Medical Room Standards in Schools

Online comments: 2

• Helen

  To The New York City Department of Health and Mental Hygiene,

  Medical Examinations for School-aged Children

  I am writing in support of the New York City Department of Health and Mental Hygiene’s proposed amendments to Article 49 of the New York City Health Code. I believe New York City children should have required medical examinations and school-based medical rooms inside school buildings. A child’s health is directly connected to educational success, and schools should be equipped to provide students with safe and easy-to-access healthcare services.
  Additionally, I encourage the Department to consider how to help schools financially with the transition and implementation of the new standards.
  First, the standard of parents having a “licensed physicians, physician assistants, and nurses” completing yearly check-ups and physical exams should go without saying. Especially since most children do not have a say on where or who their medical providers are, the city holding parents liable for providing it (and schools enforcing it) is a necessary burden to keep children safe. All New York City children should have healthcare providers who are certified and proven under our state and national requirements.
  The new amendments requires for medical examinations in pre-kindergarten, kindergarten, 5th, and 9th grades, which I agree with. These grades are not only benchmarks or growth in a child, but also when students are more likely to transfer and enter the New York City Public School system for the first time. Kindergarten Ensuring that all children are being screened for health concerns at this age is impoarnt and I believe should be required.
  Second, I support strengthening the standards for school medical rooms. Requiring dedicated spaces, accessible facilities, appropriate medical storage, and equipment such as computers and printers can improve the quality and efficiency of school health services. In a city where approximately 73% of NYC public school students live in poverty, while 14% live in temporary housing or experience homelessness (Office of the New York City Comptroller), not only is having an easily accessible place important, but also being equipped to provide care is essential.
  As a former New York City public school student, the health office played an important role in my teenage years. For the girls in my school, having a safe place to learn about our bodies, get medications during our menstrual cycle, or just having a trained professional to talk with was sacred. The staff treated us like we were not just patients, but as young adults, and helped many of us stay healthy. For some students, the health office was their only way of receiving yearly medical care, and for others, it was a convenient place to go to when they felt sick during class rather than going home. Sometimes students don’t just have bruised elbows and cuts on the knee, they have serious health concerns, and disablities which requires there to be staff and a facility available.

  Sources:

  Office of the New York City Comptroller. Tracking the K-12 Student Population in NYC. 29 Oct. 2026,https://comptroller.nyc.gov/reports/tracking-the-k-12-student-population-in-nyc/

  Comment added October 30, 2026 4:27pm

• Public Comment: Proposed Amendments to Health Code Article 49 (Medical Room Standards)

  Dear Members of the New York City Board of Health and DOHMH Staff,

  I am writing as a New York City public school parent to provide formal comment on the proposed amendments to Article 49 of the NYC Health Code regarding Medical Room Standards in Schools.In principle, I strongly support the intent behind these amendments. School nurses must have the clinical equipment required to keep our children safe. For students managing chronic conditions like type 1 diabetes, severe anaphylaxis, or unstable asthma, having a dedicated medical refrigerator that prevents insulin degradation, running water for hygiene, and direct 911 lines is essential.

  However, as drafted, converting these standards from advisory guidance to a mandatory mandate without dedicated capital funding or realistic phase-in mechanisms creates an unfunded mandate that risks harming school operations. In older, overcrowded NYC school buildings, requiring 280 to 380 contiguous square feet, trenching concrete for internal plumbing, and mandating exterior windows will inevitably force principals to cannibalize scarce instructional space—such as art, music, or specialized resource rooms—or face non-compliance while waiting years on the School Construction Authority backlog.

  I urge the Board of Health to adopt a pragmatic middle path in the final rule:

  Phase-In the Requirements by Tier: Require immediate compliance for portable life-safety equipment (medical-grade refrigerators, dedicated emergency phones, duress buttons), while providing a multi-year phased timeline for structural renovations involving plumbing, HVAC, or wall construction.

  Explicit Grandfathering & Waivers: Establish a clear administrative waiver process for existing, functional medical rooms in older facilities that cannot structurally meet exact square-footage or window requirements without compromising student instruction.

  Avoid Student Exclusion on Milestone Exams: Ensure the expanded 5th- and 9th-grade physical exam requirements include sufficient administrative grace periods so students are not barred from school activities or sports due to seasonal primary-care appointment backlogs.

  We all want our school nurses equipped to handle acute medical emergencies. Let us achieve that goal through practical, phased implementation rather than an unfunded mandate that pits student health against student learning space.

  Sincerely,
  Kevin
  Queens 11375

  Comment added November 2, 2026 1:19pm