Agency of Education urges cardiac annex in school emergency plans, stops short of AED mandate

Agency of Education interim operations director Courtney O'Brien told the Health Education committee on March 12, 2025, that cardiac emergency response planning is incorporated in existing emergency operations plan guidance and recommended strengthening the state template rather than creating a separate prescriptive requirement for automated external defibrillators (AEDs).

O'Brien said the proposed bill H.247 "very closely resembles" parts of Act 29 of 2023 that require comprehensive emergency operations plans (EOPs) and local partner integration, but that Act 29 does not mandate equipment such as AEDs. "The emergency operations plan provisions of Act 29 do not require any sort of specific equipment, particularly not AEDs," O'Brien said.

The Agency of Education (AOE), working with the Vermont School Safety Center and Vermont Emergency Management, recommended adding a specific cardiac response annex to the existing EOP template and planning guide so schools can adopt standardized, evidence-based language without new, separate regulation. "Our teams will work with experts in the cardiac response field to ensure that best practices are captured in a format that is consistent with Vermont Emergency Management response planning and can be duplicated by a school or district," O'Brien said.

Why it matters: H.247 would set out requirements that schools and districts develop and maintain cardiac emergency response plans, assign staff responsibilities, coordinate with local emergency providers, and include training and annual plan review. The AOE testified that much of that work already fits inside the EOP framework required by Act 29 (now in Title 16) and that embedding cardiac annex guidance in the EOP template would avoid duplicative or conflicting rules while enabling schools to adopt consistent protocols.

Key points from testimony and questions

- Existing statutory and regulatory framework: O'Brien referenced Act 29 of 2023 (now in Title 16, sections cited in testimony), a Department of Health statute in Title 18 that requires schools that own and operate an AED to report it to the Department of Health and local ambulance providers, and Rule Series 5100 (licensing rules) that require CPR/AED certification for health and physical education teachers and licensed school nurses. The AOE also pointed to Title 16, section 212(18), which directs the secretary of education to inform superintendents and principals about resources for CPR and AED instruction.

- Training and technical support already provided: The AOE and Vermont School Safety Center said they have published an EOP planning guide and template, hosted an EOP webinar for independent schools on March 19, 2024, coordinated multiple REMS (Readiness and Emergency Management for Schools) day-long trainings (with one session rescheduled on Feb. 18, 2025, after low registration canceled the original date), and launched monthly office hours to help schools develop annexes, including cardiac response annexes. O'Brien said the AOE received a planning guide from the American Heart Association and plans to publish it as part of the resource package following March office hours.

- Local integration and exercise: Witnesses emphasized that stronger responses occur where schools have preexisting working relationships with local emergency partners. Annie Erickson, school safety program manager with the Vermont School Safety Center, said her team and the school safety liaison officer, Rob Evans, have been doing EOP reviews and exercises in the field and have seen increased requests for assistance, although some schools remain without adequate plans.

- State tracking and assurances: O'Brien said the state does not track the frequency of all emergency drills centrally and that some drill reporting (for example, fire drills) is governed by separate life-safety code provisions. Instead, Act 29 uses superintendent assurances to confirm that a district's EOP includes components consistent with the AOE/VSSC template; the AOE relies on those assurances rather than a centralized state checklist of every drill or training.

- Scope and prescriptiveness of H.247: Committee members pressed whether H.247's annual training or drill requirements could be tracked or would be too prescriptive. O'Brien said mandating and tracking every specific drill statewide would be difficult and that EOPs should allow districts to set training frequency appropriate to local hazards. She and Erickson recommended embedding recommended cardiac annex language and training guidance in templates and resources rather than creating a separate equipment mandate.

What was not decided

No formal vote or committee decision was recorded during the testimony. The AOE recommended that, if further testimony is requested, the committee consider inviting Jay Nichols of the Vermont Group Schools Association for additional perspective.

Ending

The AOE and Vermont School Safety Center told the committee they support robust cardiac response planning embedded in comprehensive EOPs, offering technical assistance, templates, and training to help schools adopt annexes with consistent, evidence-based protocols while avoiding duplicative statutory requirements.