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.
