2020-2025 DGA: An Informed Look at DGAC Report Translation Into Policy (Part I)

Yes, all may be quiet on the Dietary Guidelines for Americans (DGA) front (out here), but having been there back in 2010 and 2015, I assure you that it’s a combination of “all hands on deck” and “burning the midnight oil” inside the government.

With just under a month and a half to go time, we thought it may be helpful to revisit where we’ve been and what’s going on now.

To review, there are 4 discreet time periods associated with the DGA process.

1. Planning and preparation;
2. Dietary Guidelines Advisory Committee scientific examination;
3. Policy development; and
4. Implementing and disseminating the policy.

Steps one and two are now complete. Step three is in progress as we speak—with the DGA policy document being drafted, reviewed, and cleared. Given that this is the government, there is a process for everything—described in detail below.

Identified government career staff, specializing in nutrition science, have already been designated as part of the writing team. We will not know who those staff are until after the DGA are released, so as to prevent outside influence.

When writing the draft, authors are advised of their responsibility to:

1. Represent the totality of the evidence—revise only those recommendations that are backed with significant scientific justification from the DGAC report. This prevents the policy from including single study findings or opinions;
2. Address the needs of Federal programs—the policy must contain sufficient technical information to provide for scientific basis upon which to inform and drive nutrition and feeding programs.
3. Keep the DGA contents confidential;
4. Mitigate unintended consequences; and
5. Follow best practices for developing guidelines—these include following the evidence, maintaining transparency, managing conflicts of interest, involving stakeholders (e.g., external review), and ensuring the Guidelines are clear, concise, and use plain language strategies.

Writing the draft is a comprehensive process that includes:

• Convening the writing team to discuss the previous DGA edition, scientific report, and public/Agency comments;
• Drafting chapters;
• Chapter reviews completed by writing team members, staff communication specialists, and a science editor;  
• Several rounds of review and revisions, including Federal subject matter experts and Agency representatives to ensure that program needs are met; and
• Design.

Next comes a multi-step, rigorous review process.

1. Federal expert technical review—this includes all Agencies with nutrition policies and promotions across the US Departments of Agriculture (USDA) and Health and Human Services (HHS) and many you have heard from (e.g., NIH, FDA, CDC, FNS, FSIS). All in all, approximately 100 Federal experts participate in the review and revision of the final DGA policy document
2. External peer review—typically, previous DGAC members are tapped for this job
3. Departmental clearance—this, as you would expect, is complex and includes:
   • Agency review – draft is sent to each Agency within USDA and HHS that performs nutrition functions
   •  Administration review – varies across Departments and over time; generally includes:
     • Office of USDA Under Secretary of Food, Nutrition, and Consumer Services (FNCS)
     • Office of USDA Under Secretary of Research, Education, and Economics (REE)
     • Office of HHS Assistant Secretary for Health
     • Staff from the Offices of the Secretary of Agriculture and Secretary of Health and Human Services, as well as communication and government relations staff

The final step is drafting a decision memorandum that goes to each Department’s Secretary, who either approves or disapproves the DGA as written. By this point, this step is typically a formality.

Once approved, the new edition is released and replaces the previous edition. This time it will likely be right under the wire as we ring in 2021. Like many activities in 2020, the 2020-2025 DGA have experienced more than its fair share of outside factors as setbacks to its progress including, but not limited to, the longest Federal shutdown in government history and the COVID-19 pandemic—enough said.

Want to help in promoting, disseminating, and implementing the 2020-2025 DGA? Join the Nutrition Communicators Network. Student of the DGA and this DGA process? See related blog: Why to become a USDA National Strategic Partner NOW