Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 1 of 6

Breastfeeding Peer Counseling Program: Allowable Costs

Policy: Breastfeeding Peer Counseling (BFPC) funds that USDA Food and Nutrition Services (FNS) distributes to State agencies are to be used to develop or expand activities necessary to sustain a peer counseling program based on the FNS WIC Breastfeeding Model Components for Peer Counseling. The primary purpose of the funds is to provide direct breastfeeding support services through peer counseling to WIC participants. The use of BFPC funds for expenditures that are not supported by the WIC Breastfeeding Model Components for Peer Counseling are not authorized.

Funding for peer counseling is provided to local agencies (LAs) through a separate grant based on state resources. Allowable costs are defined by the USDA. LAs must monitor breastfeeding peer counseling program expenditures to assure they are correctly reported in a timely manner.

Regulations: USDA FNS WIC Breastfeeding Curriculum: Peer Counselor Management; USDA FNS WIC Breastfeeding Curriculum (Levels 1 & 2); USDA FNS WIC Nutrition Services Standards – Standard 9; USDA FNS WIC Breastfeeding Policy and Guidance (July 2016); USDA FNS Allowable Costs for Breastfeeding Peer Counseling Funds (March 2024).

Procedure/Additional Guidance: The table on the following page defines allowable BFPC program costs based on USDA criteria.*

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Allowable Costs for Breastfeeding Peer Counseling Programs The table below helps to identify allowable BFPC costs. (Note: This is not an exhaustive list of allowable costs.) Item or Service Allowable Costs Comments Durable Goods and Space Furniture, desktop computers/laptops/tablets, and office equipment used to provide peer counseling services and training Yes

Phone lines, internet service, cell/smartphones, pagers and answering machines for contacts between peer counselors and mothers Yes

Portable baby scales to weigh infants outside of the WIC clinic or scales marketed for pre- and post- breastfeeding weight checks No Nutrition Services and Administration (NSA) funds may be used to purchase scales for clinical assessment for use by staff other than peer counselors. Space and lease costs for peer counselors to provide services

Yes

Incentives and Educational Materials to Promote Breastfeeding Breastfeeding educational materials for mothers No NSA funds may be used to purchase participant educational material. Breast pumps and breastfeeding aids for mothers

Breast pumps and breastfeeding aids for demonstration purposes by peer counseling staff

No

Yes Refer to Breastfeeding: Breast Pump Issuance Policy for more information on breast pumps and allowable breastfeeding aids. Incentive items distributed to WIC participants to encourage breastfeeding (e.g., breast pumps, breastfeeding aids, breastfeeding promotion and support incentive items, written materials, etc.)

No NSA funds may be used to purchase participant incentive items.

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Item or Service Allowable Costs Comments Personnel and Compensation Salaries and compensation for peer counseling staff: peer counselors, designated peer counselor coordinators, and WIC Designated Breastfeeding Experts (DBE) Yes. BFPC funds may be used to fund staff to provide oversight/management of peer counseling programs and/or supervision, mentoring and referral expertise for peer counselors.

BFPC funds may be used to pay for DBE time if a peer counselor refers a WIC mother to a DBE for problems that are outside of the peer counselor’s scope of practice. The DBE may be compensated using BFPC funds if the mother continues to be supported by the peer counselor and remains part of the peer counselor’s caseload. BFPC funds cannot be used to disproportionately hire WIC DBEs versus peer counselors.

NSA funds must be used for consultations for WIC mothers who are not referred by peer counselors and are not part of a peer counselor’s caseload.

Refer to the Nutrition Services Standards for DBE qualifications, roles, and responsibilities. Salaries and compensation for dual-role staff (e.g., part-time WIC Nutrition Assistant and part-time peer counselor or part-time CPA and part-time DBE) Yes, but costs must be allocated between the two positions held. BFPC funds may be used for the portion of time spent as a peer counselor or the DBE. See FNS Breastfeeding Policy and Guidance document for additional information on dual-role staff.

Males as breastfeeding peer counselors

No. The definition of peer counselor in the WIC Breastfeeding Model for Peer Counseling is based on research demonstrating the benefit of hiring peer counselors from WIC’s target population of WIC-eligible women

Personnel and Compensation Father-to-Father Breastfeeding Support Group No Fathers are valuable partners of breastfeeding promotion and support in WIC. However, father- led activities are outside of those defined by the WIC Breastfeeding Model for Peer Counseling. See FNS Peer Counseling Management Curriculum for additional information. Virtual Breastfeeding Support Groups (i.e., Facebook, Zoom) Yes, only for PC/DBE staff hours for monitoring and engaging with WIC participants in a Virtual Support Group that provides breastfeeding support services.

BFPC funds cannot be used for breastfeeding support to non-WIC participants.

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Item or Service Allowable Costs Comments Recruitment of peer counselors and related staff Yes

Milk Banks/Depots No. BFPC funds cannot be used for services related to milk banks/depots.

