Month: February 2025

NYHealth President and CEO David Sandman submitted the following testimony on February 25, 2025, at the New York State Joint Legislative Public Hearing 2025 Executive Budget Proposal: Higher Education. In his testimony, he addressed the opportunity for New York to allow Medical Assistants to vaccinate patients, easing the burden on doctors and nurses.

Thank you, Chair Kreuger, Chair Pretlow, and members of the Senate Finance and Assembly Ways and Means Committees. I am pleased to provide testimony on behalf of the New York Health Foundation (NYHealth), a private, independent, statewide foundation dedicated to improving the health of all New Yorkers, especially people of color and others who have been historically marginalized.

Across the state, many New Yorkers must wait weeks or months to see a primary care clinician. By the time they do, they are sicker and harder to treat. Our health care system is out of balance and hobbled by chronic underinvestment in primary care. In the United States, less than 5 cents of every dollar we spend on health care goes to primary care clinicians, despite handling one in three health care visits.^1,2 The same troubling pattern holds true in New York.³

New York’s underinvestment in primary care has contributed to a shortage of health care workers. While New York had a shortage of primary care clinicians prior to COVID-19, the pandemic resulted in an exodus of overburdened, burnt-out health care workers, further straining our health care system.

Solving the workforce shortage is no small feat. But there are practical steps we can take now to alleviate the problem. One simple and immediate solution is to allow MAs to vaccinate patients, easing the burden on clinicians.

MAs Are Trusted Bridges Between Patients and Clinicians

New York employs approximately 40,000 MAs, the fourth-highest number of any state.⁴ As one of the fastest-growing health care professions, the number of MAs in New York is expected to rise by 27% between 2022 and 2032.⁵ Due to this anticipated growth, it is particularly important that policies enable MAs to practice in ways that most effectively support care delivery and alleviate workforce shortages.

MAs are vital members of the primary care team, responsible for administrative tasks and certain clinical duties under the supervision of a physician or other clinician.⁶ Their jobs may include tasks like taking medical histories, measuring vital signs, preparing patients for exams, and drawing blood.⁷

MAs are a trusted bridge between clinicians and patients, particularly in underserved and marginalized communities. MAs are also predominantly people of color and often come from the communities they serve, making them uniquely positioned to build relationships with patients and earn their trust.⁸ Primary care teams that fully integrate MAs see measurable improvements in patient care, better health outcomes, and reductions in clinician strain and burnout.^{9,10,11,12,13}

New York Is Falling Behind Other States at a Time We Can’t Afford To

New York lags other states in making the most of MAs’ potential. We are the only state that does not allow clinicians to delegate the task of administering injections, like vaccinations, to Medical Assistants, with appropriate training and supervision.^14,15 This gap was cast into relief during the COVID-19 pandemic, when New York’s health system was strained by the massive task of immunizing New Yorkers. During this public health emergency, New York did not allow MAs to administer COVID vaccines, while neighboring states New Jersey and Connecticut used this emergency as an impetus to more fully utilize MAs.^16,17,18

The Executive Budget proposal includes a common-sense provision to align New York with every other state by allowing trained Medical Assistants to administer vaccinations under the supervision of a physician or physician assistant. Affirming the importance of this issue, the New York State Legislature has introduced a bill (A5460-A/S05340) to formally authorize MAs to administer vaccines under the appropriate supervision of a physician, physician assistant, or nurse practitioner. This policy change would expand the pool of health professionals available to vaccinate New Yorkers, alleviating strain on clinicians and allowing them to focus on more complex patient care needs.

