Understanding the Core Rules of Creditable Milk
The Child and Adult Care Food Program (CACFP) is a federal program that provides meal reimbursements to eligible child care centers, day care homes, and adult day care centers. To receive this reimbursement, institutions must adhere to strict USDA meal pattern requirements, which include specific rules regarding the milk component. Understanding these regulations is key to avoiding claim denials and providing nutritious meals. The most common reasons a milk product is not creditable are related to fat content, flavor, age of the participant, and nutritional content for milk substitutes.
The Role of Fat Content and Age
The fat content of milk served is dictated by the age of the participant. This is one of the most critical factors in determining what is not creditable. The rules are designed to align with developmental nutritional needs, shifting from higher-fat milk for toddlers to lower-fat options as children age.
- For Children 12-23 Months: Only unflavored whole milk is creditable. During the one-month transition period (24-25 months), whole or reduced-fat milk is acceptable to help a child adjust to lower-fat milk. Any other type of milk, such as skim or reduced-fat, is not creditable during the 12-23 month period.
- For Children 2-5 Years: Only unflavored low-fat (1%) or unflavored fat-free (skim) milk is creditable. Serving whole or reduced-fat (2%) milk to this age group is not creditable, except during the single-month transition.
- For Children 6+ and Adults: Only low-fat (1%) or fat-free (skim) milk is creditable. Whole and reduced-fat (2%) milk are not creditable for this group.
Restrictions on Flavored Milk
Flavored milk, which includes varieties like chocolate or strawberry milk, contains added sugars, prompting specific restrictions within the CACFP. These rules are designed to help participants develop healthy eating habits early in life.
- For Children 1-5 Years: Flavored fluid milk is not creditable and cannot be served as part of a reimbursable meal or snack. This includes both commercially prepared and facility-prepared flavored milk.
- For Children 6+ and Adults: Flavored milk can be creditable, but it must be either low-fat (1%) or fat-free (skim). Serving any other flavored milk (e.g., flavored whole milk) is not creditable for this older age group.
Non-Dairy Milk Substitutes
For non-dairy milk substitutes to be creditable, they must meet specific USDA nutritional standards. This is a common area for non-compliance, as many popular alternatives do not meet the equivalency requirements.
- Non-Creditable Non-Dairy Substitutes: Many brands of almond milk, coconut milk, and rice milk are not creditable because they do not meet the nutritional standards for protein, calcium, and other essential nutrients found in cow's milk. Oat milk, for example, is also typically not creditable for the same reason. A non-creditable non-dairy beverage can only be served and claimed for a participant with a documented disability, supported by a medical statement.
Other Non-Creditable Milk Types and Preparations
Beyond fat content and substitutes, other forms of milk are also not creditable under CACFP rules:
- Reconstituted Milk Powder: Unless there is a documented emergency preventing access to fluid milk, reconstituted milk powder is not creditable. Programs must receive prior state approval to use it.
- Sweetened Condensed Milk: This product is not creditable as it does not meet the definition of fluid milk.
- Milk as an Ingredient: With the exception of milk used in smoothies, milk mixed into recipes like soups, custards, or pudding is not creditable toward the fluid milk component of a meal.
- Raw Milk: To be creditable, milk must be pasteurized. Raw milk is not creditable.
Comparison of Creditable vs. Non-Creditable Milk in the CACFP
| Feature | Creditable Milk (Examples) | Non-Creditable Milk (Examples) |
|---|---|---|
| Fat Content (Ages 2-5) | Unflavored Low-Fat (1%) or Fat-Free (Skim) | Whole Milk, Reduced-Fat (2%) Milk |
| Fat Content (Ages 6+ / Adults) | Unflavored or Flavored Low-Fat (1%) or Fat-Free (Skim) | Whole Milk, Reduced-Fat (2%) Milk |
| Flavoring (Ages 1-5) | Unflavored milk only | Flavored Milk (chocolate, strawberry, etc.) |
| Non-Dairy Alternatives | Nutritionally equivalent substitutes (requires documentation), Lactose-free milk | Non-equivalent options like most brands of almond, oat, or rice milk |
| Preparation | Fluid milk served as a beverage or over cereal | Milk used as an ingredient in recipes (e.g., soup, pudding) |
| Form | Fluid, pasteurized milk | Raw milk, Reconstituted powdered milk (without emergency approval) |
Conclusion: Navigating CACFP Milk Rules for Full Compliance
Adhering to CACFP milk crediting requirements is a crucial administrative task for any participating institution. By carefully considering the age of the participants, the milk's fat content, the presence of flavoring, and the nutritional equivalence of non-dairy alternatives, providers can ensure they meet all USDA standards. Key takeaways include serving only whole milk for toddlers (12-23 months), unflavored low-fat or fat-free milk for preschoolers (2-5 years), and allowing flavored low-fat or fat-free milk only for participants aged six and older. For non-dairy options, a non-disability request requires the substitute to be nutritionally equivalent, while a medical statement is necessary for non-equivalent versions for a disability. Simple errors, like serving whole milk to a 4-year-old or using almond milk that doesn't meet protein standards, can lead to meal disallowances. Training staff on these specific, age-based rules is the best way to maintain compliance and avoid potential issues during audits. Consistent attention to these details ensures the program can continue to serve nutritious, reimbursable meals and snacks effectively.
CACFP Crediting Handbook is a valuable resource for clarifying these and other meal pattern requirements.
