Management Plans for Food Allergy and Glycogen Storage Disease
The CSDE and the DPH recommends that districtwide management plans for food allergy and GSD focus on safety, prevention, education, awareness, communication and emergency response. Management plans should strike a balance between the education, health, social normalcy and safety needs of the individual student with life-threatening food allergies and GSD and the education, health and safety needs of all students. Management plans for food allergy and GSD should be the basis for the development of procedural guidelines that will be implemented at the school level and provided for consistency across all schools within the district.
The goals for districtwide management plans for food allergy and GSD include:
- maintaining the health and protecting the safety of children who have life-threatening food allergies and GSD in ways that are medically-accurate, developmentally-appropriate, promote self-advocacy and competence in self-care and provide appropriate educational opportunities;
- ensuring that interventions, action plans and IHCPs for students with life-threatening food allergies and GSD are based on medically accurate, developmentally-appropriate information and evidence-based practices; and
- defining a formal process for identifying, managing and ensuring continuity of care for students with life-threatening food allergies and GSD across all transitions (PK through Grade 12).
Process for Development of Districtwide Management Plan for Food Allergy and GSD
The process for developing or revising management plans for food allergy and GSD is as important as the final product – the plan. Districtwide implementation requires a team approach with appropriate representation from schools, families, health professionals and the local community. Consensus should therefore be grounded in medically appropriate, research-based interventions, as well as best practices based on local district needs and the special health care needs of children with life-threatening food allergies and GSD.
The districtwide team works to develop, implement, monitor, review and revise the management plan for life-threatening food allergies and GSD effectively. Team members may include:
- school superintendent or designee
- building principal or designee
- school nurse supervisor or school nurse
- school medical adviser
- teacher representative
- parent representative
- student representative
- other school staff (e.g., school psychologist or counselor)
- school medical adviser
- school food service director or representative
- transportation coordinator
- supervisor of custodial staff
- community health care provider(s), e.g., pediatrician, APRN, dietitian, nutrition or health consultant, local EMS representative
- national and local experts
Before developing the plan, the district team should review the district’s policies and protocols regarding the care of students with life-threatening food allergies or GSD, students’ needs and then identify areas that need development or improvement.
An effective plan should be brief and provide the overarching goals for the district regarding the care of students with life-threatening allergies and GSD. This district plan should include:
- the rationale for the plan;
- a commitment to planning and prevention;
- a collaborative process;
- a formal process for identifying and developing IHCPs and action plans for emergencies (such as, anaphylaxis or hypoglycemia);
- the provisions for education and training;
- a balance between individual, school and community needs; and
- fostering normal development.
Important Issues in the Development of Management Plan for Food Allergy and GSD
The following issues related to planning for students with life-threatening food allergies and GSD have districtwide implications. The purpose of this section is to explain the issues, suggest ways to address them based on successful practices in school districts and provide resources for further information.
1. Banning of Specific Foods
School districts must implement a Food Allergy Management Plan to address the needs of students with life-threatening food allergies. Schoolwide bans of specific foods may not render the school environment safe because there is no method for ensuring that the allergenic food does not inadvertently enter school grounds. Bans can create a false sense of security, which can lead to less responsible approaches to effective management strategies, education and emergency responses. Banning offending foods detracts from the schools’ responsibility to plan properly for children with life-threatening food allergies and to educate all school personnel accordingly. It may also limit the opportunity to teach children with allergies to take care of themselves in environments where they may be exposed to allergens at any time. Additionally, banning can be problematic in terms of defining the limits. While it may mean the banning of peanuts for some students, will it also mean the banning of all nuts, milk or another food item for other students? School districts need to consider how to develop a plan that over time will best meet the needs of all students and prepare them for self-management and advocacy as they transition within and beyond PK through Grade 12. School options may include establishing allergen free zones, such as a child’s individual classroom, allergen free lunch table(s) or areas in the cafeteria and food-free zones, such as libraries and music rooms, as well as enforcing relevant school policies, such as those that prohibit eating on the school buses. Individual student and family privacy needs and preferences should be considered in determining appropriate plans. Not all students or families will need or want to use an allergen-free zone during the school day.