Allowing MAs to Vaccinate is Common Sense and Widely Supported

New York health care providers are ready to support MAs and implement this proposed policy change. A recent NYHealth-supported survey of primary care practice administrators and MA supervisors across New York State found that:

• Two out of three primary care providers would likely have their MAs perform vaccinations if permitted.
• That proportion increases to 8 in 10 providers among Federally Qualified Health Centers, New York’s safety net primary care providers.
• 85% of practice administrators said they would train their MAs to vaccinate in-house, supporting the feasibility of implementing this policy change.¹⁹

These findings align with direct feedback from primary care teams across the state. One practice administrator noted, “The ability for our MAs to do injections would really take extra stress off our nursing staff, who [are] expected to work with one provider in addition to needing to be available for the MAs to request injections.” Similarly, a MA shared their frustration: “We can draw blood. We can do everything else but the vaccine administration. We cannot do [vaccines], but 15 minutes away [in Pennsylvania], those MAs are able to, and they have had the exact same training as us.”²⁰

Conclusion

A robust primary care workforce is essential to a high-performing health care system. MAs can contribute even more, but outdated policies prevent them from practicing to their full potential. Expanding the role of MAs and authorizing them to administer vaccines under supervision will help New Yorkers get the care they need, when they need it.

References

[1] Patient-Centered Primary Care Collaborative, “Investing in Primary Care: A State-Level Analysis,” July 2019.
https://www.pcpcc.org/sites/default/files/resources/pcmh_evidence_report_2019_0.pdf.

[2] National Academies of Sciences, Engineering, and Medicine, Implementing High-Quality Primary Care: Rebuilding the Foundation of Health Care, Washington, DC: The National Academies Press, May 2021.
https://www.nationalacademies.org/our-work/implementing-high-quality-primary-care#sectionPublications.

[3] Milbank Memorial Fund, “The Health of US Primary Care Baseline Scorecard Data Dashboard,” February 2023.
https://www.milbank.org/primary-care-scorecard/, accessed January 2025.

[4] U.S. Bureau of Labor Statistics, “Occupational Employment and Wages, May 2023: 31-9092 Medical Assistants.”
https://www.bls.gov/oes/current/oes319092.htm, accessed February 2025.

[5] New York State Department of Labor, “Long-term Occupational Projections.”
https://dol.ny.gov/long-termoccupational-projections, accessed January 2025.

[6] U.S. Bureau of Labor Statistics, “Occupational Employment and Wages, May 2023: 31-9092 Medical Assistants,” https://www.bls.gov/oes/current/oes319092.htm, accessed February 2025.

[7] New York State Education Department, “Medical Assisting.”
https://www.nysed.gov/career-technicaleducation/medical-assisting, accessed February 2025.

[8] U.S. Census Bureau, “ACS 1-Year Estimates Public Use Microdata Sample,” Race demographics available at https://data.census.gov/app/mdat/ACSPUMS1Y2021/table?cv=RAC1P&rv=ucgid,OCCP(3645)&wt=PWGTP&g=AwFm-BVBlBmA2IA, ethnicity demographics available at https://data.census.gov/app/mdat/ACSPUMS1Y2021/table?rv=SOCP(319092),HISP,ucgid&wt=PWGTP&g=AwFm-BVBlBmA2IA, accessed February 2025.

[9] Willard-Grace R, Chen EH, Hessler D, DeVore, Prado C, Bodenheimer T, Thom DH. “Health Coaching by Medical Assistants to Improve Control of Diabetes, Hypertension, and Hyperlipidemia in Low-Income Patients: A Randomized Controlled Trial.” The Annals of Family Medicine. 2015, 13 (2).

[10] Rodriguez HP, Friedberg MW, Vargas-Bustamante A, Chen X, Martinez AE, Roby DH. “The impact of integrating medical assistants and community health workers on diabetes care management in community health centers.” BMC Health Services Research. 2018, 18(875).

[11] Shaw JG, Winget M, Brown-Johnson C, Seay-Morrison T, Garvet DW, Levine M, Safaeinili N, Mahoney MR. “Primary Care 2.0: A Prospective Evaluation of a Novel Model of Advanced Team Care with Expanded Medical Assistant Support.” Annals of Family Medicine. 2021, 19(5):411-418.

[12] Wagner EH, Flinter M, Hsu C, Cromp DA, Austin BT, Etz R, Crabtree BF, Ladden MJD. “Effective team-based primary care: observations from innovative practices.” BMC Family Practice. 2017, 18(13).