Drop In Breastfeeding Groups Yes. BFPC/DBE time may only be used for WIC participants. BFPC/DBE time may not be counted toward nutrition education contacts. Staffing and expenses related to WIC Peer Counselor support to the Buddy Program Yes. Duties such as matching buddy pairs, responding to buddy requests/inquiries, following up on buddy interactions, prompting discussions with conversation starters, and other duties as assigned by the peer counselor supervisor.

Staffing and expenses related to WIC Peer Counselor support to breastfeeding hotlines and call centers Yes. BFPC funds may be used to fund peer counselors to answer calls to a WIC breastfeeding hotline if the peer counselor: 1) meets the definition of peer counselor; 2) receives the appropriate training and supervision as outlined in the WIC Breastfeeding Model for Peer Counseling; and 3) does not provide services to non-WIC participants. Other expenses related to the hotline/call center (e.g., rent, phone lines, equipment, etc.) are allowable for any portion of those expenses that are for the purpose of a WIC peer counselor providing WIC participant contacts through the hotline/call center. BFPC funds cannot be used for breastfeeding hotline support to non-WIC participants. Staff Training and Resources Travel for WIC State-required training of peer counselors/DBE and peer counseling staff/managers Yes, only for the FNS Breastfeeding trainings or WIC State-developed approved comparable training.

NSA funds may be used for attendance at a state/national breastfeeding conference. Travel for home and hospital visits by peer counseling staff Yes, for visits to WIC participants; peer counselors may not provide services to non-WIC participants.

Continuing education for DBEs Yes, if it relates to servicing peer counseling programs (e.g., mentoring, serving as a referral, etc.)

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Item or Service Allowable Costs Comments Breastfeeding resources for peer counseling staff

Breastfeeding resources for WIC staff not related to peer counseling Yes, if the resources are related to peer counseling (e.g., training materials for peer counselors and DBE).

No Training materials/education must be within scope of a peer counselor (i.e., basic breastfeeding information and support). NSA funds may be used to purchase general breastfeeding resources for WIC staff. Training and coursework for peer counselors to become International Board-Certified Lactation Consultant (IBCLC) or Certified Lactation Counselor (CLC) No. NSA funds may be used for CLC or IBCLC training and coursework. The priority use of BFPC funds is to hire and train peer counselors to provide breastfeeding peer counseling services to WIC participants. Staff with advanced lactation training are not considered peer counselors.

Research recommends that peer counselors be provided career path training options. CLC or IBCLC exam, renewal, or membership fees No At the WIC State agency’s (SA) discretion, NSA funds may be used for CLC or IBCLC training, exam fees, renewal and/or association membership fees. The SA must determine if it is necessary and of benefit to the WIC Program for the person in a particular job position to have the certification. SAs must also determine whether the cost fits within its WIC NSA grant budget. Peer Counseling Program Advertising and Promotion Media outreach (e.g. bus placards, paid social media and digital ads to advertise BFPC programs) Yes. Media outreach using BFPC funds are allowed if directly recruiting peer counselors or informing WIC participants about the PC program, including the Buddy Program, as a WIC breastfeeding benefit. FNS would not expect to see a disproportionate amount of the BFPC funds spent on advertising the program at the expense of direct services to participants.

BFPC funds may not be used for ads that promote breastfeeding in general but NSA funds may be used for this purpose. Name badges, buttons and similar low-cost items that identify peer counselor staff Yes

Pamphlets and similar materials to promote the peer counseling program Yes

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Item or Service Allowable Costs Comments Miscellaneous Indirect costs (e.g., personnel, accounting, or information technology services, etc.) Yes, but only those that are related to providing a WIC peer counseling program.

Second nutrition education contacts No. BFPC funds are for activities that are in addition to current required WIC activities. NSA funds provide for at least two nutrition education contacts; therefore, BFPC funds may not be used for the “second” contact.

In addition, the 1/6th nutrition education requirement and breastfeeding target must be met with regular NSA funds. Childcare No

Cribs or other materials and equipment for infants of peer counselors who bring their babies to work No

Monitoring and tracking of program effectiveness Yes. Funds may be used to monitor and track program components (e.g., contacts, referrals, training, etc.) to determine effectiveness and where improvements are needed.

Evaluation studies may not be paid for using BFPC funds. Miscellaneous Peer counseling services to non- WIC participants No. Peer counselors should refer WIC- eligible women to WIC to apply for WIC benefits. Peer counselors should refer women who are not WIC-eligible to appropriate non-WIC resources.

Breastfeeding coalitions No BFPC funds can only be used for services and activities related directly to peer counseling. *Updated March 2024. This is not an exhaustive list of allowable costs. Refer to the FNS Regional Office for questions about allowable cost and to the Breastfeeding Policy and Guidance.