USDA Child Nutrition Program, Breastfed Toddlers and Day-Care

Under the USDA Child Nutrition Program guidelines, infants and children 1 year of age and older, who are in licensed day-care programs, must be offered fluid cow’s milk (or approved alternative milk) in order for their day-care providers to be reimbursed for their meals. This is in conflict with what is best for employed moms of breastfed toddlers and their day-care providers, who have limited breastfeeding friendly options under these guidelines.

Many employed moms, knowing that their breastmilk provides excellent nutrition, antibodies, and a sense of security for their older babies, continue to breastfeed when they are with their babies, even if they no longer express milk while they are at work. A breastfed baby, who is 1 year of age or older and eating nutrient dense solids, needs approximately 15 ounces of breastmilk each day to meet child nutrition standards. If a mom and baby breastfeed at least 3–4 times daily, the baby will receive age-appropriate amounts of milk and will not need a milk-substitute when separated from mom.

In order to support the breastfeeding relationship, a day-care provider may choose not to be reimbursed for the meals the breastfed child consumes that do not include milk, however this option is economically punitive to the provider and may affect how much they charge for their services. In order to take the burden off the day-care provider, the mom may send food from home for the child to consume at day-care but this creates extra work and expense for the mom. Alternatively, the mom’s own expressed breastmilk may be served at meals.  This satisfies the milk requirement under the USDA Child Nutrition Program, but continued breastmilk expression may be unnecessarily burdensome for the mom of an older baby who doesn’t need this extra milk.

Expressing breastmilk takes a great deal of dedication and time; pump-weaning can be a welcome relief for the employed breastfeeding mother of an older baby. No longer does she have to cart her pump to and from work or have to scramble to accommodate for the occasional misplaced or broken pump part. Break times become actual breaks and lunches can be enjoyed without the hassle of setting up a pump, expressing and storing milk, and cleaning pump parts.

If a breastfeeding mom allows cow’s milk or other alternative milks to be offered at her child’s meals, she may risk their breastfeeding relationship. One mom who had pump-weaned but whose toddler continued to breastfeed when they were together writes, “when I got to that point with [my daughter], she just stopped getting milk at daycare. She is getting enough mama milk straight from the source when we are together. She just drinks water at daycare. We didn’t originally do it that way—we gave her cow’s milk for a couple of days—then she drastically reduced nursing, so I took her off of cow’s milk. She went back to nursing like normal.”

The Healthy, Hunger-Free Kids Act of 2010 states “In the case of children who cannot consume fluid milk due to medical or other special dietary needs, other than a disability, the caregiver may serve non-dairy beverages in lieu of fluid milk….If a non-dairy milk substitute is served that does not meet the nutritional standards outlined in Title 7 CFR 210.10(m)(3), then the meal is not reimbursable.” According to Kelley Knapp, MS RD from the California Department of Education Nutrition Services Division, there is another option in USDA’s Child Nutrition Programs. The child’s physician can fill out a form, “…stating that the child cannot receive milk due to a disability.” In this case, the toddler may be offered a physician-determined alternative (e.g. water or juice) with meals and the meal may still be reimbursable.

These options do not address the unique needs of the breastfed toddler who does not have a disability or a medical condition, but just doesn’t need additional milk in their diet. It doesn’t address the concern that offering non-human milk to a breastfed toddler can reduce the amount of breastmilk that is consumed and replace it with an inferior substitute that is linked to allergy and obesity.

Employed moms should not have to continue to express milk for their children past the age when it is needed and they should not have to jump through hoops for their children to continue to enjoy a health promoting breastfeeding relationship. Day-care providers should not have to take an economic hit in order to support their breastfeeding clients. It is imperative that this gap in the USDA food program be closed, so that we may continue to support breastfeeding moms, their babies, and their care providers, whether their breastfeeding relationships are measured in terms of months or years.

© 2013 Laura Spitzfaden, LLLL, IBCLC


Child & Adult Care Food Program Reimbursable Meals and Snacks



Long-Term Breastfeeding: Nourishment or Nurturance? Kathleen M. Buckley, PhD, RN, IBCLC, J Hum Lact November 2001 17: 304-312 (

Breastfeeding Past Infancy Fact Sheet (

Feeding Infants: A Guide for Use in the Child Nutrition Programs, Chapter 2

USDA FCS INSTRUCTION 783-7 Food and Nutrition Service REV. 1 Milk Requirement Child Nutrition Programs (

“Child and Adult CareFood Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act”(81 FR 24348)



This article was also posted at Lactation Matters, the official blog of the International Lactation Consultant Association.