[13] Sinsky CA, Willard Grace R, Schutzbank AM, Sinsky TA, Margolius D, Bodenheimer T. “In Search of Joy in Practice: A Report of 23 High-Functioning Primary Care Practices.” Annals of Family Medicine. 2013, 11(3):272—278.

[14] American Association of Medical Assistants, “State Scope of Practice Laws.”
https://www.aamantl.org/docs/default-source/state-sop-laws/new-york-state-opinion-utilization-of-medical-assistants-june2023.pdf?sfvrsn=e7fe6ba1_1, accessed February 2025.

[15] Reference available upon request.

[16] Declaring a Disaster Emergency in the State of New York. NY Exec Order No. 202. (March 2020).
https://www.governor.ny.gov/sites/default/files/atoms/files/EO_202.pdf.

[17] Authorization for Members of the Healthcare Provider Community to Conduct COVID-19 Vaccination Administration. NJ Exec Directive No. 20-037. (March 2020).
https://www.state.nj.us/health/legal/covid19/ExecutiveDirectiveNo20-037_HCPVaccinationAuthorization.pdf.

[18] An Act Allowing Medical Assistants to Administer Vaccinations. CT Senate Bill No. 213. (March 2022).
https://www.cga.ct.gov/2022/fc/pdf/2022SB-00213-R000217-FC.pdf.

[19] Summary of preliminary analysis available upon request.

[20] Fitzhugh Mullan Institute for Health Workforce Equity at the George Washington University. (2025). “Medical Assistants in New York: Focus Group Findings.” Available upon request.

NYHealth President and CEO David Sandman submitted the following testimony on February 11, 2025, at the New York State Joint Legislative Public Hearing 2025 Executive Budget Proposal: Health. In his testimony, he addressed the opportunity for New York to require health insurance companies to prioritize spending on primary care and allow Medical Assistants to vaccinate patients, easing the burden on doctors and nurses.

Thank you, Chair Kreuger, Chair Pretlow, and members of the Senate Finance and Assembly Ways and Means Committees, for the opportunity to testify. I am pleased to provide testimony on behalf of the New York Health Foundation (NYHealth), a private, independent, statewide foundation dedicated to improving the health of all New Yorkers, especially people of color and others who have been historically marginalized.

As we work to transform New York’s health care system—enhancing accessibility, quality, and equity while controlling costs—we must expand and strengthen primary care. To achieve this, New York leaders need to:

• Require health insurance companies to prioritize spending on primary care.
• Allow Medical Assistants to vaccinate patients, easing the burden on doctors and nurses.

Primary care is the cornerstone of better health, but is woefully underfunded

Primary care is often a patient’s first and most frequent point of contact with the health care system—and one of the strongest predictors of better health outcomes. Research proves beyond a doubt that accessible, high-quality primary care leads to:

• More preventive care, including cancer screenings, flu vaccinations, and nutrition counseling.^[1]
• Better management of chronic diseases, such as diabetes and asthma, reducing complications and improving quality of life.^[2]

However, one in three New Yorkers lives in a region with insufficient primary care access, and it’s far worse for rural communities and communities of color.^[3] In predominantly Black neighborhoods, residents are 28 times more likely to live in census tracts with the most pronounced primary care shortages.^{[4], [5]} Across the state, New Yorkers have to wait weeks or months to see a primary care doctor or nurse.

When people can’t see their doctor when they need to, they end up sicker. They are then forced to turn to hospitals or emergency rooms (ERs), where it’s much more expensive and more traumatic. The average cost of an ER visit is more than $1,200 compared to $300, what it costs for a primary care visit.^[6] Primary care saves lives and dollars.

Investing in primary care is key to a stronger, more effective health care system

Our health care system is out of balance. In the United States, less than 5 cents of every dollar we spend on health care goes to primary care doctors and nurses, even though they handle one in three health care visits.^{[7], [8]} In New York, primary care spending is even lower than the national average—and it has decreased over the past five years.^[9]

At the same time, New York spends 20% more on health care than the national average—yet our health outcomes remain average or worse compared to other states.^{[10], [11]}

It’s not about spending more. We need to spend smarter and better, and in ways that give us better value for our dollars. 

