The Nutrition Coalition to USDA-HHS: Disclose Conflicts of Interest for Dietary Guidelines Advisory Committee

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February 2, 2023

The Honorable Xavier Becerra
Secretary of Health and Human Services 
U.S. Department of Health and Human Services 
200 Independence Avenue SW 
Washington, DC 2020

Dear Secretaries Becerra and Vilsack:

Regarding conflicts of interest (COI) on the DGAC, the NASEM specifically recommended: 

The secretaries of USDA and HHS should disclose how provisional nominees’ biases and conflicts of interest are identified and managed by: 

a. Creating and publicly posting a policy and form to explicitly disclose financial and nonfinancial biases and conflicts;  

b. Developing a management plan for addressing biases and conflicts for the panel as a whole and individuals, as needed;  

c. Certifying that a federal ethics officer independently reviewed and judged the advisory committee’s biases and conflicts of interest; and by  

d. Documenting how conflicts of interest were managed in the Dietary Guidelines Advisory Committee report. 

We write to urge the USDA-HHS to adopt these recommendations in a way that is transparent to the public.

As the 2017 NASEM report noted in making its recommendations, “a potential reason for lack of adherence to dietary intakes recommended in the DGA is that the public has ‘lost faith’ in the DGA.” It goes to say that disclosure of COI “...is vital to engendering public trust in the process, as well as providing assurance that decisions were made free of undue influences.”

“Given the erosion of trust in expertise in general and the public attention on COI in nutrition research, these issues are likely to remain pertinent to future DGA cycles. Therefore, assessment and transparent management of both individual and institutional COI will remain important for maintaining and increasing public trust in the DGA.

Congress mandated these NASEM reports with a total $2,000,000 allocation and the clear intention that the resulting recommendations would be adopted. Greater transparency in the Dietary Guidelines process is evidently a priority for the NASEM, with references to the need for “enhanced” or “improved” transparency mentioned nearly 20 times in the 2022 NASEM report.  

If the USDA-HHS has, in fact, publicly disclosed the COI of the 2025 DGAC, we respectfully make two requests: 

• Please let us know where these disclosures can be found, and 

• Please let us know if the USDA-HHS has published a management plan to address biases and conflicts of interest for the panel, as the NASEM recommended. 

We respectfully request USDA-HHS to comply with the NASEM recommendations on COI disclosure and management. In the event that USDA-HHS has complied, we respectfully ask the agencies to respond to our requests outlined above.

Sincerely,

John Bates
Executive Director
The Nutrition Coalition