Fewer than half of the District's public and charter schools had fully approved plans in place this spring to handle life-threatening student medical emergencies like severe allergic reactions, asthma attacks and dangerously low blood sugar, according to a new government watchdog report. Of 246 schools required to have the plans, only 113 had received full approval as of late April, while 120 were still listed as pending and 12 were sent back for revisions.
The findings come from a formal Management Alert Report issued by the Office of the District of Columbia Auditor, which found the Office of the State Superintendent of Education (OSSE) out of compliance with the District's 2023 Access to Emergency Medications Amendment Act, according to WTOP News. The 2023 law, which took full effect for the 2025–2026 school year, requires D.C. public schools to store medications for emergencies including low blood sugar, bee stings and asthma attacks, WTOP reports. It expanded on earlier rules that only mandated epinephrine, adding requirements for undesignated albuterol and glucagon, according to DC Health. According to the Council of the District of Columbia, D.C. Law 22-168 was the "Access to Emergency Epinephrine in Schools Clarification Amendment Act of 2018," providing an earlier legislative backdrop for the District's broader emergency-medication requirements.
A Dispute Over Who Is Actually Responsible
At the center of the story is a disagreement over accountability. D.C. Auditor Kathy Patterson said OSSE is responsible for ensuring compliance while DC Health handles training and certification of school staff, per the WTOP report. She went further, calling the disagreement over who owns the problem “a little bit scary,” and said schools simply need to ensure their emergency medication plans are actually in place.
OSSE, for its part, pushed back on that framing. The agency described emergency medication readiness as a shared responsibility spread across OSSE, DC Health and the schools themselves, per the same WTOP account, and said the auditor's numbers amount to a point-in-time snapshot of what is really a multi-step administrative process. According to OSSE, most schools flagged as incomplete already have approved plans on file and are simply working through DC Health's training and certification process for designated staff. Antoinette Mitchell, referenced in the same report, disagreed with the idea that OSSE alone is responsible for compliance.
Why the Training Pipeline Is Bottlenecked
The law requires every school to designate at least two staff members certified through DC Health's Administration of Medication (AOM) program who are available throughout the school day, and DC Health rules explicitly bar school health suite nurses from counting toward that two-person minimum, according to the Office of the District of Columbia Auditor. That requirement pushes the training burden onto regular teachers and staff rather than medical personnel, since nurses are excluded from the count even when they're on campus.
Complicating matters, DC Health discontinued a shorter, EpiPen-only training course before the 2025–2026 school year, requiring staff to instead complete the longer, multi-module AOM program to get certified, as reported by East of the River. Parent advocates testified to the D.C. Council that scrapping the abbreviated course created new barriers for teachers otherwise willing to administer emergency allergy shots. DC Health certified 769 people during the last school year, per the WTOP report, though the volume of new training required under the expanded law appears to have strained the pipeline. According to the Department of Health's FY 2025 Performance Accountability Report, the agency included training materials for certified school personnel during the fiscal year.
Stipends and Budget Dollars Behind the Mandate
To help close the gap, District of Columbia Public Schools set up a one-time $600 stipend for staff who complete or recertify AOM training, provided they formally commit to serving in that role for the school year, according to DCPS. The idea is to offset staff reluctance to take on the added medical responsibility that comes with the certification.
The mandate itself came with real money behind it: the D.C. Council Committee on Health allocated $757,386 in recurring fiscal year 2025 funding to fully implement the Access to Emergency Medications Amendment Act, alongside a separate $1.41 million boost for the District's broader School Health Services Program. District public schools submitted plans for 245 of 246 schools by late April, per WTOP's reporting, though Washington Latin PCS's Anna Julia Cooper Campus high school did not submit an emergency medication plan, according to the same report.
What Happens Next
For the 2026–2027 school year, OSSE has set a September 11 deadline for public and charter schools to submit their annual Undesignated Emergency Medications Action plans through its Quickbase application, requiring details on designated liaisons and certified staff. The auditor's alert report also recommended OSSE determine whether it needs additional sanction authority to enforce compliance, and propose legislative or regulatory changes if current oversight tools prove insufficient, according to the Office of the District of Columbia Auditor.
The compliance fight is also unfolding against a backdrop of rising administrative spending in D.C.'s education bureaucracy. A March 2026 study commissioned by the D.C. Auditor found that total administrative and leadership costs across OSSE and the Deputy Mayor for Education reached an estimated $91.8 million annually, a figure examined as part of a broader look at governance structures in mayoral-controlled education agencies.
Medical protocols under the law also draw a distinction schools must navigate carefully: undesignated albuterol and epinephrine can be given to any student during a life-threatening emergency without a prior diagnosis, but undesignated glucagon may only be administered to students who already have a documented diabetes diagnosis on file with the school, according to DC Health guidelines. That distinction underscores why officials say the stakes of getting certification and training right extend well beyond a paperwork exercise.
