Stock epineprhine IN SCHOOLs TOOLKIT
Standing Order and Protocol
Undesignated Stock Epinephrine
MN Statute 121A.2207 Life-Threatening Allergies in Schools: Stock Supply of Epinephrine Delivery Systems
Subdivision 1. Districts and schools permitted to maintain supply.
Notwithstanding section 151.37, districts and schools may obtain and possess epinephrine delivery systems to be maintained and administered by school personnel to a student or other individual if, in good faith, it is determined that person is experiencing anaphylaxis regardless of whether the student or other individual has a prescription for an epinephrine delivery systems. The administration of an epinephrine delivery system in accordance with this section is not the practice of medicine.
(b) Registered nurses may administer epinephrine delivery systems in a school setting according to a condition-specific protocol as authorized under section 148.235, subdivision 8. Notwithstanding any limitation in sections 148.171 to 148.285, licensed practical nurses may administer epinephrine delivery systems in a school setting according to a condition-specific protocol that does not reference a specific patient and that specifies the circumstances under which the epinephrine delivery system is to be administered, when caring for a patient whose condition falls within the protocol.
Subd. 2. Arrangements with manufacturers.
A district or school may enter into arrangements with manufacturers of epinephrine delivery systems to obtain epinephrine delivery systems at fair-market, free, or reduced prices. A third party, other than a manufacturer or supplier, may pay for a school's supply of epinephrine delivery systems.
Subd. 3. Standing order for distribution and condition specific protocol.
The commissioner of health must provide a district or school with a standing order for distribution of epinephrine delivery systems under sections 148.235, subdivision 8; and 151.37, subdivision 2.
This statute allows for but does not require schools to stock and administer an undesignated epinephrine delivery system for life-threating allergies.
Standing Order for Distribution
A standing order for distribution of epinephrine is required for Minnesota schools to obtain undesignated stock epinephrine delivery systems from a vendor who can dispense prescription medication. A licensed prescriber cannot write a prescription for a “school” or “district”. By law, prescriptions are patient specific (MN Statute 151.01 Definitions, Subd. 16a. Prescription). Therefore, schools as entities require a standing order for distribution for undesignated stock epinephrine medication. Schools may be distributed to but not prescribed to.
Condition Specific Protocol
Condition specific protocols are required for nurses (RN and LPN) administering undesignated stock epinephrine delivery systems and a best practice recommendation for all school personnel. The condition specific protocol is an essential component of the over all emergency response plan developed to address life threatening allergic reactions.
148.235, Subd. (8) Prescription by Protocol allows RNs to implement a protocol that results in a prescription of legend (prescription) drugs for administration, including epinephrine, based on conditions (as opposed to being based on specific patients).
Subd. (8). Prescription by Protocol states, “A registered nurse may implement a protocol that does not reference a specific patient and results in a prescription of a legend drug that has been predetermined and delegated by a licensed practitioner as defined under section 151.01, subdivision 23, when caring for a patient whose condition falls within the protocol and when the protocol specifies the circumstances under which the drug is to be prescribed or administered.”
MN Statute 121A.2207 Life-Threatening Allergies in Schools: Stock Supply of Epinephrine Delivery Systems allows LPNs working in the school setting, to implement a protocol that results in the administration of an undesignated stock epinephrine delivery system.
Subdivision 1. Districts and schools permitted to maintain supply states, “(b) Registered nurses may administer epinephrine delivery system in a school setting according to a condition-specific protocol as authorized under section 148.235, subdivision 8. Notwithstanding any limitation in sections 148.171 to 148.285, licensed practical nurses may administer epinephrine delivery systems in a school setting according to a condition-specific protocol that does not reference a specific patient and that specifies the circumstances under which the epinephrine delivery system is to be administered, when caring for a patient whose condition falls within the protocol.”
Therefore, the nurse (RN/LPN) must follow a condition specific protocol for anaphylaxis to administer undesignated stock epinephrine. The Guidance for an Anaphylaxis Protocol in a School Setting further explains the nursing practice rationale behind the need for a condition specific protocol.
MDH Statewide Standing Order and Condition Specific Protocol
During the 2025 first special legislative special session, MN Statute 121A.2207 was amended by Chapter 10, Article 8, Section 3, requiring the commissioner of health to provide a district or school with a standing order and condition specific protocol for stock epinephrine delivery systems.
Subd. 3. Standing order for distribution and condition-specific protocol.
The commissioner of health must provide a district or school with a standing order for distribution of epinephrine delivery systems under sections 148.235, subdivision 8; and 151.37, subdivision 2.
Registering for the MDH Statewide Standing Order and Condition Specific Protocol
MDH offers a statewide standing order and condition specific protocol for undesignated stock epinephrine auto-injectors (EPI PEN brand) and nasal atomizer (neffy brand). MDH’s standing order and condition specific protocol only authorizes these two epinephrine delivery systems because these brands are supplied through manufacturer-sponsored free epinephrine programs and for their widespread use in school districts. Schools may request to use the undesignated epinephrine standing order for distribution and condition specific protocol by completing the Minnesota Undesignated Stock Epinephrine Standing Order and Condition Specific Protocol Registration and Renewal Form for Schools.
Please note: Only schools that employ nurses may register for the Statewide Standing Order and Condition Specific Protocol as this standing order and protocol only provides authorization for nurses.
This registration form ONLY provides the standing order for distribution and condition specific protocols. Schools will still need to procure the epinephrine delivery systems by purchasing through a local pharmacy or school health vendor or utilize one of the programs that offer free epinephrine delivery systems for school stock epinephrine programs.
Standing Orders and Protocols from Local Providers
Many schools have a relationship with a licensed prescriber and have already maintain a supply of epinephrine and only need a condition specific protocol. These resources may help you work with a local provider to sign a standing order and condition specific protocol.
Templates for a standing order and condition specific protocol for both epinephrine auto-injector and nasal atomizer neffy® have been developed.
Epinephrine auto-injector Condition Specific Protocol Template for the School Setting
neffy® Condition Specific Protocol Template for the School Setting
Schools choosing to use these templates must understand that the criterion in the template includes indications, contraindications, and side effects for administering epinephrine auto-injector or nasal atomizer. However, the criteria must be reviewed and further defined according to the licensed prescriber’s parameters who is authorizing by their signature. Additional criteria and prescribed actions may be necessary. The prescribed actions are examples and may not suit your school situation and may not include all possible actions. A licensed prescriber must review the criteria and actions and determine the appropriate action to be prescribed.
Please note: It is recommended that standing orders for distribution and the condition specific protocols be reviewed annually.