June 11, 2025
The President’s Make America Healthy Again (MAHA) Commission has released its initial report on the scope of childhood chronic disease in the U.S. and potential contributing causes. The Commission frames the Make Our Children Healthy Again Assessment as a “call to action” that explores the “potential dietary, behavioral, medical, and environmental drivers” contributing to the rates of chronic diseases in U.S. children.
As we noted in a recent blog, the MAHA Commission’s purpose is to evaluate the current understanding around chronic disease in the United States and take steps to lower chronic disease rates, especially in children. With the publication of this initial report, the Commission now has 80 days to provide a strategy to address the findings.
The Commission was instructed to use rigorous and transparent data to evaluate the threat that potential over-utilization of medication, certain food ingredients and chemicals, and other specific exposures pose to children. The Commission was also directed to identify and report on best practices for preventing childhood health issues and restoring the integrity of science.
Key findings of the report
The Assessment focuses on the root causes of deteriorating child health and aims to establish a clear, evidence-based foundation for the policy interventions, institutional reforms, and societal shifts needed to address chronic disease. The Commission identified four potential root causes that present the clearest opportunities to make progress:
1.
Poor Diet: The Assessment notes that nearly 70% of American children’s daily calorie intake comes from ultra-processed foods (UPFs), which can contribute to obesity, diabetes, and other chronic conditions.
The report defines UPFs broadly as “packaged and ready-to-consume products that are formulated for shelf life and/or palatability but are typically high in added sugars, refined grains, unhealthy fats, and sodium and low in fiber and essential nutrients.” Special attention is paid to additives such as emulsifiers, binders, sweeteners, colors, and preservatives.
The Food and Drug Administration (FDA) had already targeted certain additives prior to the release of the Assessment. Legal experts with Holland & Knight note the FDA also recently announced plans to implement post-approval reviews of additives. Since Secretary of Health and Human Services Robert F. Kennedy, Jr. chairs the MAHA Commission and oversees the FDA, it is not surprising that the agency’s priorities align with the MAHA agenda.
2.
Aggregation of Environmental Chemicals: According to the Assessment, children’s health may be affected by cumulative exposure to numerous chemicals in their everyday lives. The Assessment calls for continued studies from the public and private sectors, especially the National Institutes of Health (NIH), to better understand the collective impact of multiple exposures to chemicals such as heavy metals, per- and polyfluoroalkyl substances (PFAS), pesticides, and phthalates.
The Assessment also recommends that the current regulatory framework be continually evaluated to ensure that various environmental chemicals do not interact to pose a threat to children’s health and the compound effect is considered instead of looking at the chemicals in isolation. The authors urge that this regulatory framework not be overly restrictive but should continue to promote economic development through innovation.
3.
Lack of Physical Activity and Chronic Stress: The report argues that American children are experiencing unprecedented levels of inactivity, screen use, sleep deprivation, and chronic stress. The Assessment outlines how these factors contribute to the rise in chronic diseases and mental health challenges. However, it does not offer any preliminary recommendations beyond the need for further study of the potential causal relationship.
4.
Overmedicalization: The report argues that there is a concerning trend of overprescribing medications to children and suggests it is often driven by conflicts of interest in medical research, regulation, and practice. Based on its analysis of relevant scientific research, the Assessment found that this “overmedicalization” has led to unnecessary treatments with long-term health risks.
Looking ahead
The MAHA Commission now has until early August 2025 to submit a strategy to address the findings in the Assessment. The report recommends 10 research initiatives to prioritize in order to better combat childhood chronic disease, and notes that many of those initiatives are already underway or will begin in the near future. These projects include post-marketing safety monitoring of drugs intended for children, Generally Recognized As Safe (GRAS) oversight reform, drug safety research, AI-powered surveillance, and alternative testing models, among others.
Businesses should thoroughly review the Assessment and consider how any changes to address its recommendations could impact their operations or introduce new risks. They should also take advantage of any opportunities to engage with the Commission as it determines its strategy. Additionally, they should monitor activity in Congress, where both the House and Senate have established their own MAHA caucuses. This coordinated effort means that businesses may face new requirements from both regulators and policymakers.
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