Medication issues are best addressed within school district’s policy and administrative procedures that regulate medication practices.
Storage of Emergency Medications
Section 10-212a-5 (b) of the Regulations of the Connecticut State Agencies, require that all medications, except those approved for self administration, “shall be kept in a locked container, cabinet or closet used exclusively for the storage of medication…Except as otherwise determined by a student’s emergency care plan, emergency medications shall be stored in an unlocked, clearly labeled and readily accessible cabinet or container in the health room during school hours under the general supervision of the school nurse, or in the absence of the school nurse, the principal or the principal’s designee who has been trained in the administration of medication… Emergency medications will be locked beyond the regular school day or program hours, except as otherwise determined by a student’s emergency care plan…” Therefore, to promote rapid, life-saving steps in an emergency, emergency medications such as Epipens for anaphylaxis and Glucagon for hypoglycemia, should not be locked during the school day. While they must not be accessible to any student or unauthorized staff member, they should be kept in a safe, accessible and reasonably secure location that can be properly supervised by a nurse or other authorized and trained staff member.
The regulations also allow emergency medications to be shared with before- and after-school programs, however, parents are required to supply an extra set of emergency medications for availability during intramural or interscholastic activities. Responsible planning should be in place when are being shared among multiple school programs.
Location of Emergency Medications
The primary consideration for location of emergency medications should be the safety of students. Considerations for making responsible and reasonable decisions about location and safety include:
- general safety standards for handling and storage of medications;
- developmental stage of students;
- competence of the student;
- size of the school building;
- availability of a full time school nurse in the school building;
- availability of communication devices between school personnel (such as teachers, paraprofessionals) who are inside the building or outside on school grounds and the school nurse;
- school nurse response time from the health office to the classroom;
- preferences and other responsibilities of the teacher;
- preferences of the students and parent; and
- movement of the student within the school building.
School districts should then prioritize and determine which of the above items are the safest and most appropriate for teams to choose from when developing IHCPs and emergency care plans (ECP) for students who require assistance with the administration of emergency medications. Location of emergency medications when students have a self-administration medication order and plan is discussed below.
Self-administration of Medication
Section 10-212a-4 of the Regulations of the Connecticut State Agencies stipulates that Boards of Education must permit students who have a verified chronic medical condition and are deemed capable to self-administer prescribed emergency medication, including rescue asthma inhalers and cartridge injectors for medically-diagnosed allergies, to self-administer such medication and may permit such students to self- administer other medications, excluding controlled drugs (as defined in Section 10-212a-1 of the Regulations of the Connecticut State Agencies) provided that the following are in place:
- an authorized prescriber provides a written medication order including the recommendation for self-administration;
- a parent or guardian or eligible student provides written authorization for self-administration of medications;
- the school nurse has assessed the student’s competency for self-administration in the school setting and deemed it to be safe and appropriate including that a student:
- is capable of identifying and selecting the appropriate medication by size, color, amount, or other label identification;
- knows the frequency and time of day for which the medication is ordered;
- can identify the presenting symptoms that require medication;
- administers the medication appropriately;
- maintains safe control of the medication at all times;
- seeks adult supervision whenever warranted;
- cooperates with the established medication plan; and
Important Note: Students may self-administer inhalers for asthma and cartridge injectors for medically diagnosed allergies with only the written authorization of an authorized prescriber and written authorization from a student’s parent or guardian or eligible student (Section 10-212a-4 of the Regulations of the Connecticut State Agencies).
- in the case of inhalers for asthma and cartridge injectors for medically diagnosed allergies, the school nurse’s review of a student’s competency to self-administer inhalers for asthma and cartridge injectors for medically diagnosed allergies in the school setting must not be used to prevent a student from retaining and self-administering inhalers for asthma and cartridge injectors for medically diagnosed allergies.
- the school nurse has reviewed the medication order and parental authorization, developed an appropriate plan for self-administration, including provisions for general supervision and documented the medication plan in the student’s or participant’s health record;
- the principal and appropriate staff are informed that the student is self- administering prescribed medication; and
- such medication is transported by the student to the school and maintained under the student’s control in accordance with the board of education’s policy on self-medication by students and the individual student plan.
