In April, the US Department of Health and Human Services published its proposed list of scientific questions for the next update of the Dietary Guidelines for Americans (DGA). The DGA, reviewed and updated every five years, provides the foundation for the federal government’s recommendations to the public about eating patterns that lead to better health outcomes. Federal child nutrition program standards, like school breakfast and lunch, are required by law to align to the DGA recommendations for kids. So this process of examining scientific evidence on diet underpins the work that farm to school and farm to ECE stakeholders are doing every day. 

NFSN commended the Advisory Committee for its proposed examination of the health effects of ultra-processed foods, the negative impact of added sugars, evidence on effects of saturated fat, and a lifespan approach that recognizes that a diversity of culturally relevant meal pattern approaches can support health. We also commend the commitment to examining all findings through a health equity lens. 

We were dismayed at what seemed to be an increased emphasis on weight, weight management, and obesity as the primary marker of health and main goal of the DGA. body-mass index (BMI), the most common measure of obesity, is a flawed and racially biased way to measure body composition for individuals and diverse populations, and of questionable value as a primary predictor of health. The purpose of Dietary Guidelines for Americans is to review evidence and make recommendations to help Americans avoid chronic disease and enjoy longer, healthier lives. An increased emphasis on weight as a primary goal is, in both substance and implementation, likely to increase racial harms, for instance in medical settings where Black and Brown patients are already at risk of delayed or denied care. Similarly, we worry about the health impact for children of emphasizing weight management as a primary goal of diet quality, rather than nourishing and supporting them for the healthiest and most empowered lives. We encourage the Advisory Committee to focus on the evidence that improves specific chronic disease and well-being outcomes for children and youth, regardless of their weight. 

Finally, NFSN shares the sentiments of many nutrition advocates in calling on the DGA to recognize that sustainability and health are interdependent. The proposed questions would remove questions of the healthiest sustainable diet for examination in a separate process at a later date. NFSN stakeholders work closely with producers and communities who provide child nutrition programs with whole, fresh, and unprocessed foods that nourish kids. Therefore they know that the ability to consume a healthy diet depends on whether our planet can continue to support its production, and the two questions are not exclusive. 

In our comments on the 2020 Dietary Guidelines, NFSN highlighted how farm to school and farm to ECE activities offer proven strategies and tools to help kids learn about the food system, gain lifelong food skills, and shift power within their own food environment. As the process of updating and implementing the DGA continues, NFSN will continue to monitor opportunities for NFSN stakeholder and community comment. 

See NFSN’s full comments here