MAHA Commission’s Plan to Fix Kids’ Health

“The initial mission of the Commission shall be to advise and assist the President on how best to exercise his authority to address the childhood chronic disease crisis.” 

– Executive Order 14212 

The first phase of that directive was released several days ago and has been covered to varying degrees in the press. For those wishing to read the entire report, it can be found here. For the rest of us, the tl:dr crowd, here are the thoughts of an informed physician-citizen, hoping for the best but with a skeptical eye.

The report, which is tasked with 10 deliverables, is mixed. Its greatest strengths lie in identifying the medicines American children are taking, along with rising trends in side effects and costs and how federal food dollars are being spent. While echoing their assignment in discussing the impact of ultra-processed foods, environmental chemicals, and medication overuse, the causal math is light, and the evidence, when offered, is primarily anecdotal. There is no systematic critique of best practices or the effectiveness of educational programs. 10% of the report, 7 pages, discusses corporate capture, raising important flags about scientific integrity but stops at rhetoric; practical reforms remain aspirational. Despite an Administration that claims it is the “most transparent in history,” it is left to the reader to investigate the numerous citations in the report, a task few, if any, will take on. 

Several inconsistencies in the study should raise concerns:

• “The American food system is safe but could be healthier,” is stated. Then, the section portrays that system as delivering food that “negatively affects overall health” and is implicated in virtually every chronic disease listed. Perhaps I misunderstand the term “safe,” but can our foods be simultaneously safe and harmful?
• The logic toggles between “more prescriptions show the epidemic is worsening” and “more prescriptions show over-treatment of non-disease.” Can the same statistic validate and invalidate a problem, or is this just a sleight of hand?
• In discussing corporate capture, the authors note, “Peer review, the gatekeeping attribute that defines medical journals, is ineffective and biased,” however, the evidence they cite here and throughout the report comes from the same peer-review system it says cannot be trusted. 

The MAHA Commission consists of political appointees, often with well-known, strong pre-existing positions on vaccines, regulation, and corporate capture. Those perspectives, indeed, the initial charges to the Commission to investigate “assess the threat that potential over-utilization of medication, certain food ingredients, certain chemicals, and certain other exposures pose to children” and “restore the integrity of science, including by eliminating undue industry influence” permeate the narrative. 

Having called out industry’s “tainted findings,” studies by advocacy groups seem to be taken at face value, a sin of “good” intentions we have committed for many years and continue. While the report calls for a more holistic consideration of our diet, it has no option other than to use as evidence of UPFs' role in our demise the reductionist data, providing, at best, associations rather than causations they deride. With the departure of Kevin Hall, the only NIH researcher studying UPFs holistically, the proposed cuts to the NIH research budget, and the timeline necessary to get real data on diet and health, any policy generated by the MAHA commission will be based on data they consider gravely flawed. 

The report raises significant concerns, and there is a great deal to be said about understanding the additive effects of foods and vaccines. However, solely focusing on UPFs or vaccine schedules is just as myopic and reductive. A focus on food coloring, or emulsifiers, restricting the food choices of SNAP beneficiaries is merely rearranging the deck chairs on the Titanic. There was no word about government subsidies for sugar, although, in fairness, the report did mention the disparity in how the government supports corn and other row crops compared to farming fruits and vegetables. 

I would be remiss in mentioning one last discrepancy between words and deeds. In a section describing the distortion of scientific literature, the authors rightly point to two unwarranted assumptions: 

“That journal articles include the most relevant findings on benefits and harms. That the publication of articles in reputable journals is tantamount to an attestation and confirmation that the reports are faithfully distilled representations of original study data.”

It is, therefore, quite remarkable that Drs. Makary and Prasad have chosen the New England Journal of Medicine to announce new FDA policy on the COVID vaccines. Perhaps the MAHA Commission, which includes Dr. Makary, should share their concerns more widely.

Despite the angst the MAHA Commission reports in those who believe they are on the receiving end of a regulatory beat-down, the report breaks no new ground. No new problems are identified; they are aggregated into one package. The weaknesses in analysis, conflating association with causation, failing to recognize the intertwined nature of the players as much as the ingredients and a skepticism of those marked with today’s Scarlet Letter remain. 

Having pledged “radical transparency” and a revival of scientific integrity, the Commission’s debut sounds more like a series of well-known concerns rather than a blueprint for change. The full slate of recommendations, still six months away, will slam into entrenched interests: industry lawyers ready to rebut charges of corporate capture, advocacy groups guarding their narratives, an Administration intent on trimming research budgets, and a Congress already tightening the purse strings on farm and food programs. Unless the next phase replaces rhetoric with reproducible data and resolves its internal contradictions, the MAHA Commission will fall short of the Executive Order’s charge of

“ending Federal practices that exacerbate the health crisis or unsuccessfully attempt to address it, and by adding powerful new solutions that will end childhood chronic disease.”