From the Scientific Advisory Report to the Dietary Guidelines for Americans:
USDA-HHS Development of the Dietary Guidelines
The Dietary Guidelines provides recommendations on what the average American should eat and drink to promote health and help prevent chronic disease. Since 1985, each edition has been informed by an Advisory Committee’s Scientific Report and consideration of public and Federal agency comments. The Committee’s Scientific Report is not a draft of the Dietary Guidelines. The primary audience of the Committee’s Scientific Report is USDA and HHS. It provides the review of the current state of nutrition science and includes independent, evidence-based advice for consideration as USDA and HHS develop the next edition of the Dietary Guidelines. The primary audiences of the Dietary Guidelines are health professionals and policy makers, including Federal programs, which implement the Dietary Guidelines through the programs and services they provide to the American public.
Developing the Dietary Guidelines involves a step-by-step process of writing, review, and revision supported by a writing team of Federal staff from USDA and HHS. The review culminates with the Secretaries of USDA and HHS. After approval by the Secretaries, the Departments release the Dietary Guidelines to Federal agencies and the public for implementation across programs and through educational activities.
Key Tenets of the Writing Process
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As the Dietary Guidelines are updated, revisions must have sufficient scientific justification. The Departments work to ensure that recommendations are based on the preponderance of available evidence current at the time and not on individual studies or opinion.
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Given that the primary audience of the Dietary Guidelines is the many Federal food, nutrition, health and related programs, it is developed to provide a framework for these programs to tailor and implement to meet the specific needs of their audiences. Thus, the Dietary Guidelines includes technical information to support implementation through policy and programs (e.g., quantitative recommendations for food groups and other components).
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The writing team discusses unintended consequences such as, “Given this advice to do X, what else might the public do or not do? How might it change their dietary behaviors in other ways?” For example, chapter 3 of the 2015-2020 Dietary Guidelines describes that as manufacturers reformulate a food product to improve one aspect to better align with Dietary Guidelines recommendations, care should be taken to consider the overall nutritional profile of the product so that other aspects are not changed in ways that do not align with healthy choices.
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- Leading U.S. and international organizations have established key best practices for developing population-wide health guidance. These central themes are incorporated into the writing process:
- Support transparency
- Manage conflicts of interest
- Organize an effective guidelines development group
- Involve key stakeholders
- Write clear and concise guidelines
- Include external review
- Use evidence to inform recommendations
Institute of Medicine Committee on Standards for Developing Trustworthy Clinical Practice Guidelines. Clinical Practice Guidelines We Can Trust. Washington, DC: National Academies Press; 2011.
World Health Organization. WHO Handbook for Guideline Development. Geneva, Switz.: 2008. - Leading U.S. and international organizations have established key best practices for developing population-wide health guidance. These central themes are incorporated into the writing process:
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Plain language strategies are used whenever possible to be direct and clear in what is meant for its intended audience of policy makers and public health professionals. Plain language principles include minimizing use of jargon and incorporating easy-to-read design elements.
About the Writing Team
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The writing team includes Federal nutrition scientists with expertise in the Dietary Guidelines and related research and programs and communications specialists with expertise in communicating nutrition information
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The role of the writers is to represent the preponderance of scientific information when developing guidance. Writers are not to represent their personal scientific interests or opinions.
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To protect the integrity of the writing process, the membership of the writing team is kept confidential until the release of the Dietary Guidelines. It is not shared among the Federal agencies or outside the Federal government so that these staff are not intentionally or unintentionally targeted or influenced.
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The writing staff are asked to recuse themselves from participating in any activities for which, after their role as a writer is public information, it might be a perceived or real conflict of interest that their confidential knowledge of the draft could have influenced their contributions to another activity.
Writing the Dietary Guidelines
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Prior to writing, the team discusses:
- Major themes from the Scientific Report
- Recommendations from the previous Dietary Guidelines edition that the Committee recommended moving forward with, and those not recommended for moving forward
- Potential changes for the next edition of the Dietary Guidelines suggested by the Committee, including new audiences (i.e, infants and toddlers from birth to 24 months of age)
- Comments from the public and Federal agencies
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The writing team develops and refines the major themes and chapter organization of the Dietary Guidelines. Then, chapter and section writing teams are created among the members based on subject matter expertise and with equal representation across USDA and HHS.