The solution is to require health insurance companies to prioritize spending on primary care. This means rebalancing health care spending by allocating a greater percentage of what we spend to primary care.  

New York State should set a specific and ambitious target for increasing investment in primary care. At least 17 other states have already adopted policies to do so.^[12] Those that acted early—such as Rhode Island—have seen both a decrease in overall health care costs and an increase in the primary care workforce. By requiring commercial insurers to increase the share of primary care expenditures by 5% over five years, Rhode Island lowered total health care expenditures by 14% while growing its primary care provider workforce.^[13]

Most recently, California’s Office of Health Care Affordability set an ambitious target for primary care investment Research on California’s commercial health care market revealed the transformative power of such a policy shift. It found that if organizations that spent the least on primary care matched those that spent the most on primary care, 25,000 acute hospital stays, and 89,000 emergency room visits would be avoided. And, $2.4 billion in health care spending would be saved in a single year.^[14]

New York cannot afford to fall behind. The Legislature has already recognized the urgency of this issue, passing bills to establish a primary care reform study commission, only to see them vetoed by the Governor, who acknowledged that New York underspends on primary care. This session, Senator Rivera and Assemblymember Paulin have introduced bills (S1634/A1915A), that would require health insurers that spend less than 12.5% of their overall spending on primary care to gradually increase their spending (1% per year) until they do so. Just last week, the bill passed through the Senate Health Committee.  

A common-sense policy to unlock the full potential of medical assistants

Investing in primary care is the fundamental—but not the only—way to enhance patients’ access to primary care and strengthen providers’ ability to provide quality care. Addressing workforce shortages and provider strain is also critical. One immediate, practical solution is to expand the role of Medical Assistants (MAs).

MAs are vital members of the primary care team, responsible for administrative tasks and certain clinical duties under the supervision of a physician or other clinician.^[15] As one of the fastest-growing health care professions, the number of MAs in New York is expected to rise by 27% between 2022 and 2032, outpacing many other health occupations.^[16] Care teams that use MAs beyond administrative and basic clinical duties often see improvements in patients’ use of health services and health outcomes;^[17],[18] improved clinical quality metrics and operational efficiencies;^[19],[20] and reductions in provider strain and burnout.^[21] MAs are also predominantly people of color and often come from the communities they serve, making them uniquely positioned to build relationships with patients and earn their trust.^[22] In short, MAs are capable of—but currently underutilized in—supporting equitable and high-quality patient care.

New York has lagged other states in making the most of MAs’ potential. We are the only state that does not allow clinicians to delegate the task of administering injections, like vaccinations, to Medical Assistants, with appropriate training and supervision.^[23],[24] This gap was cast into relief during the COVID-19 pandemic, when New York’s health system was strained by the massive task of immunizing New Yorkers. New York did not allow MAs to administer COVID vaccines, in contrast to neighboring states like New Jersey and Connecticut, along with many others.^{[25],[26],[27]}

The Executive budget proposal includes a common-sense provision to bring New York in line with every other state by allowing trained MAs to administer vaccinations under the supervision of a physician or physician assistant. Permitting MAs to administer vaccinations will increase the number of health professionals available to vaccinate New Yorkers and free up clinicians to focus on more complex patient care needs.

NYHealth-supported research confirms this.^[28] A survey of primary care practice administrators and nurse supervisors of MAs across New York State reveals that 2 out of 3 primary care providers would be likely to have their MAs perform vaccinations if permitted. Among Federally Qualified Health Centers, New York’s safety net primary care providers, that proportion increases to 8 in 10 providers. And 85% of practice administrators said they would train their MAs to vaccinate in-house.

There is no silver bullet to solve New York’s workforce shortage, but enhancing the role of MAs is an immediate, common-sense, and widely supported step. This will also enable other clinicians to work at the top of their licenses.

