Vertical Integration and the Fraud of the Nation’s Nutrition Guidelines

Earthquake Inbound

With President-elect Trump’s massive win in the presidential election, bureaucrats in the federal government are preparing for an earthquake, and also no doubt readying their resistance, but the shaking and rattling is bound to reverberate in state bureaucracies as well, in Wisconsin no less than elsewhere.

That’s because, for the most part, state agencies prefer to take their marching orders from federal agencies rather than from their own state officials. They might exist to serve the people through their elected representatives, but, living Borg-like in their own insulated reality, they think their reason for being is to advance the causes of the administrative state everywhere—think globally, act globally.

Nowhere is this truer than in our public health agencies, and one stark example from that universe is federal nutrition guidelines, where on the federal level noble-sounding slogans mask sinister conflicts of interest to literally cook the books, and where on the state level the money-based recipes for good living are pawned off by state regulators so expertly that they are embraced even by some conservatives.

In the hours after Trump was elected, Robert F. Kennedy, Jr., whom Trump has said will play a leading role in reshaping federal health policies, fingered nutrition explicitly: “In some categories … there are entire departments, like the nutrition department at the FDA (Food and Drug Administration) … that have to go, that are not doing their job, they’re not protecting our kids.”

The FDA has for decades served to promote corporate and bureaucratic interests—to feather the nests of special interests while simultaneously bolstering bureaucratic control of the American people’s health—and nutrition is no exception. Indeed, there is no better place than the government’s nutritional guidelines to illustrate not just massive government failure to protect the American people but the FDA’s enslavement to ideological interests that actively undermine public health.

The poster child for failure is obesity, which has soared generally but especially so among children. According to the Centers for Disease Control’s (CDC ) National Health Statistics Report, obesity among children aged 2–19 years soared to 19.7 percent in 2020 from 5.2 percent in the early 1970s. Among adults aged 20 and over, obesity prevalence was 41.9 percent.

This despite—arguably because of—the government’s nutrition guidelines, which are institutionally the biggest factor in the food consumption behavior of Americans. As the educational group Nutrition Coalition points out, those guidelines are distributed to each K-12 school in the country and to doctors, nutritionists, dietitians and other health professionals.

The guidelines are much more than guidelines, in fact, they are the foundation of all federal nutrition programs, which impact a quarter of the U.S. population, including the National School Lunch Program, the supplemental Nutrition Assistance Programs, special Nutritional Program for Women, Infants and Children, and food programs for the elderly.

Problem is, a lot of it could be bunk.

Have Evidence, Will Ignore

Testifying before Congress in 2019, the Nutrition Coalition’s executive director, Nina Teicholz, pointed to a 2015 congressionally funded study by the National Academies of Sciences, Engineering, and Medicine (NASEM) that offered up the first-ever outside peer-review of the nutrition guidelines process. That study ultimately led to 11 recommendations to the U.S. Department of Agriculture to reform the process of formulating the guidelines, which still have not been implemented.

The lack of reform was unfortunate, Teicholz testified, because the guidelines—which cap caloric intake of saturated fats and ignore the potential benefits of low-carbohydrate diets, all the while failing to condemn ultra-processed foods—had for 35 years ignored clinical trial evidence, the gold standard of scientific research.

“Indeed, multiple trials did not confirm that a diet restricted in fat or saturated fat could protect against diet-related diseases,” she said.

The final 2020 guidelines—they are issued very five years—retained a cap on saturated fats that an array of scientists and studies say is not supported by the available science. And Nutrition Coalition asserts that, for the upcoming 2025 guidelines, the committee’s “criteria appear likely to continue to exclude clinical trials on low-carbohydrate diets despite more than 100 of them that show the diets to be safe and effective for combating obesity, diabetes, and heart disease.”

That’s not all. In October, the panel concluded that there just wasn’t enough evidence to recommend against ultra-processed foods such as soda, frozen dinners, breakfast cereal, and flavored yogurt.

As for the process for coming to conclusions, a 2023 NASEM update concluded that “the proposed analytic and methodologic improvements to the DGAC (Dietary Guidelines Advisory Committee) process had largely not yet been achieved.” Among other things, the 2022 final report found a lack of scientific inquiry: “The only substantial input from scientific experts outside of the federal government to the 2020–2025 DGAC process was provided by the members of the DGAC.”