- The writing team members draft and cross-review chapters.
- In addition to a science editor, the communication specialists on the writing team also review the drafts for clarity and completeness of concepts.
- The writing team also consults with additional Federal subject matter experts as needed.
- Ultimately, several rounds of review and revisions occur within the writing team to yield the early chapter drafts. Addressing the agencies’ questions early and throughout the process helps to ensure that the document reflects and meets program needs to the extent possible.
- These discussions contribute to the consensus-building process that occurs across USDA and HHS to ensure that the Dietary Guidelines accurately represents the science and is supported by both Departments
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As the writing is occurring, the Department with the administrative lead coordinates activities to design the publication and produce both digital (online and downloadable) and printable Dietary Guidelines. This step involves developing the visual graphics, figures, photos, and other presentation style elements to support and accurately portray the recommendations.
Review Process
The draft Dietary Guidelines goes through several rounds of review and revisions. For the 2015-2020 Dietary Guidelines, it is estimated that the review and revision phase included more than 100 Federal experts. Ultimately, the document is reviewed by all Agencies with nutrition policies and programs across USDA and HHS, such as NIH, FDA, CDC, FNS, and FSIS. It is also reviewed by external experts to ensure accuracy.
Three-step Review
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The first review is a technical review by Federal scientists, including staff who supported the advisory committee during its deliberations.
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The second review is an external peer-review, including members from previous advisory committees. Additional review by Federal scientists and policy advisors occurs on all or portions of the draft after comments have been addressed.
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The Dietary Guidelines then goes through final Departmental clearance, which culminates with review and signoff by the Secretaries of USDA and HHS. The specific process for Departmental clearance varies depending on the procedures for each Department at the time of the review. However, there are typically two portions to this review:
- Agency Review- The draft of the Dietary Guidelines is sent to each Agency within USDA and HHS; usually, only Agencies with nutrition policies or programs participate in the clearance review. In many cases, the Agency Director/Administrator and subject matter experts within the Agency are sent the draft. If substantive revisions are made to the draft, additional review and clearance may be required. One rationale for the initial rounds of technical review (referenced earlier) is to familiarize Agencies with the draft guidance and engage with them to discuss and resolve issues before the formal clearance step.
- Administration Review- The Administration review varies across Departments and over time.
- Generally, this step includes formal review of the draft by the Office of the USDA Under Secretary of Food, Nutrition, and Consumer Services (FNCS), USDA Under Secretary of Research, Education, and Economics (REE), and HHS Assistant Secretary for Health, and staff from the Offices of the Secretary of Agriculture and Secretary of Health and Human Services, as well as Departmental communication staff, government relations staff.
- As the final step, a decision memorandum is routed through each Department to the Secretary, who either approves or disapproves the Dietary Guidelines. Once approved, the Dietary Guidelines is released.
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Once released, the new edition of the Dietary Guidelines replaces the previous. The release of the new edition is communicated to nutrition and health professionals within and outside of the Federal government for broad implementation.
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The Dietary Guidelines provides the foundation for Federal nutrition and health initiatives. Federal programs apply the Dietary Guidelines to meet the needs of Americans and specific population groups through food, nutrition, and health policies and programs and in nutrition education materials for the public.
- Individual Federal agencies determine how best to implement the new edition to meet the specific needs of target audiences.
- One way to implement to the Dietary Guidelines is through MyPlate, which serves as a reminder to build healthy eating patterns by making healthy choices across the food groups. Both Federal and nonfederal programs use MyPlate as a resource to help Americans make shifts in their daily food and beverage choices to align with the Dietary Guidelines.
- In addition to implementation by the Federal government, ample opportunities exist for many other sectors of society to implement the Dietary Guidelines in the multiple settings they influence, from home to school to work to community.