Last month, Secretary of Agriculture Sonny Perdue announced a number of proposed changes to the organization of the vast federal department he oversees. With its 29 agencies and offices and nearly 100,000 employees, the US Department of Agriculture (USDA) is charged with a wide-ranging mission, from helping farmers to be profitable and environmentally sustainable to ensuring the nutritional well-being of all Americans. And while some of the organizational changes Secretary Perdue is pursuing (which all stem from a March executive order from President Trump) may seem arcane, they will have real impacts on all of us. The proposed merger of two key nutrition programs is a case in point.
The plan involves relocating the USDA’s Center for Nutrition Policy and Promotion (CNPP) into the department’s Food and Nutrition Services (FNS). While FNS is well-known in anti-hunger and agricultural communities for its role in administering nutrition assistance programs, including the Supplemental Nutrition Assistance Program (SNAP), CNPP is less so—though not for lack of impact or importance.
Established in 1994, CNPP is the agency responsible for reviewing and compiling the best available scientific literature on human nutrition, developing measures of dietary quality such as the Healthy Eating Index, and (jointly with the Department of Health and Human Services) issuing the Dietary Guidelines for Americans, the cornerstone of federal nutrition policy and dietary guidance. At a time when more than 117 million Americans—half of all adults—are living with one or more preventable, diet-related chronic diseases, the role that CNPP plays in protecting public health has never been more critical.
Reorganization compromises health without achieving efficiency
In the words of Perdue himself, the proposed reorganizations are aimed at making the USDA “the most effective, most efficient, and best managed department in the federal government.”
To be clear, reorganization (or “realignment”) is not an inherently bad thing. Proposals that could successfully increase the effectiveness and accountability of government agencies without compromising mission or purpose would be laudable. But merging CNPP into FNS accomplishes neither—and follows a dangerous pattern of this administration pushing back on science with its policy agenda. Furthermore, the merger poses serious threats to the scientific integrity of the agency charged with developing evidence-based dietary guidelines for the entire country, for several key reasons:
- FNS and CNPP serve distinctly different purposes. FNS administers 15 food and nutrition programs targeting distinct populations, serving only a fraction of Americans. CNPP develops science-based recommendations designed to identify nutritional deficiencies and address dietary needs at a population level, which are then applied to dozens of programs across the federal government. To conflate the distinct purposes of each agency would be to detract from the efficiency of each.
- The CNPP administrator will lack appropriate credentials to oversee the development of evidence-based national nutrition guidelines. Following the reorganization, CNPP would no longer be headed by a politically-appointed administrator, but instead by a career associate administrator. This individual is highly unlikely to possess the education and level of expertise required by this position.
- Merging CNPP into FNS introduces a conflict of interest. Nutrition programs administered by FNS must adhere to dietary recommendations established by CNPP, introducing a potential conflict of interest. Without clear separation between CNPP and FNS, undue influence on the former by the latter—or even the perception thereof—would present a threat to the integrity of evidence-based recommendations.
The USDA received public comments on this issue between September 12 and October 10. The full comment authored by the UCS Food and Environment Program, outlining the risks to scientific integrity and population health posed by the proposed reorganization, follows.
UCS Comments on USDA Notice, “Improving Customer Service”
October 10, 2017
Dear Secretary Perdue and Acting Deputy Assistant Secretary Bice,
On behalf of the Union of Concerned Scientists (UCS), we are compelled to respond to the United States Department of Agriculture (USDA) notice, “Improving Customer Service,” with concerns regarding the proposed merging of the Center for Nutrition and Policy Promotion (CNPP) into the Food and Nutrition Services (FNS). This proposed action would threaten the scientific integrity of CNPP and compromise public health, while providing zero demonstrable financial or public benefit.
UCS, a science-based nonprofit working for a healthy environment and a safer world, combines independent scientific research and citizen action to develop innovative, practical solutions and secure responsible changes in government policy, corporate practices, and consumer choices. The Food and Environment Program at UCS makes evidence-based policy recommendations to shift our nation’s food and agriculture system to produce healthier, more sustainable and just outcomes for all Americans.
CNPP evidence-based recommendations play a critical role in protecting population health.
The current state of US population health poses enormous costs both to quality of life and health care systems. More than 117 million Americans—half of all adults—are now living with one or more preventable, diet-related chronic diseases, including cardiovascular disease, hypertension, diabetes, overweight/obesity, and certain types of cancer. Recent research shows that dietary factors may now play a role in nearly half of all deaths resulting from heart disease, stroke, and type 2 diabetes. In 2012, the direct medical expenses and lost productivity due to cardiovascular disease alone averaged $316 billion, while those due to diagnosed diabetes totaled $245 billion. In total, chronic diseases account for approximately 86 percent of all US health care expenditures.
