Policy Backgrounder: Key Conclusions of the Make America Healthy Commission Report
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Policy Backgrounders

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The Make America Healthy Again Commission released its inaugural report. The report, authored by senior-level officials across the Federal government, outlines a path for the government’s role in diagnosing and addressing childhood chronic diseases and has drawn scrutiny for aspects of its findings from stakeholders, including those related to industry practices. The Commission will now develop a Strategy which is expected to guide future rulemaking.

Key Insights

  • The report focused on what it terms four key drivers of childhood chronic diseases: poor diet, exposure to environmental toxins, lower physical activity, and overmedicalization. While the sources and extent of these drivers’ impact varies, the report emphasizes a greater role for parents, more holistic approaches, and distrust of traditional public health authorities as important factors to consider in pursuit of broader reforms.
  • The report criticizes the private sector, specifically the pharmaceutical, chemical, and food industries. It argues that research, lobbying, and direct-to-consumer advertising have failed to improve health outcomes for American children because of what it terms “corporate capture” of agencies responsible for advancing children’s health.
  • While the public health community endorsed several elements of the report, it also asserts controversial claims on issues such as vaccines and medical research.
  • While the report proposes a limited number of policy recommendations, several indicators throughout the report may signal the focus of future proposals for the Commission, Federal agencies, and Congress as it develops a comprehensive strategy.

Introduction

The President’s Make America Health Again (MAHA) Commission was established through an Executive Order on February 13. While broadly tasked with addressing the health of Americans facing at least one chronic disease, the Order specifically called for the Commission to focus on children’s health. The Commission is chaired by Department of Health and Human Services Secretary Robert F. Kennedy, Jr. and includes representatives of 11 other agencies.

The Make America’s Children Healthy Again report is intended to serve as an initial assessment of how the Administration views key issues facing childhood health, with extensive commentary on how they believe these issues emerged and why they remain pervasive. Now, the Commission will develop a corresponding strategy detailing policy implications and future actions.

Making America’s Children Healthy Again

The introduction outlines what Secretary Kennedy calls an epidemic of chronic disease. It cites rising rates of obesity, diabetes, autism diagnosis, and other conditions, along with lower life expectancy compared to peer countries, as key indicators of the crisis and the need for significant reform. The report asserts that prior generations of Americans, particularly those who lived before the prevalence of ultra-processed foods (UPFs), were healthier, even though life expectancy is higher today than in the 1960s. It cites several developed economies in Europe and Asia as having public health and regulatory frameworks that may serve as models for reform.

The report asserts that these worrying trends have risen for decades alongside larger and more complex pharmaceutical, food, and chemical industries. By outlining trends indicating Americans are less healthy than ever before, it declares that the overall challenge goes beyond health policy and is a threat to economic growth and national security. The report emphasizes what it calls four key drivers of childhood chronic disease.

“Ultra-processed” foods (UPFs)

The report offers a critical examination of the role ultra-processed foods (UPFs) play in children’s diets, highlighting both widespread consumption and significant health implications. Drawing on the NOVA food classification system, it defines UPFs as “industrially manufactured food products made up of several ingredients (formulations) including sugar, oils, fats and salt and food substances of no or rare culinary use.” These foods are often cheaper and safer, but some tend to be high in calories and low in nutritional value. The report argues that greater consumption of UPFs leads to the displacement of whole foods in children's diets and contributes to weight gain and chronic health issues.

According to the report, the US far exceeds peer countries in UPF consumption, a trend the report links to the nation’s higher rates of chronic illness. Beyond calorie content, the report underscores broader nutritional depletion associated with UPFs. The report points to a number of substances—including food dyes, butylated hydroxytoluene (BHT), and artificial sweeteners—as posing potential risks that the Administration has already sought to address.

The report claims the prevalence of UPFs results from systemic issues such as corporate consolidation in the food industry and insufficient independent government research. It criticizes the influence of industry-funded studies that allegedly skew dietary guidelines in favor of commercial interests. It highlights key Federal initiatives including the Dietary Guidelines for America Program (DGA), SNAP, and the National School Lunch Program (NSLP) as needing reform, arguing that they rely on UPFs, produce poor health outcomes, and increase public health care costs. The Federal Supplemental Nutrition Program for Women, Infants, and Children (WIC) is the exception; the report states it has been effective at providing more nutritious foods for populations in need. While language throughout the report seeks to assuage criticism of US agriculture, it specifically calls out subsidies that favor commodity crops over healthier specialty crops, further limiting access to nutritious food in the view of the authors.