Conclusion

Primary care is the backbone of a high-functioning health care system. Greater investment in primary care as a percentage of total health spending will lead to a healthier New York and a more cost-effective system. Supporting and strengthening the primary care workforce will address widespread shortage and strain. Together, these efforts will advance racial health equity. By prioritizing primary care, we can build stronger, healthier communities across New York State and make sure everyone gets the care they need, when they need it.

We stand ready to work with you on these shared goals.

[1] Levine DM, Landon BE, Linder JA. “Quality and Experience of Outpatient Care in the United States for Adults With or Without Primary Care,” JAMA Internal Medicine 2019;179(3):363–372. https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2721037.

[2] Shi L, “The Impact of Primary Care: A Focused Review,” Scientifica. 2012; 2012:432892. https://pmc.ncbi.nlm.nih.gov/articles/PMC3820521/.

[3] Kaiser Family Foundation, “Primary Care Health Professional Shortage Areas (HPSAs),” https://www.kff.org/state-category/providers-service-use/health-professional-shortage-areas/, accessed January 2024.

[4] Brown E, Polsky D, Barbu C, Seymour J, Grande D. “Racial Disparities in Geographic Access to Primary Care in Philadelphia,” Health Affairs 2016; 35(8). https://www.healthaffairs.org/doi/10.1377/hlthaff.2015.1612.

[5] “Predominantly Black neighborhoods” are census tracts where 80 percent of residents or more identify as African American.

[6] Agency for Health Care Research and Quality. “Information on the health status of Americans, health insurance coverage, and access, use, and cost of health services: Medical Expenditure Panel Survey (MEPS) Household Component (HC),” n.d., https://datatools.ahrq.gov/meps-hc/?tab=use-expenditures-and-population&dash=12, accessed February 2025.

[7] Patient-Centered Primary Care Collaborative, “Investing in Primary Care: A State-Level Analysis,” July 2019. https://www.pcpcc.org/sites/default/files/resources/pcmh_evidence_report_2019_0.pdf.

[8] National Academies of Sciences, Engineering, and Medicine, Implementing High-Quality Primary Care: Rebuilding the Foundation of Health Care, Washington, DC: The National Academies Press, May 2021. https://www.nationalacademies.org/our-work/implementing-high-quality-primary-care#sectionPublications.

[9] Milbank Memorial Fund, “The Health of US Primary Care Baseline Scorecard Data Dashboard,” February 2023. https://www.milbank.org/primary-care-scorecard/, accessed January 2025.

[10] New York Health Foundation, “Health Care Spending Trends in New York State,” October 2017. https://nyhealthfoundation.org/resource/health-care-spending-trends-in-new-york-state/, accessed February 2023.

[11] America’s Health Rankings analysis of America’s Health Rankings composite measure, United Health Foundation, State Findings: New York, 2021. https://www.americashealthrankings.org/explore/annual/state/NY.

[12] Primary Care Development Corporation, “State Trends: Primary Care Policy Update,” January 2024. https://www.pcdc.org/wp-content/uploads/2023-State-Primary-Care-Legislation-Trends-FINAL_010423.pdf, accessed February 2025.

[13] Koller C. & Khullar D. “Primary Care Spending Rate – A Lever for Encouraging Investment in Primary Care.” New Eng. J. Med. 2017. 377(18) 1709-1711. Doi:10.1056/NEJMp1709538.

[14] Yanagihara, D. et al. (2022) Investing in Primary Care: Why It Matters for Californians with Commercial Coverage, Primary Care Matters: Commercial Study. https://www.chcf.org/resource/primary-care-matters/commercial-study/, accessed February 2025.

[15] U.S. Bureau of Labor Statistics, “Occupational Employment and Wages, May 2022: 31-9092 Medical Assistants,” https://www.bls.gov/oes/current/oes319092.htm, accessed March 2023.

[16] New York State Department of Labor, “Long-term Occupational Projections,” https://dol.ny.gov/long-term-occupational-projections, accessed January 2025.

