By Holland & Knight’s Public Policy & Regulation Group

The Make America Healthy Again (MAHA) Commission, as established by President Donald Trump’s Executive Order 14212 in February 2025, has released its inaugural report titled “The MAHA Report: Making Our Children Healthy Again.” The Report identifies several factors it argues are driving up rates of chronic disease in the U.S. among children, including ultra-processed foods (UPFs), poor diet and lifestyle habits, environmental exposure to certain chemicals and overuse of certain prescription drugs.

Although the Report’s findings dovetail with many of the same issues U.S. Department of Health and Human Services (HHS) Secretary and MAHA Commission Chair Robert F. Kennedy Jr. has emphasized for years, the Report does not result in any immediate changes to regulatory frameworks for the approval of food additives, prescription drugs, pesticides or other chemicals. However, the Report is likely to be used as a precursor to a comprehensive strategy addressing its findings – expected to be completed in August 2025. The EO calls for a governmental approach that deploys proactive policies as well as a realignment of food, health and scientific systems to prioritize prevention and resilience.

Four Drivers
of Chronic Disease

The Report argues that four key factors contribute to increasing rates of chronic illnesses.

Poor Diet: The Report cites the growing prevalence of UPFs in the diets of Americans as a key driver of chronic disease rates. This includes ultra-processed grains, sugars and fats as opposed to whole foods, as well as the inclusion of additives such as emulsifiers, binders, sweeteners, colors and preservatives. The Report discusses and criticizes the shift in dietary fats from minimally processed animal-based sources to industrial fats derived from refined seed oils such as soybean, corn, safflower, sunflower, cottonseed and canola.

Chemical Exposure: While acknowledging the benefits of industrial chemicals in modern life, the Commission emphasizes that children are uniquely vulnerable to the health risks posed by widespread exposure to synthetic substances, particularly in early developmental stages. Childhood exposure to chemicals including heavy metals, per- and polyfluoroalkyl substances (PFAS), pesticides, microplastics, phthalates, bisphenols and other products through ingestion, inhalation and other means are also cited as a factor behind chronic disease. The Report highlights that more than 40,000 chemicals are registered for use in the U.S. – many of which are found in the blood and urine of children and pregnant women – such as pesticides, microplastics, dioxins and endocrine-disrupting compounds.

Changes in Lifestyle Habits: Lack of physical activity and increasing amounts of time spent online are also listed in the Report, specifically as a detriment to mental health, which has been seen in the form of increased stress, feelings of loneliness and anxiety among children.

Overdiagnosis and Overmedication: The Report cites the prescription of antidepressant, antipsychotic, antibiotic and stimulant medications among children as the final, major contributing factor to rates of chronic disease. Anti-obesity, asthma drugs and vaccines included in the childhood vaccine schedule are also highlighted. The Report cites the need for additional placebo-based, longitudinal and randomized clinical trials to better evaluate the impact of exposure to certain medicines on children’s health.

Additional Critical Findings

Beyond these drivers, the Report focuses on several topics, calling for several significant reforms in food systems, school nutrition programs and federal dietary guidelines. For instance, with respect to UPFs, the MAHA Commission calls for a national shift toward whole foods – which it defines as minimally processed, nutrient-rich options produced by American farmers.

With respect to the growing concern over the cumulative chemical burden American children face in their daily environments, the Commission calls for a reassessment of current regulatory frameworks and scientific methodologies to better understand and mitigate the long-term effects of chemical mixtures on child health. Although some studies show associations with conditions such as obesity, early puberty, infertility and neurodevelopmental disorders, the Commission stresses that more rigorous, long-term research is needed. It also acknowledges that many of these substances are present in everyday items such as food packaging, personal care products and household dust, making exposure nearly unavoidable.

10 Steps to Combat Chronic Disease

The Report concludes by outlining 10 steps the MAHA Commission will take to combat chronic disease:

Address “replication” to ensure scientific results can be reproduced, including studies that were not publicly funded.

Implement new post-market surveillance programs at the FDA and the National Institutes of Health (NIH) to monitor the safety of pediatric drugs.

Expand initiatives linking data from electronic health records, medical claims and other inputs to inform studies of chronic diseases.

Create a federal task force to streamline the use of federal datasets using artificial intelligence (AI) and machine learning technologies.

Reform the generally recognized as safe (GRAS) standard and fund independent studies to evaluate the safety of GRAS-affirmed ingredients.

Fund long-term clinical trials to compare diets in children.

Launch a national initiative to support studies of lifestyle interventions such as by increasing the use of randomized clinical trials into existing clinical trial frameworks.

Support long-term studies on the health impacts of medicines commonly prescribed to children.

Incorporate alternative testing models to complement animal testing in drug development and evaluation.

Initiate a national effort to map toxicological impacts of certain substances on childhood disease.

What’s Next

Based on the Report’s findings, the MAHA Commission will develop and submit a strategy to President Trump, which is expected by August. Many of the 10 steps outlined are already underway across HHS.

Continued effects of reductions in force across HHS, especially at the FDA and NIH, as well as several bills currently under consideration by Congress, will be major factors in determining whether the MAHA Commission’s goals come to fruition. The Report is anticipated to serve as a precursor to further regulatory action and enforcement, as well as future legislative activity from Congress, as many solutions suggested by the Report will require legislation to effectuate.

This article was authored by the following members of Holland & Knight’s Public Policy & Regulation Group: Senior Public Affairs Advisor Jordan Brossi, Partners Michael Werner, Meaghan Colligan Hembree and Rachel Gartner, Senior Policy Advisor Michal Freedhoff, Associates Parker Reynolds and Sara Klock, and Public Affairs Advisor Sarah Starling Crossan.