The Nutrition Coalition (TNC) submitted its public comments to the USDA regarding the final expert report by the 2020 Dietary Guidelines Advisory Committee. The 2020-2025 Dietary Guidelines for Americans, due out at the end of this year, will be based on this report.
TNC expressed concerns about USDA's lack of adherence to a rigorous, verified methodology for its scientific reviews, as recommended by the National Academies of Sciences, Engineering, and Medicine (NASEM) in two Congressionally-mandated reports in 2017. The NASEM also made recommendations to increase transparency and manage bias in the DGA process, but the USDA did not adopt this advice. TNC noted that these recommendations are standard features of any high-quality scientific paper, and stated that a report upon which the health of the nation depends should also uphold these basic standards of good science, in order to ensure a policy that is trustworthy and reliable. TNC also noted that the 2020 DGAC Report does not comply with the law; for instance, it does not, in many scientific reviews, reflect the “preponderance of scientific and medical knowledge which is current at the time the report is prepared.”