However, just as diet is a key factor driving these trends, it also offers great potential to reverse them. The federal government has a critical role to play in promoting health and reducing the burden of chronic disease by supporting evidence-based policies and programs that improve the dietary patterns of Americans. For more than twenty years, CNPP has filled this role. The Nutrition Evidence Library (NEL) at CNPP applies rigorous scientific standards to conduct systematic reviews of current nutrition research, and informs a range of federal nutrition programs, including the National School Breakfast Program, National School Lunch Program, Special Supplemental Nutrition Program for Women, Infants and Children (WIC), and the Supplemental Nutrition Assistance Program (SNAP). Working jointly with the Department of Health and Human Services (DHHS), CNPP is also responsible for overseeing the development of the Dietary Guidelines for Americans, the nutrition recommendations that are a cornerstone of federal nutrition policy and dietary guidance. As an autonomous agency, CNPP is well positioned to deliver unbiased and scientifically sound recommendations to other federal agencies and to the general public.
The proposed merger is unlikely to result in increased efficiency.
As stated in USDA-2017-05399, Executive Order 13781, “Comprehensive Plan for Reorganizing the Executive Branch,” was intended to improve efficiency, effectiveness, and accountability through agency reorganization. However, there is no duplication of function between CNPP and FNS. FNS administers 15 food and nutrition programs targeting distinct populations, serving only a fraction of Americans. CNPP develops science-based recommendations designed to identify nutritional deficiencies and address dietary needs at a population level, which are then applied to dozens of programs across the federal government. To conflate the distinct purposes of each agency would be to detract from the efficiency of each. Changes in allocation of resources from restructuring would also threaten the ability of CNPP to conduct its mission.
The proposed merger threatens the scientific integrity of CNPP, compromising its core function.
Merging CNPP into FNS will weaken the ability of the USDA to provide the most current evidence-based nutrition guidance to federal food and nutrition programs. The change would also jeopardize the ability of CNPP to comply with Congressional mandates, chiefly the National Nutrition Monitoring and Related Research Act of 1990, which requires the establishment of dietary guidelines at least once every five years and the promotion of these guidelines by any federal agency carrying out a federal food, nutrition, or health program.
The proposed reorganization would degrade the scientific integrity and core function of CNPP, particularly if:
- The CNPP administrator lacks appropriate credentials to guide the development of science based recommendations, including the Dietary Guidelines for Americans (DGA).
The CNPP administrator has previously been appointed by the Food, Nutrition, and Consumer Services program. With the proposed reorganization, this position would be filled by a career official lacking necessary technical expertise. In its recent review of the DGA process, the National Academy of Sciences, Engineering, and Medicine (NAS) stated that it is of critical importance that “the DGA be viewed as valid, evidence-based, and free of bias or conflict of interest.” As the individual responsible for overseeing management of the NEL and development of DGAs and other science-based recommendations, the CNPP administrator must have strong credentials, including a background in dietetics, nutrition, medicine, and/or public health, with demonstrated experience relevant to nutrition science/research, population health, chronic disease prevention, epidemiology, economics, surveillance systems, and nutrition communications and marketing. This individual must also possess experience in advanced management and budget oversight; continuous quality improvement; program planning; implementation and evaluation; data analytics; information technology; and public policy.
- There is inadequate separation of agency function, diminishing the autonomy of CNPP.
The application of dietary recommendations in programs administered by FNS introduces a potential conflict of interest. Without clear separation between CNPP and FNS, undue influence on the former by the latter—or even the perception thereof—would present a threat to the integrity of evidence-based recommendations. The development of the DGAs and the USDA Food Plans (e.g. Thrifty Food Plan) are of particular concern, as they inform programs administered by FNS.
The Union of Concerned Scientists appreciates the USDA’s efforts to increase the effectiveness and accountability of government agencies. However, the merging of CNPP into FNS accomplishes neither. The ability of CNPP to effectively and independently fulfill its mission of developing evidence-based dietary guidelines without undue influence may be compromised by: 1) the replacement of an appointed administrator with a career associated administrator who may not possess the qualifications needed to oversee the development of science-based federal nutrition recommendations; and 2) the inherent conflict of interest that occurs by way of FNS oversight over CNPP, as the latter develops guidelines that the former must adhere to in the implementation of various nutrition programs.
Given the alarming trajectory of diet and disease in the US, it is in the best interests of the public and the US healthcare system that CNPP continues to operate independently from FNS to produce evidence-based recommendations for population health. As the Director of the Office of Management and Budget considers proposed agency reorganizations to meet the directive of Executive Order 13781, “Improving Customer Service,” UCS is hopeful that the Director recognizes the magnitude of the potential risks associated with merging these agencies and rejects the proposed action.