Exposure to Environmental Chemicals

The report highlights a range of environmental exposures—including to pesticides, microplastics, dioxins, heavy metals, air pollutants, endocrine-disrupting chemicals, and waterborne contaminants—as significant health risks, particularly for children. It emphasizes that children are uniquely vulnerable to these synthetic chemicals because of their developmental stage and greater exposure relative to body size.

Further, the report emphasizes that current regulatory and scientific approaches often assess chemicals individually, which may not account for the cumulative or synergistic effects of multiple exposures. It highlights that no country, including the US, fully evaluates the combined impacts of these exposures on children’s health. Although chemicals play a key role in food safety and technological advancement, the report identifies a need for improved assessment tools and further research to inform public health responses. It also notes that a significant portion of related studies are conducted by industry, which may bias research design and outcomes, and calls for greater investment in independent research and policy development.

Shifts in Childhood Behavior

The report details what it terms a psychosocial health crisis among American youth, driven by the convergence of increased exposure to digital devices, reduced physical activity, chronic stress, and insufficient sleep. This shift reflects a broader societal transformation toward a sedentary, technology-saturated lifestyle that has reshaped childhood and adolescence. The decline in outdoor play and in-person interaction has coincided with a rise in anxiety, depression, loneliness and other mental health disorders. The report argues that while these trends are irrefutable, over-diagnosis may also play a role and lead to decreased childhood resilience. Despite increased access to therapy, outcomes have not improved significantly, with some analyses suggesting that therapeutic interventions alone may be insufficient—or even counterproductive—without broader environmental and behavioral changes.

The report also highlights the weakening role of family cohesion, indicating a loss of grounding social structures that traditionally supported child development. These overlapping psychosocial stressors, intensified by digital media and cultural shifts, underscore the need for more holistic approaches to youth well-being that go beyond clinical treatment to address lifestyle, environment, and systemic influences.

Further, the report scrutinizes the role of large technology corporations in shaping online experiences, public discourse, and parental authority. Practices such as algorithmic content curation, opaque data flows, and digital “dark patterns”—including systems that allow minors to make purchases or share data without parental consent—are identified as undermining child protection frameworks. During the COVID-19 pandemic, government-agency coordination with tech firms to moderate health content raised additional concerns about censorship and the narrowing of permissible debate. The report suggests that this informal governance model in which platforms operate as de facto public utilities but without democratic oversight erodes transparency and accountability. It calls for a reassessment of regulatory frameworks to address the cumulative effects of digital exposure, bolster independent oversight, and realign tech industry incentives with the mental and social health needs of children.

Overmedicalization

The report raises serious concerns about what it identifies as the “overmedicalization” of American children, portraying it as a systemic issue fueled by industry influence and misaligned incentives within the health care system. It highlights a pattern of overdiagnosis and overtreatment, particularly in areas such as psychotropic medication, hormone therapy, antibiotics, and pediatric weight-loss drugs, that has outpaced global norms and lacks sufficient evidence of long-term benefit. The US prescribes ADHD medications, for example, at higher rates than peer countries, suggesting a distinct trend toward excessive medical intervention. This is not only financially burdensome but also poses direct risks to children’s health, on the assertion that treatments that offer no benefit compared to placebo are, by definition, harmful. The report stresses that these known harms likely represent only a portion of the full picture, with undetected long-term consequences still poorly understood, particularly concerning treatments administered during critical periods of growth and development.

The report scrutinizes the current schedule of childhood vaccines. While it affirms the public health value of vaccines in preventing infectious diseases, it raises concerns about the lack of transparency in vaccine safety monitoring and the limited public access to government-funded data sources including the Vaccine Safety Datalink (VSD). The report also highlights legal and regulatory structures, including liability protections granted to vaccine manufacturers, that it argues may limit accountability. Additionally, it critiques professional disciplinary measures against physicians who question or deviate from official vaccine guidance, suggesting that these policies may constrain scientific dialogue and medical freedom.

More broadly, the report frames these developments within a larger critique of alleged corporate capture in the health care system. It identifies the pharmaceutical industry as the leading force behind this trend, using lobbying, revolving-door employment practices, and media influence to shape health care in ways that prioritize profitability. This dynamic, the report argues, has led to a model that undervalues foundational contributors to child well-being (such as diet, lifestyle, and environment) in favor of pharmacological interventions and overmedicalization. In this view, the decline in children’s health outcomes, despite historically high health care spending, reflects a structural failure rooted in the erosion of independent medical knowledge and public trust.

