Comment  for DGAC 2025  from The SMHP

The Society of Metabolic Health Practitioners (SMHP) represents all researchers and practitioners working to improve metabolic health around the world through education, training, and support of evidence-based nutritional approaches, including carbohydrate reduction, as a valid therapeutic option or intervention. It is a coalition of doctors, academics, and other Americans who have had positive health results from adopting a low carbohydrate diet. We appreciate the opportunity to comment to the Dietary Guidelines Advisory Committee for the 2025 Dietary Guidelines for Americans.

Our members have repeatedly asked the DGAC to broaden its criteria for dietary patterns to provide a low-carb option.  Benefits from a low-carb diet include helping people to achieve or maintain a healthy weight, which is one of the USDA’s stated goals for the Guidelines. Low-carbohydrate diets have also been shown, in clinical trials, to reverse pre-diabetes and type 2 diabetes as well as improve the vast majority of cardiovascular risk factors.

We have pointed out to the Committee that 42.4% of Americans are obese and 114 million Americans have pre-diabetes or diabetes. Over a quarter of adolescents aged 12-19 are now pre-diabetic.  They will become fully diabetic adults unless they change course. Combined, an estimated 60% of the U.S. population suffer from one or more diagnosed diet-related health conditions.  If not addressed, these epidemics will only get worse.

Despite our efforts, the DGAC continues to support nutritional guidance that is appropriate only for the less than 40% of Americans who have not been diagnosed with one or more diet-related chronic disease. The current dietary patterns, which the 2020 DGA endorses, recommend a daily intake of between 51% and 54% of calories from carbohydrate.  This high level cannot be tolerated with obesity or diabetes or many other diet-related diseases. In fact, it is clearly evident that maintaining the status quo will not address the rising tide of chronic and debilitating diet-related health conditions. This will only happen with a course correction.

The 2020 Committee unfortunately excluded a large quantity of rigorous, scientific evidence on low-carb diets. We identified at least 65 clinical trials where a diet with fewer than 25% of calories from carbohydrate were tested. Virtually all of these studies were excluded from the Committee’s review. We ask your department to direct the Committee to reopen its review in 2025 in order to consider these rigorous studies on thousands of Americans.

If you decide to continue the direction of 2020, we ask you to consider the consequences of letting federal nutrition guidance continue to ignore the ongoing and growing epidemics of obesity and diabetes. Seven years ago, in 2015, then-HHS Secretary Sylvia Burwell Matthews admitted at a hearing before the House Agriculture Committee that “we are on the wrong trajectory” in addressing these health concerns.  Now, in 2022, the problems are worse. How much worse will they be in 2025, when the next Guidelines are written?

And how, today, do you respond to growing evidence that ties a higher percentage of African Americans, Hispanics and Latinos, American Indians/Alaska Natives, and other vulnerable populations who have chronic diet-related comorbidities, including obesity, diabetes, and cardiovascular issues, to a higher rate of hospitalizations and deaths from COVID-19? This is not something that can be put off by setting up a task force to coordinate Federal nutrition policy between agencies or by accelerating nutrition research. Results from these decisions won’t be available, and won’t be acted on, for many years. The science is available now to help these populations, so why is it being ignored?

If the Dietary Guidelines are not the place to confront the very real health consequences of chronic diet-related diseases, then where should it be done? Ignoring obesity and diabetes as irrelevant to the Guidelines is a travesty for the American people. And this is being made worse as vulnerable people face COVID-19.   The need to directly address the real needs of 60-plus percent of the American people with diet-related conditions by providing meaningful nutritional guidance is the basic issue underlying the debate on the Guidelines. Our nation needs Guidelines that serve the general public—and it’s the majority of the general public who are now sick.  We urge you to create Guidelines that address our current reality, not one from 40 years ago.

Thank you for the opportunity to comment