Child with nebulizer over their nose and mouth being embraced by adult

Incidental Medical Services (IMS) in Child Care Programs

The Americans with Disabilities Act (ADA), the California Unruh Civil Rights Act, and the California Disabled Persons Act protect children and adults with disabilities. These laws apply to Child Care Centers (CCCs) and Family Child Care Homes (FCCHs). CCCs and FCCHs must make reasonable accommodations for children with disabilities and special health care needs. Your child care program may be asked to safely give medications or provide other types of care, such as blood glucose testing or gastrostomy tube (g-tube) feedings. These services are called Incidental Medical Services (IMS).

California Community Care Licensing Division released Provider Information Notice PIN 22-02-CCP in February 2022. PIN 22-02-CCP describes what needs to be in place to safely give IMS in licensed child care programs. 

Your Program’s IMS Plan  

Your IMS Plan describes the kinds of services you are prepared to give and the steps you will take to do it safely. Your IMS Plan is part of your Plan of Operation. The IMS Plan needs to be written, kept up-to-date, and submitted to your Regional Licensing Office.  It also needs to be available for staff to read. Your program’s IMS Plan should include:

The types of IMS you provide, for example:

  • Blood glucose testing
  • Insulin administration
  • Inhaled medications administration, such as for asthma
  • G-tube feeding and care
  • Other medical orders provided by the child’s primary care provider
  • Emergency IMS:
    • Glucagon administration
    • Epinephrine auto-injector administration
    • Anti-seizure medication administration

The forms you will use, for example:

How you will store medicines and supplies out of children’s reach. Include how you:

  • Receive medications
  • Store medications
  • Return unused and expired medications

Your staffing plans:

  • One or more trained staff members must be present when a child who needs IMS is in care, even when on field trips.  
  • Ask the child’s health care provider what kind of training is needed.
  • Keep proof of training on-site.
  • Provide training for new and substitute staff who provide care for a child with special health care needs.  

Your hygiene and sanitation practices:

  • Wash hands before and after giving medication.
  • Use standard precautions when handling blood: wash hands, wear gloves, clean and disinfect surfaces.
  • Store needles and other hazardous waste in special “sharps” containers.
  • Dispose of “sharps” containers according to local hazardous disposal rules.

The records you will keep:

  • Keep a record of when a staff member gives IMS or notices unusual signs or symptoms.  
  • Share the records with the child’s family.  

What to do in an emergency:

  • Work with a child’s family and health care provider to identify their emergency signs and symptoms and what to do in an emergency. Include this information in the child’s special health care plan.
  • Immediately after providing emergency IMS, call 9-1-1, then notify the family.
  • Fill out an Unusual Incident/Injury Report (LIC 624 for CCC, LIC 624B for FCCH). Submit it to your CCL Regional Office.
Your Program’s Disaster Plan

In addition to developing and updating your IMS Plan, you will need to update your Disaster Plan. Include how children who need IMS will be cared for, even during an emergency or disaster situation. Make plans to take medication and supplies with you in case of evacuation.  

Children’s Special Health Care Plans

Develop special health care plans for children who need IMS. Work with the family and their health care provider to develop a special health care plan.  Having a detailed plan that is specific to an individual child will help you keep them healthy and safe.
The special health care plan describes the unique needs of a child with a disability or a special health care need. Include:

  • A statement from the child’s health care provider with the kind of care the child needs and the kind of training child care staff need.
  • Written parent consent for each staff member trained to give the care needed.
  • The supplies you will need.
  • When and how to give care, including medications.
  • Who is trained to give care.
  • The child’s symptoms in an emergency.  
  • What to do in an emergency.
  • When and how to contact the child’s family.
  • When and how to contact the child’s health care provider.

 February 2023, UCSF California Childcare Health Program