Stakeholder Reactions

A number of industry groups criticized the report, particularly the allegations of corporate capture and its deleterious impact on children’s health. Despite an attempt to uphold the agriculture industry as the “backbone of America”, various industry associations have denounced the report, decrying specific criticism of commonly used pesticides and other additives as unscientific and fear-based. One notable line of support from various advocacy groups is support for the report’s description of corporate consolidation in food and agricultural systems. While some groups, including membership from the Farm Bureau Federation, have expressed support for building up a fresher and healthier food supply, most have generally urged future policy implications to remain grounded in scientific research and consultation.

Other groups accepted the report’s goal to recognize and address chronic childhood disease, commending the sense of urgency to tackle a crisis. Beyond that, reactions have ranged from skepticism to criticism, even alleging the report fuels medical misinformation. Critics have also noted some contradictions in the report, such as calling for more public research funding while making dramatic reforms to the workforce at key agencies and also noted the omission of important factors such as socioeconomic factors.

Similar to other stakeholders, reactions from Congress have ranged from support to concern. There has been partisan criticism against the Administration’s broader approach to public health, focusing on this specific report using scientifically questionable claims. Republican lawmakers allied with the food and agriculture industry have shared concerns regarding potential restrictions and regulations on commonly used foods and chemicals. Still, the Administration maintains support from lawmakers on critical committees that have applauded the approach and will likely play a key role in MAHA-related legislation.  

Policy Implications and Next Steps

Now, the Commission has 80 days to produce a “Make Our Children Healthy Again Strategy” based on the report’s findings. Next steps that will serve as a baseline for the strategy include  a focus on addressing critical research gaps, improving data monitoring through AI, and introducing alternative testing models for consumer safety.

While there is no clear process for public comment on the strategy, stakeholders, particularly those implicated in the report, will likely seek ways to address its findings and seek points of agreement with the Commission. It will also important to follow closely how state and local governments, including school districts, respond to some of the report’s findings. Some may begin reforms preemptively, such as modifications to vaccine mandates, school lunch purchases, and screen time in the classroom, ahead of what they could be future regulatory changes.

Key Conclusions of the Make America Healthy Commission Report

May 29, 2025

The Make America Healthy Again Commission released its inaugural report. The report, authored by senior-level officials across the Federal government, outlines a path for the government’s role in diagnosing and addressing childhood chronic diseases and has drawn scrutiny for aspects of its findings from stakeholders, including those related to industry practices. The Commission will now develop a Strategy which is expected to guide future rulemaking.

Key Insights

  • The report focused on what it terms four key drivers of childhood chronic diseases: poor diet, exposure to environmental toxins, lower physical activity, and overmedicalization. While the sources and extent of these drivers’ impact varies, the report emphasizes a greater role for parents, more holistic approaches, and distrust of traditional public health authorities as important factors to consider in pursuit of broader reforms.
  • The report criticizes the private sector, specifically the pharmaceutical, chemical, and food industries. It argues that research, lobbying, and direct-to-consumer advertising have failed to improve health outcomes for American children because of what it terms “corporate capture” of agencies responsible for advancing children’s health.
  • While the public health community endorsed several elements of the report, it also asserts controversial claims on issues such as vaccines and medical research.
  • While the report proposes a limited number of policy recommendations, several indicators throughout the report may signal the focus of future proposals for the Commission, Federal agencies, and Congress as it develops a comprehensive strategy.

Introduction

The President’s Make America Health Again (MAHA) Commission was established through an Executive Order on February 13. While broadly tasked with addressing the health of Americans facing at least one chronic disease, the Order specifically called for the Commission to focus on children’s health. The Commission is chaired by Department of Health and Human Services Secretary Robert F. Kennedy, Jr. and includes representatives of 11 other agencies.

The Make America’s Children Healthy Again report is intended to serve as an initial assessment of how the Administration views key issues facing childhood health, with extensive commentary on how they believe these issues emerged and why they remain pervasive. Now, the Commission will develop a corresponding strategy detailing policy implications and future actions.

Making America’s Children Healthy Again

The introduction outlines what Secretary Kennedy calls an epidemic of chronic disease. It cites rising rates of obesity, diabetes, autism diagnosis, and other conditions, along with lower life expectancy compared to peer countries, as key indicators of the crisis and the need for significant reform. The report asserts that prior generations of Americans, particularly those who lived before the prevalence of ultra-processed foods (UPFs), were healthier, even though life expectancy is higher today than in the 1960s. It cites several developed economies in Europe and Asia as having public health and regulatory frameworks that may serve as models for reform.