[17] Willard-Grace R, Chen EH, Hessler D, DeVore, Prado C, Bodenheimer T, Thom DH. (2015). Health Coaching by Medical Assistants to Improve Control of Diabetes, Hypertension, and Hyperlipidemia in Low-Income Patients: A Randomized Controlled Trial. The Annals of Family Medicine, 13 (2).

[18] Rodriguez HP, Friedberg MW, Vargas-Bustamante A, Chen X, Martinez AE, Roby DH. “The impact of integrating medical assistants and community health workers on diabetes care management in community health centers.” BMC Health Services Research. 2018, 18(875).

[19] Shaw JG, Winget M, Brown-Johnson C, Seay-Morrison T, Garvet DW, Levine M, Safaeinili N, Mahoney MR. “Primary Care 2.0: A Prospective Evaluation of a Novel Model of Advanced Team Care With Expanded Medical Assistant Support.” Annals of Family Medicine. 2021, 19(5):411-418.

[20] Wagner EH, Flinter M, Hsu C, Cromp DA, Austin BT, Etz R, Crabtree BF, Ladden MJD. “Effective team-based primary care: observations from innovative practices.” BMC Family Practice 2017, 18(13).

[21] Sinsky CA, Willard Grace R, Schutzbank AM, Sinsky TA, Margolius D, Bodenheimer T. “In Search of Joy in Practice: A Report of 23 High-Functioning Primary Care Practices,” Annals of Family Medicine 2013; 11(3):272—278. 10.1370/afm.1531.

[22] U.S. Census Bureau, “ACS 1-Year Estimates Public Use Microdata Sample,” Race and ethnicity demographics available at https://data.census.gov/app/mdat/ACSPUMS1Y2021/table?cv=RAC1P&rv=ucgid,OCCP(3645)&wt=PWGTP&g=AwFm-BVBlBmA2IA, accessed February 2025.

[23] American Association of Medical Assistants, “State Scope of Practice Laws.” https://www.aama-ntl.org/docs/default-source/state-sop-laws/new-york-state-opinion-utilization-of-medical-assistants-june-2023.pdf?sfvrsn=e7fe6ba1_1, accessed February 2025.

[24] Reference available upon request.

[25] Declaring a Disaster Emergency in the State of New York. NY Exec Order No. 202. (March 2020). https://www.governor.ny.gov/sites/default/files/atoms/files/EO_202.pdf.

[26] Authorization for Members of the Healthcare Provider Community to Conduct COVID-19 Vaccination Administration. NJ Exec Directive No. 20-037. (March 2020).

[27] An Act Allowing Medical Assistants to Administer Vaccinations. CT Senate Bill No. 213. (March 2022).

[28] Summary of preliminary analysis available upon request.

NYHealth submitted the following comments in support of integrating evidence-based recommendations from the 2025 Dietary Guidelines Advisory Committee into the Dietary Guidelines for Americans, 2025-2030.

February 10, 2025 

Janet M. de Jesus 

Senior Nutrition Advisor, Office of Disease Prevention and Health Promotion 
Office of the Assistant Secretary for Health, Health and Human Services 
1101 Wootton Parkway, Suite 420, Rockville, MD 20852 
Docket ID: HHS-OASH-2024-0017-0001  

Re: Scientific Report of the 2025 Dietary Guidelines Advisory Committee 

Dear Ms. de Jesus:  

The New York Health Foundation (NYHealth) appreciates the opportunity to comment on the Scientific Report of the 2025 Dietary Guidelines Advisory Committee (Committee). We urge the U.S. Department of Agriculture (USDA) and U.S. Department of Health and Human Services (HHS) to integrate the Committee’s evidence-based recommendations into the Dietary Guidelines for Americans, 2025-2030. 

NYHealth is a private foundation that works to improve the health of all New Yorkers, especially people of color and others who have been historically marginalized.^[1] Our Healthy Food, Healthy Lives program seeks to advance policies and programs that connect New Yorkers with the food they need to thrive.^[2] Maximizing participation in federal nutrition programs is a core strategy of the program. The Dietary Guidelines for Americans (DGAs) form the basis for essential federal nutrition programs, including the Supplemental Nutrition Assistance Program (SNAP); the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC); the National School Lunch Program (NSLP); the School Breakfast Program (SBP); the Gus Schumaker Nutrition Incentive Program (GusNIP); and other Food Is Medicine (FIM) programs.  

