On May 24, 2025, Robert F. Kennedy, Jr. and the Make America Healthy Again (MAHA) Commission are expected to submit the Make our Children Healthy Again Assessment to President Trump as required by the President's February 13 Executive Order (EO) establishing the Commission.1 The EO directed Secretary Kennedy and the MAHA Commission to assess potential contributors to childhood chronic disease in America, focusing on the American diet, absorption of toxic material, medical treatments, lifestyle, environmental factors, Government policies, and food production technique.
Kennedy's focus on food has been central to his MAHA platform. The HHS Secretary has made several announcements related to food safety and nutrition policy, including the Food and Drug Administration's (FDA) announcement aimed at phasing out petroleum-based dyes from food, launching an investigation for safe, nutritious infant formula, and directing the FDA to change the rules of the "Generally Recognized as Safe" (GRAS) designation. 2 Kennedy has also visited states to promote state and local legislation that removes food dyes and additives from school lunches, bans fluoride in public drinking water, and restricts soda and junk food purchases with Supplemental Nutrition Assistance Program (SNAP) funds. On May 9, 2025, the FDA and National Institutes of Health (NIH) announced a joint nutrition regulatory research program to examine how ultra-processed foods and food additives are affecting health.3
While food safety and nutrition has garnered significant attention from Secretary Kennedy, the idea of creating more nutritious diets in order to promote health is not new. The "food is medicine" (FIM) movement, which gained bipartisan support during the Biden Administration, similarly focused on interventions that respond to the connection between food and health to help prevent, manage, or reverse diet-related diseases.4 These interventions may include medically tailored meals, produce prescriptions, and medically tailored food packages. FIM initiatives have been associated with decreased inpatient hospital admissions, decreased overall healthcare costs, increased medication adherence, and increased diet quality.5
Under the Biden Administration, Congress appropriated funding to HHS to develop a federal strategy to reduce nutrition-related chronic diseases and food insecurity.6 HHS and federal partners implemented a variety of FIM interventions across communities and systems through cross-sector collaboration efforts.7 For more information on FIM models, check out our previous blog post here.
While the FIM and MAHA movements share common goals in improving American diets and health, it remains uncertain how MAHA will influence dietary habits nationwide. Despite the new Administration's multiple FDA announcements aimed at bolstering food safety released in the first 100 days, many of the Administration's new initiatives rely on industry voluntary participation, and there have been few announcements related to new regulations or enforcement. For example, on May 9, 2025, the FDA approved three new natural food dyes, announced as a part of the Administration's larger effort to phase out petroleum-based food dyes.8 While Secretary Kennedy and FDA Commissioner Martin A. Makary claimed this move will aid in the shift away from synthetic food dyes, there currently is not a formal agreement or ban on using artificial dyes in food.9
Kennedy's state tour celebrated state legislation banning food dyes and additives in school meals and, in Utah, banning fluoride in public drinking water. States have also moved to restrict using SNAP benefits to purchase soda and junk food, though some anti-hunger advocates question the legality of these bans. 10
The restructuring ordered by President Trump's EO, "Implementing the President's 'Department of Government Efficiency' Workforce Optimization Initiative" has raised questions about the Administration's ability to reform food policy as proposed. The FIM Initiative created during the Biden Administration is housed in HHS' Office of Disease Prevention and Health Promotion (OASH), which is set to undergo a massive restructuring in accordance with the proposed HHS restructuring. OASH will be combined with Health Resources and Services Administration (HRSA), Substance Abuse and Mental Health Services Administration (SAMHSA), Agency for Toxic Substances and Disease Registry (ATSDR), and National Institute for Occupational Safety and Health (NIOSH) to form the Administration for a Healthy America (AHA).11 The impact of this restructuring on FIM models and interventions is uncertain. Furthermore, some nutrition experts have raised concerns that the recent dismissal of 20,000 federal health workers could jeopardize the objectives of the MAHA Commission.12 For example, FDA has laid off a reported 3,500 employees, including staff in charge of food safety and nutrition policy.
Recent actions by the Trump Administration may also threaten current FIM models provided through state Medicaid waivers. In March 2025, the Centers for Medicare & Medicaid Services (CMS) announced the rescission of health-related social needs (HRSN) guidance issued by the Biden Administration. Under the last administration, states were encouraged to use 1115 waivers to address HRSN, with 18 waivers approved to authorize evidence-based housing and nutrition services for specific high-need populations.13 While existing HRSN approvals remain, CMS states that future requests will be considered on a "case-by-case" basis. In April 2025, the Trump Administration announced the phase-out of Designated State Health Programs (DSHP) funding authority, which may limit states' ability to finance new 1115 initiatives. 14
Footnotes
1. Establishing the President's Make America Healthy Again Commission – The White House
2. MAHA Wins First 100 Days | HHS.gov
3. FDA and NIH Announce Innovative Joint Nutrition Regulatory Science Program | FDA
4. Garfield, Katie, Julia Koprak, and John Haughton. Issue brief. Addressing Nutrition and Food Access in Medicaid: Opportunities and Considerations. The Food Trust, 2022. https://thefoodtrust.org/wp-content/uploads/2022/07/report_addressing-nutrition-and-food-access-in-medicaid_2021.original.pdf.
5. Downer, Sarah, Seth A. Berkowitz, Timothy S. Harlan, Dana Lee Olstad, and Dariush Mozaffarian. "Food is medicine: actions to integrate food and nutrition into healthcare." bmj 369 (2020).
6. Food Is Medicine: A Project to Unify and Advance Collective Action | odphp.health.gov
7. Understanding Food Is Medicine | odphp.health.gov
8. FDA Approves Three Food Colors from Natural Sources | FDA
9. Food companies agree to phase out synthetic dyes, in win for MAHA | STAT
10. HHS Secretary Would Support State Waivers to Ban Soda from SNAP
11. HHS Announces Transformation to Make America Healthy Again | HHS.gov
12. As RFK Jr. pledges food victories, he faces the realities of governing – The Washington Post
13. Section 1115 Waiver Watch: Early Signs Point to New Directions Under Trump Administration | KFF
14. Id. 13
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