The report asserts that these worrying trends have risen for decades alongside larger and more complex pharmaceutical, food, and chemical industries. By outlining trends indicating Americans are less healthy than ever before, it declares that the overall challenge goes beyond health policy and is a threat to economic growth and national security. The report emphasizes what it calls four key drivers of childhood chronic disease.

“Ultra-processed” foods (UPFs)

The report offers a critical examination of the role ultra-processed foods (UPFs) play in children’s diets, highlighting both widespread consumption and significant health implications. Drawing on the NOVA food classification system, it defines UPFs as “industrially manufactured food products made up of several ingredients (formulations) including sugar, oils, fats and salt and food substances of no or rare culinary use.” These foods are often cheaper and safer, but some tend to be high in calories and low in nutritional value. The report argues that greater consumption of UPFs leads to the displacement of whole foods in children's diets and contributes to weight gain and chronic health issues.

According to the report, the US far exceeds peer countries in UPF consumption, a trend the report links to the nation’s higher rates of chronic illness. Beyond calorie content, the report underscores broader nutritional depletion associated with UPFs. The report points to a number of substances—including food dyes, butylated hydroxytoluene (BHT), and artificial sweeteners—as posing potential risks that the Administration has already sought to address.

The report claims the prevalence of UPFs results from systemic issues such as corporate consolidation in the food industry and insufficient independent government research. It criticizes the influence of industry-funded studies that allegedly skew dietary guidelines in favor of commercial interests. It highlights key Federal initiatives including the Dietary Guidelines for America Program (DGA), SNAP, and the National School Lunch Program (NSLP) as needing reform, arguing that they rely on UPFs, produce poor health outcomes, and increase public health care costs. The Federal Supplemental Nutrition Program for Women, Infants, and Children (WIC) is the exception; the report states it has been effective at providing more nutritious foods for populations in need. While language throughout the report seeks to assuage criticism of US agriculture, it specifically calls out subsidies that favor commodity crops over healthier specialty crops, further limiting access to nutritious food in the view of the authors.

Exposure to Environmental Chemicals

The report highlights a range of environmental exposures—including to pesticides, microplastics, dioxins, heavy metals, air pollutants, endocrine-disrupting chemicals, and waterborne contaminants—as significant health risks, particularly for children. It emphasizes that children are uniquely vulnerable to these synthetic chemicals because of their developmental stage and greater exposure relative to body size.

Further, the report emphasizes that current regulatory and scientific approaches often assess chemicals individually, which may not account for the cumulative or synergistic effects of multiple exposures. It highlights that no country, including the US, fully evaluates the combined impacts of these exposures on children’s health. Although chemicals play a key role in food safety and technological advancement, the report identifies a need for improved assessment tools and further research to inform public health responses. It also notes that a significant portion of related studies are conducted by industry, which may bias research design and outcomes, and calls for greater investment in independent research and policy development.

Shifts in Childhood Behavior

The report details what it terms a psychosocial health crisis among American youth, driven by the convergence of increased exposure to digital devices, reduced physical activity, chronic stress, and insufficient sleep. This shift reflects a broader societal transformation toward a sedentary, technology-saturated lifestyle that has reshaped childhood and adolescence. The decline in outdoor play and in-person interaction has coincided with a rise in anxiety, depression, loneliness and other mental health disorders. The report argues that while these trends are irrefutable, over-diagnosis may also play a role and lead to decreased childhood resilience. Despite increased access to therapy, outcomes have not improved significantly, with some analyses suggesting that therapeutic interventions alone may be insufficient—or even counterproductive—without broader environmental and behavioral changes.

The report also highlights the weakening role of family cohesion, indicating a loss of grounding social structures that traditionally supported child development. These overlapping psychosocial stressors, intensified by digital media and cultural shifts, underscore the need for more holistic approaches to youth well-being that go beyond clinical treatment to address lifestyle, environment, and systemic influences.

Further, the report scrutinizes the role of large technology corporations in shaping online experiences, public discourse, and parental authority. Practices such as algorithmic content curation, opaque data flows, and digital “dark patterns”—including systems that allow minors to make purchases or share data without parental consent—are identified as undermining child protection frameworks. During the COVID-19 pandemic, government-agency coordination with tech firms to moderate health content raised additional concerns about censorship and the narrowing of permissible debate. The report suggests that this informal governance model in which platforms operate as de facto public utilities but without democratic oversight erodes transparency and accountability. It calls for a reassessment of regulatory frameworks to address the cumulative effects of digital exposure, bolster independent oversight, and realign tech industry incentives with the mental and social health needs of children.