Our work has given us in-depth knowledge of the critical role evidence-based federal programs like SNAP and WIC play in the lives of New Yorkers. Programs like these reduce health care expenditures and improve dietary quality.^{[3] [4]} These outcomes would not be possible without the DGAs, which incorporate the latest nutrition science into program design. It is critical that the DGAs remain a source for rigorous and evidence-based research.  

NYHealth strongly supports the Committee’s most recent recommendations to promote a healthy dietary pattern. The Committee’s 2025 Scientific Report outlines specific foods and nutrition factors that create a healthy dietary pattern and are associated with positive health outcomes. Diets consistent with these evidence-based eating patterns can meet individual cultural, religious, and financial needs and preferences.  

Accordingly, NYHealth supports the Committee’s recommendations to: 

• Prioritize legumes, nuts, fish, and other seafood as protein sources.  
• Reduce intake of red and processed meats.  
• Increase intake of whole grains. 
• Limit added sugar and saturated fat to less than 10% of calories for Americans ages 2 and older.  
• Promote water as the primary beverage to optimize health.   

NYHealth also urges the USDA and HHS to highlight important policy, systems, and environmental strategies that help Americans follow the DGAs. The Committee noted that these strategies are needed in future research. In contrast, previous committees acknowledged the need for the DGAs to directly include such strategies. The 2025 DGAs should include recommendations from trusted scientific organizations. One example is the National Academies of Sciences, Engineering, and Medicine’s (NASEM) promotion of potential policies such as “expanding state Medicaid and Children’s Health Insurance Program coverage of counseling interventions by registered dietitians.”^[5]  

Other key stakeholders, including food and beverage manufacturers and food retailers, play a role in creating healthier food environments. The final DGAs should include recommendations on how these stakeholders can reduce sodium, saturated fat, and added sugar in the food supply.  

The DGAs are a powerful lever that shape the food system. They influence the food available through federal nutrition programs like WIC and SNAP. They shape meals served in thousands of schools, childcare centers, and older adult centers across the country, and they guide billions of dollars of food procurement. The DGAs also influence individual eating choices through nutritional tools like MyPlate and shape the dietary advice that health professionals provide. Given their broad and deep impact, the DGAs must be based on the most current and rigorous nutrition science outlined in the recommendations by the 2025 Dietary Guidelines Advisory Committee.   

Thank you for the opportunity to provide comments. The New York Health Foundation strongly supports the work of the 2025 Dietary Guidelines Advisory Committee and urges the USDA and HHS to incorporate its recommendations into the upcoming DGAs. We look forward to supporting efforts to update these critical guidelines. 

Sincerely,  

David Sandman, Ph.D.
President and CEO
New York Health Foundation

Julia McCarthy, J.D.
Senior Program Officer 
New York Health Foundation

 

^[1] New York Health Foundation. What we do. https://nyhealthfoundation.org/what-we-do/. Accessed January 2025.  

^[2] New York Health Foundation. Healthy food, healthy lives. https://nyhealthfoundation.org/what-we-fund/healthy-food-healthy-lives/. Accessed January 2025.

^[3] Berkowitz SA, et al. Supplemental Nutrition Assistance Program (SNAP) participation and health care expenditures among low-income adults. JAMA Inter Med. 2017;177(11):1642-1649. 

^[4] Venkatarmani M, et al. Maternal, infant, and child health outcomes associated with the Special Supplemental Nutrition Program for Women, Infants, and Children: A systematic review. Annals Intern Med. 2022;175(10).  

^[5] Complementary feeding interventions for infants and young children under age 2: scoping of promising interventions to implement at the community or state level. National Academies Press. 2023. https://nap.nationalacademies.org/read/27239/chapter/10#196.