Self-administration of controlled medication, as defined in Section 10-212a-1 of the Regulations of the Connecticut State Agencies, may be considered for extraordinary situations, such as international field trips, and shall be approved by the school nurse supervisor and the school medical adviser in advance and an appropriate plan shall be developed.
When medication is required by students who have chronic health conditions, especially when medication may be life saving, it is best practice to encourage and assist students to become educated and competent in their own care. When self-administration is allowed, students should agree to keep their emergency medications on their person or immediately under their control and supervision at all times. This is for both the safety and the self-care education of the students. Emergency medications that are locked away in a locker or left in a backpack are not sufficiently accessible when the student is in another part of the building or outside on the playing grounds and may cause considerable delay in medication administration in a true emergency. In addition, students should be responsible for keeping control of their medication so that other students cannot access them and inadvertently harm themselves.
3. Section 504 of the Rehabilitation Act of 1973
Section 504 is a federal law designed to protect the rights of individuals with disabilities in programs and activities that receive federal financial assistance from the United States Department of Education (USDE). Section 504 provides in part that "No otherwise qualified individual with a disability in the United States . . . shall, solely by reason of her or his disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance . . ." Recipients of this federal financial assistance include public school districts, institutions of higher education, and other state and local education agencies. The regulations implementing Section 504 in the context of educational institutions appear at 34 CFR Part 104.
The Section 504 regulations require a school district to provide a "free appropriate public education" (FAPE) to each qualified student with a disability who is in the school district's jurisdiction, regardless of the nature or severity of the disability. Under Section 504, FAPE consists of the provision of regular or special education and related aids and services designed to meet the student's individual educational needs as adequately as the needs of nondisabled students are met (OCR, 2011).
Who Is Protected Under Section 504?
Section 504 covers qualified students with disabilities who attend schools receiving federal financial assistance. To be protected under Section 504, a student must be determined to: 1) have a physical or mental impairment that substantially limits one or more major life activities; or 2) have a record of such an impairment; or (3) be regarded as having such an impairment. Section 504 requires that school districts provide a FAPE to qualified students in their jurisdictions who have a physical or mental impairment that substantially limits one or more major life activities. Major life activities, as defined in the Section 504 regulations at 34 CFR 104.3(j)(2)(ii), include functions such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, and working. This list is not exhaustive. Other functions can be major life activities for purposes of Section 504. In the Amendments Act, Congress provided additional examples of general activities that are major life activities, including eating, sleeping, standing, lifting, bending, reading, concentrating, thinking, and communicating. Congress also provided a non-exhaustive list of examples of “major bodily functions” that are major life activities, such as the functions of the immune system, normal cell growth, digestive, bowel, bladder, neurological, brain, respiratory, circulatory, endocrine, and reproductive functions. The Section 504 regulatory provision, though not as comprehensive as the Amendments Act, is still valid—the Section 504 regulatory provision’s list of examples of major life activities is not exclusive, and an activity or function not specifically listed in the Section 504 regulatory provision can nonetheless be a major life activity.
Physical or Mental Impairment that Substantially Limits a Major Life Activity
The determination of whether a student has a physical or mental impairment that substantially limits a major life activity must be made based on an individual inquiry. The Section 504 regulatory provision at 34 CFR 104.3(j)(2)(i) defines a physical or mental impairment as any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genitourinary; hemic and lymphatic; skin; and endocrine; or any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities. The regulatory provision does not set forth an exhaustive list of specific diseases and conditions that may constitute physical or mental impairments because of the difficulty of ensuring the comprehensiveness of such a list. Whether students with life-threatening food allergies and GSD are identified under Section 504 as disabled individuals or not, school districts are required to provide students with IHCPs and action plans to address their health and safety needs.
Office of Civil Rights (OCR). (2011). Protecting Students with Disabilities: Frequently Asked Questions About Section 504 and the Education of Children with Disabilities. Retrieved on August 6, 2012.
The Food Allergy Network’s sample school policy
The Centers for Disease Control and Prevention’s Food-Safe School Needs-Assessment and Planning Guide