No Transparency but Many Conflicts

That’s unfortunate because the dietary guidelines committee has been riddled with conflicts of interest among its members. One study, led by a researcher from Trinity College in Dublin, “Conflicts of interest for members of the US 2020 dietary guidelines advisory committee,” found that 95 percent of the committee members had associations with big food or pharmaceutical companies, including Kellogg, Abbott, Kraft, Mead Johnson, General Mills, Dannon, and the International Life Sciences.

Those conflicts of interest have apparently continued on the 2025-2030 committee, so much so that U.S. Sen. Chuck Grassley (R-Iowa) sent a letter last year to the secretaries of Agriculture and Health and Human Services demanding transparency. Grassley was especially concerned after Dr. Fatima Cody Stanford was appointed to the committee.

“Recently appointed DGAC member Dr. Fatima Cody Stanford has been paid tens of thousands of dollars by drug makers that manufacture weight loss and obesity drugs, including the producers of Semaglutide and Ozempic,” Grassley wrote. “She has also promoted these products in media appearances. These facts raise concerns about financial ties and potential conflicts of interest that bear on her judgment as a member of the DGAC.”

In response, the government released a four-page aggregate compilation of apparent conflicts of interest but did not release individual names tied to those conflicts. The same large number of conflicts appeared as in the committee’s previous iteration—members had a host of connections to corporate entities, from receiving grants, contracts, royalties, and honoraria to travel expenses, board memberships, and other perks. What’s more, the organization U.S. Right to Know asserts, besides lacking individual identification, the disclosures were voluntary and only covered the last year.

U.S. Right to Know thus conducted a deeper assessment of those conflicts, an assessment that told a disturbing story. Among nine of 20 members, it found, there were eight conflicts of interest with food giants, three conflicts with pharmaceutical companies, and two with weight loss companies.

“Four of the 20 members had possible conflicts of interest with food and pharmaceutical companies or organizations that had a history of corporate sponsorship and lobbying in the development of the guidelines,” the report stated.

Multiple committee members had ties to Abbott (which manufactures infant formula), Novo Nordisk, Eli Lilly, and Weight Watchers International. Multiple members also had associations with the American Society for Nutrition and the Academy of Nutrition and Dietetics, the latter a powerful professional nutrition association that has lobbied on the guidelines on behalf of its many corporate sponsors.

A quick look at the Academy of Nutrition and Dietetics (AND) begins to show how the bureaucratic stranglehold takes effect on the state level. The name of the group sounds noble enough, and every year it sponsors National Nutrition Week. It lauds the eating of fresh fruits and vegetables, whole grains, “healthy” fats, and natural sweeteners. The group is as wholesome as a garden green salad, right?

Unfortunately, National Nutrition Week pushes the same diet as the government does, and many say the reason is that AND is a shill for Big Food and Big Pharma.

A 2022 study in Public Health Nutrition, “The corporate capture of the nutrition profession in the USA: the case of the Academy of Nutrition and Dietetics,” broke it all down. Analyzing documents obtained through Freedom of Information requests from 2014 to 2020, the study found that AND leaders held “key positions in multinational food, pharmaceutical or agribusiness corporations,” and AND also accepted corporate financial contributions.

More shockingly, AND wasn’t just a recipient, it was an investor in corporations such as Nestlé, PepsiCo and multiple pharmaceutical companies. As the study stated, AND is one of the more influential professional health associations in the U.S.

“It is the largest US-based organization comprised of food and nutritional professionals, with approximately 100 000 dietitians and nutrition practitioners and students,” the study stated. “… It is established as a 501(c)(6) trade association and certifies dietitians and nutrition practitioners in the USA and abroad.”

Its influence is felt not least in the formulation of U.S. dietary guidelines, and the study demonstrated just how symbiotic the relationship between the development of the guidelines and Big Food and Big Pharma are.

