Dietary Needs in School Nutrition Programs

Content provided by:, written by Betty Marcelynas, MA, RD and Bette Brandis, RD Updated by Donna Parsons, MS, RD

Several federal laws have been passed with the intent of ensuring that all enrolled students, regardless of disability, have access to meals served at school and that those students eligible for free or reduced-price meals receive them. Under Section 504 of the Rehabilitation Act of 1973 and the Americans with Disabilities Act (ADA), a “person with a disability” is defined as anyone who has a physical or mental impairment that substantially limits one or more major life activities, has a record of such impairment, or is regarded as having such impairment.

Major life activities covered by this definition include caring for one’s self, eating, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning and working. One effect of these laws and the Individuals with Disabilities Education Act (IDEA, 1990) has been an increase in the number of children with disabilities who are educated in regular school classrooms. Often, the disability prevents the child from eating meals prepared for the general school population. Students with special nutritional needs usually have the same or greater nutritional needs as students without physical disabilities; however, they may have a difficult time meetings those needs.

School Food Service Requirements

Students who may need modified or special meals can be classified in two major categories:

  1. those who are unable to eat regular school meals because of a disability and
  2. those who have a chronic medical condition but are not determined to have a disability

A sample order form that a physician or recognized medical authority may use for students with disabilities or a chronic medical condition to modify a diet can be found on

Students with Disabilities

The US Department of Agriculture’s (USDA) nondiscrimination regulation, as well as the regulations governing the National School Lunch Program and School Breakfast Program, make it clear that substitutions to the regular meal must be made for students who are unable to eat school meals because of their disabilities when that need is certified by a statement or order signed by a recognized medical authority. The order must include:

  • The student’s disability and an explanation of why the disability restricts diet.
  • The major life activity affected by the disability.
  • The food or foods to be omitted from the student’s diet and the food or choice of foods to be substituted.

Students with Chronic Medical Conditions

For a student without a disability, but with a chronic medical condition that requires a special diet, an order signed by a recognized medical authority must be provided. This order must include:

  • Identification of the medical or other special need which restricts the child’s diet.
  • The food or foods to be omitted from the child’s diet and the food or choice of Nutrition Interventions for foods that may be substituted (e.g. texture changes and foods substitutions).

Other items that may be included in orders for children with disabilities or chronic medical conditions are:

  • Whether the allergy/medical condition is temporary or permanent. (A permanent note will relieve the family from updating this information every year).
  • The location for maintaining this documentation to ensure that it accompanies the student should she transfer to another school or district.

Students with Other Special Dietary Needs

Schools may make food substitutions, at their discretion, for individual students who do not have a disability, but who are medically certified as having a special medical or dietary need. Such determinations are made only on a case-by-case basis and must be supported by a statement or order that specifies the food substitution needed and is signed by a recognized medical authority. This provision covers those children who have food intolerances or allergies, but do not have life-threatening reactions (anaphylactic reactions) when exposed to the foods to which they are allergic. Generally, children with food allergies or intolerances do not have a disability as defined under the USDA’s regulations and school food authorities may, but are not required to, make substitutions for them. However, when in the physician’s assessment, food allergies may result in severe, life-threatening (anaphylactic) reactions, the student’s condition would meet the definition of disability and the substitutions ordered by the physician must be made. Schools are not required to make modifications to meals due to personal opinions of the family regarding “healthful” diets.

Students with Individualized Education Plans

Many students with special needs will have an Individualized Education Plan (IEP) or an Individualized Family Service Plan (IFSP). These are plans for students receiving special education and related services to help the student benefit the most from the school program. The services described in the IEP or IFSP may include special meals, supported by a diet order. The food service director or manager is responsible for providing meals as described in the diet order, but is not responsible for revising, changing, or interpreting the diet order.

Interventions for Children with Special Health Care Needs

Section 504 of the Rehabilitation Act of 1973 specifies that food service program administrators must serve special meals at no extra charge to students whose disability restricts their diet (8). There is no provision for additional federal reimbursement for the added expense. However, these costs are legitimate program costs that can be paid for out of the food service account, which includes federal reimbursement for meals served for these students. If federal reimbursements are insufficient, alternative funding sources may also be available from Medicaid and special education to cover some of these costs. School officials should explore all possible funding sources.

Nutrition Team

The team for a student with special nutritional needs often includes the principal and teachers, the food service director and/or staff, the child’s parents, and other health professionals and specialists. The team considers the needs and abilities of the individual student. The food service staff:

  • Applies basic guidelines for food preparation to meet those needs
  • Refers to resources, including parental input, on the proper techniques for preparing regular menus in a special way with the rest of the team
  • Evaluates whether or not the meal plan is meeting the special needs of the student

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