staff having anaphylactic symptoms include:

• Development of a policy regarding possession and use of epinephrine auto-injectors pursuant to Public Health Law §3000-c and Education Law §921 which includes the mandated training regarding responding to anaphylaxis;
• Written district policy on calling for emergency transport or 911, including which school personnel will accompany the student until the parent/guardian is present;
• Evaluation, review, and periodic revision of policy, protocols, and procedures as necessary to keep them up to date with current best practice;
• Identification of school personnel roles and responsibilities;
• Identification and provision of professional development and education for both licensed and trained unlicensed school personnel;
• Training of unlicensed school personnel on preventing and responding to anaphylaxis. Training can be conducted by a nationally recognized organization experienced in training laypersons in emergency health treatment or through the NYSDOH approved course. Training shall include how to recognize signs and symptoms of severe allergic reactions, including anaphylaxis, recommended dosage for adults and children, standards and procedures for the storage and administration of an epinephrine auto-injector and emergency follow-up procedures;
• Sending a notification, at least once per calendar year, to the parents/guardians of all students to make them aware of the anaphylactic policies and informational materials in this document pursuant to Public Health Law Article 25 §2500-h(2)(f); and
• Schools must provide teachers written informational material on the use of an epinephrine auto-injector that is created and approved by the Department of Health. The NYSDOH materials are not available yet.  In the interim, schools are encouraged to use information from the manufacturer's website to be provided to teachers. The manufacturer information can be found on the Epinephrine Resource page.

Q. Who trains unlicensed school personnel to administer stock epinephrine auto-injectors to students or staff having anaphylactic symptoms in a school building? 
A. Schools choosing to train unlicensed school personnel to administer emergency epinephrine via auto-injector must use training approved by the NYS Department of Health (NYSDOH). A free NYSDOH approved training webinar titled Managing Allergies and Anaphylaxis at School: Training for School Personnel, a post-test, and a skills training checklist are available on the NYS Center for School Health website.

Q. Who trains unlicensed school personnel to administer epinephrine to a student with a patient specific order?
A. Education Law §921 requires that unlicensed personnel are trained by an RN, NP, PA, or physician to administer epinephrine via auto-injector to a student with a patient specific order. This training, and ECP review, must be completed annually.

Pursuant to Commissioner's regulation 136.7(f)(1), training must include:

• Identification of the specific allergen(s) of the student(s), including review of each student’s emergency care plan if available;
• Signs and symptoms of a severe allergic reaction warranting administration of epinephrine;
• How to access emergency services per school policy;
• The steps for administering the prescribed epinephrine auto-injector;
• Observation of the trainee using an epinephrine auto-injector training device;
• Steps for providing ongoing care while awaiting emergency services;
• Notification of appropriate school personnel;
• Methods of safely storing, handling, and disposing of epinephrine auto-injectors

For details, see pages 24-25 in the Guidelines for Medication Management in Schools.

Q. Can unlicensed trained school personnel administer Neffy®?
A. No, unlicensed trained school personnel cannot administer Neffy®. Education Law §921 only allows unlicensed trained school personnel to administer epinephrine via auto-injector.
Neffy® can only be administered by an RN and an LPN under the direction of an RN.

Patient specific

Q. Can trained unlicensed school personnel administer epinephrine via auto-injector to a student with a patient specific order at school, on school property or transportation, and at any school-sponsored event?
A. Yes, appropriately trained unlicensed school personnel can administer epinephrine via auto-injector to a student with a patient specific order at school, on school property or transportation, and at any school-sponsored event. See page 24 in the Guidelines for Medication Administration in Schools for details on the training requirements.

Q. Can trained unlicensed school personnel administer a second dose of epinephrine via auto-injector to a student with a patient specific order if the student's symptoms do not improve?
A. Yes, appropriately trained unlicensed school personnel can administer a second dose of epinephrine via auto-injector if the health care provider order states the student is to receive more than one dose of epinephrine within a specified time frame.  This would be in accordance with the student’s health care provider order and emergency care plan (ECP) and occur while awaiting emergency medical services transportation.

Non-patient specific

Q. Can trained unlicensed school personnel administer stock epinephrine via auto-injector to a student or staff member outside of a school building or off school grounds (e.g., field trips)? 
A. No. Trained unlicensed school personnel cannot administer non-patient specific (stock) epinephrine via auto-injector to a student or staff member outside of a school building or off school grounds (e.g., field trips).   Education Law Article 19 §921-a limits trained unlicensed school personnel to administration of epinephrine via auto-injector to students or staff having anaphylactic symptoms in school buildings only.

Q. Can trained unlicensed school personnel administer a second dose of stock epinephrine via auto-injector if the student/staff symptoms do not improve?
A. Yes, trained unlicensed school personnel can give a second dose of stock epinephrine via auto-injector if the student/staff symptoms do not improve in accordance with Public Health Law §3000-c training and according to the district policy and protocol. Emergency medical services must be called after the first dose is administered.