Overmedicalization

The report raises serious concerns about what it identifies as the “overmedicalization” of American children, portraying it as a systemic issue fueled by industry influence and misaligned incentives within the health care system. It highlights a pattern of overdiagnosis and overtreatment, particularly in areas such as psychotropic medication, hormone therapy, antibiotics, and pediatric weight-loss drugs, that has outpaced global norms and lacks sufficient evidence of long-term benefit. The US prescribes ADHD medications, for example, at higher rates than peer countries, suggesting a distinct trend toward excessive medical intervention. This is not only financially burdensome but also poses direct risks to children’s health, on the assertion that treatments that offer no benefit compared to placebo are, by definition, harmful. The report stresses that these known harms likely represent only a portion of the full picture, with undetected long-term consequences still poorly understood, particularly concerning treatments administered during critical periods of growth and development.

The report scrutinizes the current schedule of childhood vaccines. While it affirms the public health value of vaccines in preventing infectious diseases, it raises concerns about the lack of transparency in vaccine safety monitoring and the limited public access to government-funded data sources including the Vaccine Safety Datalink (VSD). The report also highlights legal and regulatory structures, including liability protections granted to vaccine manufacturers, that it argues may limit accountability. Additionally, it critiques professional disciplinary measures against physicians who question or deviate from official vaccine guidance, suggesting that these policies may constrain scientific dialogue and medical freedom.

More broadly, the report frames these developments within a larger critique of alleged corporate capture in the health care system. It identifies the pharmaceutical industry as the leading force behind this trend, using lobbying, revolving-door employment practices, and media influence to shape health care in ways that prioritize profitability. This dynamic, the report argues, has led to a model that undervalues foundational contributors to child well-being (such as diet, lifestyle, and environment) in favor of pharmacological interventions and overmedicalization. In this view, the decline in children’s health outcomes, despite historically high health care spending, reflects a structural failure rooted in the erosion of independent medical knowledge and public trust.

Stakeholder Reactions

A number of industry groups criticized the report, particularly the allegations of corporate capture and its deleterious impact on children’s health. Despite an attempt to uphold the agriculture industry as the “backbone of America”, various industry associations have denounced the report, decrying specific criticism of commonly used pesticides and other additives as unscientific and fear-based. One notable line of support from various advocacy groups is support for the report’s description of corporate consolidation in food and agricultural systems. While some groups, including membership from the Farm Bureau Federation, have expressed support for building up a fresher and healthier food supply, most have generally urged future policy implications to remain grounded in scientific research and consultation.

Other groups accepted the report’s goal to recognize and address chronic childhood disease, commending the sense of urgency to tackle a crisis. Beyond that, reactions have ranged from skepticism to criticism, even alleging the report fuels medical misinformation. Critics have also noted some contradictions in the report, such as calling for more public research funding while making dramatic reforms to the workforce at key agencies and also noted the omission of important factors such as socioeconomic factors.

Similar to other stakeholders, reactions from Congress have ranged from support to concern. There has been partisan criticism against the Administration’s broader approach to public health, focusing on this specific report using scientifically questionable claims. Republican lawmakers allied with the food and agriculture industry have shared concerns regarding potential restrictions and regulations on commonly used foods and chemicals. Still, the Administration maintains support from lawmakers on critical committees that have applauded the approach and will likely play a key role in MAHA-related legislation.  

Policy Implications and Next Steps

Now, the Commission has 80 days to produce a “Make Our Children Healthy Again Strategy” based on the report’s findings. Next steps that will serve as a baseline for the strategy include  a focus on addressing critical research gaps, improving data monitoring through AI, and introducing alternative testing models for consumer safety.

While there is no clear process for public comment on the strategy, stakeholders, particularly those implicated in the report, will likely seek ways to address its findings and seek points of agreement with the Commission. It will also important to follow closely how state and local governments, including school districts, respond to some of the report’s findings. Some may begin reforms preemptively, such as modifications to vaccine mandates, school lunch purchases, and screen time in the classroom, ahead of what they could be future regulatory changes.

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Authors

David K. Young

David K. Young

President

Read BioDavid K. Young

John Gardner

John Gardner

Vice President, Public Policy

Read BioJohn Gardner

Anthony Reyes

Anthony Reyes

Senior Economic Policy Analyst

Read BioAnthony Reyes

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