It should be noted that AND rejected the report’s conclusions, calling it “a calculated attack against the more than 112,000 credentialed nutrition and dietetics practitioners whom the Academy of Nutrition and Dietetics proudly represents. The report contains numerous factual and methodology errors, omissions and information taken out of context.”

The group also contended that its corporate sponsorships were minimal compared to its overall funding.

Perhaps its investments don’t color its work, but I was always told that the perception of a conflict is as bad as a real conflict, and the facts of its partnerships are irrefutable. For example, in 2013, the AND Foundation announced a partnership with Kraft to promote some of Kraft’s products, including Krafts Singles. Here’s how the New York Times put it in 2015:

“Kraft Singles, those individually wrapped slices of processed cheese that have long been a staple of school lunches, are the first product to earn a nutrition seal from the Academy of Nutrition and Dietetics, the trade group representing 75,000 registered dietitians and other nutrition professionals.”

The stamp of approval was later withdrawn after an outcry. And there is much more, including a 2015 email obtained by U.S. Right to Know, in which AND leaders discussed a collaboration with Abbott to promote the use of Pediasure, an Abbott nutritional supplement for children, in pediatricians’ offices, along with a retailer campaign.

Abbott at the time had a two-year, $150,000-a-year sponsorship deal with AND.

A Helping of Vegetables and Big Government

All of which brings us to Wisconsin. While conflicts of interest rage at the federal level, the noble-sounding sloganeering often enough escapes scrutiny at the state level. The Wisconsin Academy of Nutrition and Dietetics (WAND), the state affiliate of AND, is one of the major groups arguing for the government’s nutritional guidelines, and, as such, the state’s Department of Health Services (DHS) is one of its biggest promoters.

The DHS website directs consumers repeatedly to WAND for nutrition advice (“daily tips for healthier eating, fad diets, and links to registered dietitians in your area”), WAND’s Health Aging Dietetic Practice Group, and others. And, of course, who can oppose Malnutrition Awareness Week or National Nutrition Month, which was created by AND? Not Gov. Tony Evers, who issued proclamations for them both, as well as lauding AND.

Many Republicans have also embraced both WAND and the government’s guidelines unquestionably. Partly that’s because WAND makes sure to shower Republican lawmakers with awards, but it goes deeper than that.

In 2017, a bipartisan school nutrition bill roared through the Republican-controlled legislature and was signed by a Republican governor. Ostensibly the bill was to update an obsolete mission statement for school nutrition education, and it did that, but it did more: It explicitly tethered the state’s school nutrition instruction in health classes to the U.S. dietary guidelines.

In other words, the law now allows no deviation from those guidelines, and if they are wrong, and if they are shaped by corporate influence more than anything else, then the instruction is wrong. The evil of saturated fats will be taught as science-based fact. The evil of low-carb diets will be taught as science-based fact. Ultra-processed foods—no evidence that they are harmful.

One of the principal supporters of the bill? The very virtuous sounding Wisconsin Academy of Nutrition and Dietetics.

Never mind that a law mandating that we teach our children federal government orthodoxy about proper nutrition and diet screams out for school choice. More important is that it illustrates how righteous sounding names can conceal the true intentions of special interests working for their own gain.

It shows how seemingly innocuous bureaucratic campaigns on the state level can actually be examples of dangerous vertical integration—federal mandates, often saturated with the grease of special interest money, trickling down to state agency partners to implement.

I should be clear. Its not that all of the dietary advice is wrong. It’s not even that such groups as AND are corrupted by money—maybe all that corporate money from Big Pharma and Big Food doesn’t influence their policies and work.

It’s that the federal government’s process gives undue weight to those special interests and too little weight to independent scientists in formulating the guidelines, and makes no effort to be transparent about it. It’s that there’s no independent inquiry and no consideration of dissenting scientific opinions.

At the very least, such conflicts need to be disclosed, and the process reformed.

On the state level, it’s a lesson that lawmakers should never take anything coming from state or federal agencies as credible on its face, no matter how noble they sound. Questions always need to be asked. The money trail should always be followed. Lawmakers should always be on the look-out for vertical integration.

The state’s nutrition policies and guidelines—maybe better derived right here by Wisconsin parents, business owners, dietitians, doctors, and other residents—would be a good place to start.