The Process by Which the Guidelines are Created Needs Reform

Redesigning the Process for Establishing the Dietary Guidelines for Americans

In September, 2017, the National Academies of Sciences, Engineering and Medicine (NASEM) issued a report on the process used to develop the Dietary Guidelines for Americans (DGA). This report had been mandated and funded by Congress, following concern that the DGA have failed to combat obesity and type 2 diabetes, as well as other major nutrition-related diseases.

A crucial finding of the report is that the current DGA process for reviewing the science falls short of meeting the "best practices for conducting systematic reviews," and that "methodological approaches and scientific rigor for evaluating the scientific evidence" need to "be strengthened." The report states, "To develop a trustworthy DGA, the process needs to be redesigned."

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Highlights Raising Questions of Concern:

Quoted from: National Academies of Sciences, Engineering, and Medicine. 2017. Redesigning the process for establishing the Dietary Guidelines for Americans. Washington, DC: The National Academies Press.

Scientific Rigor: “The U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) should comprehensively redesign the process for updating the DGA to improve transparency, promote diversity of expertise and experience, support a deliberative process, foster independence in decision-making, and strengthen scientific rigor.”

“…scientific rigor needs to be maximized. The process by which the science is evaluated can be strengthened by (1) using validated, standardized processes and methods; and (2) using the most up-to-date data. Processes and actions ought to be based on the best available evidence, requiring the types of analysis used be continuously improved and advanced.”

“To develop a trustworthy DGA, the process needs to be redesigned.”

“The current DGA process for reviewing the science falls short of meeting the best practices for conducting systematic reviews.”

“Methodological approaches and scientific rigor for evaluating the scientific evidence need to be strengthened.”

 “The methodological approaches to evaluating the scientific evidence require increases rigor to better meet current standards of practice.”

Chronic disease prevalence: “...it is not currently positioned to effectively adapt to changes such as food diversity and chronic disease prevalence, while also ensuring the integrity of the process…”

“Given the prevalence of chronic disease and risk for chronic disease in the population, this National Academies committee believes it will also be essential for the DGA Policy Report to include all Americans whose health can benefit by improving their diet based on the scientific evidence. Without these changes, present and future dietary guidance will not be applicable to a large majority of the general population.”

Bias: “The adoption and widespread translation of the DGA requires that they be universally viewed as valid, evidence-based, and free of bias and conflicts of interest to the extent possible. This has not routinely been the case.”

Enhancing Transparency: “...is vital to engendering public trust in the process, as well as providing assurance that decisions were made free of undue influences.”

“The process to update the DGA should be redesigned to increase transparency and allow for the appropriate expertise…”

Strengthen the Evidence Base:  “Methodological approaches and scientific rigor for evaluating the evidence should be strengthened by using validated, standardized processes and methods with the most up-to-date data. It is critical that, for example, the Nutrition Evidence Library is aligned with best practices for conducting systematic reviews and uses appropriate methods.”

Advanced Methods Used: “Processes and actions should be based on the best available evidence, requiring that the analyses used be continuously improved and advanced.”

General comments: Collectively, these findings and conclusions compromise the integrity of the DGA and limit its ability to develop a full body of evidence on a continuous basis over time.

“…the effect of the DGA will be limited if they do not apply to the general population and if the public questions the credibility of the process and the ultimate DGA recommendations. To develop a trustworthy DGA, the process needs to be redesigned.”

“It will be imperative for the process to enhance transparency, manage biases and conflicts of interest to promote independent decision making, promote diversity of expertise and experience, support a deliberative process, and adopt state-of-the-art processes and methods to maximize scientific rigor.”