Executive Summary 

• The Trump Administration released the “Make Our Children Healthy Again: Strategy Report,” the follow-up report to the Make America Healthy Again (MAHA) Commission’s “Make Our Children Healthy Again: Assessment,” containing policy recommendations in support of the Assessment. 
• The Strategy Report contains more than 120 recommendations spanning multiple federal Cabinet departments and agencies to identify mostly executive actions to address the proclaimed childhood chronic disease crisis. 
• These recommendations should be interpreted as an opening salvo of regulatory activity aimed at demonstrating progress on the declared childhood chronic illness crisis; implementation uncertainty around the goals in the Strategy Report will remain the default policy environment for the foreseeable future. 

Introduction 

The Trump Administration on September 9 released the “Make Our Children Healthy Again: Strategy Report,” the follow-up report to the Make America Healthy Again (MAHA) Commission’s “Make Our Children Healthy Again: Assessment,” containing policy recommendations in support of the Assessment. The Strategy Report, which is filled with more than 120 recommendations, elevates executive actions that various Cabinet departments and agencies will take to address the proclaimed childhood chronic disease crisis. These recommendations should be interpreted as a roadmap of agency regulatory activity intended to address childhood chronic illness. This regulatory action – which relies predominantly on existing authorities – is projected to take several forms. For example, long-established scientific agencies are being instructed to expand the scope of their traditional remit. While potentially resourced to do this, the addition of responsibilities will divert these resources and personnel from other administration priorities. 

While the report’s proposals can generally be accomplished without Congress – which portends swift action on certain items – some policies (such as the establishment of the Administration for a Healthy America (AHA)) will require legislative activity for initial action and/or long-term implementation across administrations. Other than any regularly established notification or personal contact from regulatory staff, Congress will not be asked to contribute to the implementation of a vast majority of the Strategy Report. It also appears very unlikely that the administration will seek public input on these actions, as the policy goals laid out in the report appear to be targeted at interest groups and other inside-the-beltway constituents rather than the broader public. 

Though the Strategy Report’s action items are fairly clear in their goals, implementation uncertainty – particularly around responsible parties and methodologies – will be the default policy environment for the foreseeable future. 

How We Got Here 

President Trump created the MAHA Commission by Executive Order 14212 on February 13, 2025, chaired by Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. and staffed by senior White House officials and multiple Cabinet agencies. The order tasked the commission with delivering two products on the proclaimed childhood chronic illness crisis: an initial assessment of the state of the crisis within 100 days and a government-wide strategy to address the crisis within 180 days. 

On May 22, 2025, the commission published the “Make Our Children Healthy Again Assessment,” a supposed baseline diagnosis of rising childhood chronic disease. It spotlighted four recurring drivers: poor diet, cumulative chemical exposures (e.g., PFAS, pesticides, heavy metals), stress/physical inactivity, and over-medicalization (including pediatric use of prescription drugs). The assessment also directed agencies to coordinate a follow-on Strategy Report later in the year. 

This Strategy Report pivots from diagnosis to execution across four pillars – advance research, realign incentives, increase public awareness, and foster private collaboration – with a heavy emphasis on doing more under existing authorities.  

Initial Reactions 

The Strategy Report is ambitious in scope but largely leans on existing authorities. The report offers a greater focus on communications, targeted enforcement, and incremental food policy, while the biggest swings will be slower and require new authorizing language or appropriations. Thus, much of the agenda in this Strategy Report can be accomplished without congressional input. There are several overarching themes that seem to connect the various actions to which the MAHA Commission has committed: 

• Promoting the National Institutes of Health (NIH) as a research entity, a convener, and a cross-government analysis hub for chronic disease data and policy formulation alike. 
• Overhauling food policy through coordination with the United States Department of Agriculture (USDA), the Food and Drug Administration (FDA), and Environmental Protection Agency (EPA). 
• Enhancing conflict-of-interest transparency, consumer protections, and advertising enforcement with joint efforts by FDA, the Federal Trade Commission (FTC), and the Department of Justice (DOJ). 

It is interesting to consider the scope of these policy recommendations. Though purported to be addressing the childhood chronic illness crisis, the data sets named for analysis, the regulatory actions proposed, and ultimately the largest impacted population of these goals are not children, but adults. Whether because of the role that adults have in children’s lives (such as the provider of food and medicine) or the agencies that are implementing the report’s proposals (Veterans Affairs, FTC, and DOJ), it seems unlikely that full implementation of the MAHA Strategy Report will address the childhood chronic illness crisis as desired. 

The Report 

Advancing Critical Research to Drive Innovation 

The strategy’s research pillar aims to shorten the distance between the questions families face and the evidence regulators, clinicians, and payers need to act. It begins by directing NIH to launch a MAHA Chronic Disease Initiative organized around a “whole-person health” prevention lens and is designed to align disparate portfolios into a coordinated program with clear outputs. A centerpiece is a Real-World Data Platform (RWDP) that links claims, electronic health records, and consumer/wearable data under standardized, privacy-protective agreements. By reducing data friction and duplicative work, the RWDP is meant to accelerate observational studies, pragmatic trials, and post-market safety research relevant to children and the conditions that emerge from childhood into adulthood. 

The plan also scales new approach methodologies (NAMs) across NIH, EPA, and FDA – such as organoids, microphysiological systems, in-silico models, and other non-animal tools – to make toxicology and therapeutic development more predictive for human biology. Building on NAMs, EPA, the USDA, and NIH will stand up a cumulative exposure framework that looks at chemical classes and common modes of action rather than one-by-one assessments, improving how risks of pesticides and other contaminants are evaluated. 

Targeted research tracks will aim to fill chronic evidence gaps. HHS/NIH (with the Centers for Medicare and Medicaid Services (CMS)) will push autism etiologies using the RWDP; HHS/NIH will also develop a vaccine injury research program to improve understanding of rare adverse events and inform safer immunization strategies. Environmental threads include water quality work (with a specific look at fluoride and per- and polyfluoroalkyl substances (PFAS)), air quality effects on child health, and microplastics/synthetic fibers risk characterization. In clinical areas, the Strategy Report calls for nutrition science (including food-as-medicine outcomes), repurposed drugs for chronic disease prevention/management, the oral-systemic disease connection (e.g., periodontal health and cardiometabolic risk), and a pediatric gut microbiome initiative. 

To enrich pediatric longitudinal evidence, the Department of Veterans Affairs (VA) will provide de-identified data (e.g., from the Civilian Health and Medical Program of the Department of Veterans Affairs (CHAMPVA)) to NIH, while NIH strengthens clinical-trial networks by leveraging large integrated systems (including the VA). Additional meta-research priorities include a review of electromagnetic radiation exposure science, expanded mental health/addiction research with a focus on screen time, and a quality audit of rural and tribal health research. 

Finally, the pillar elevates artificial intelligence-enabled discovery – starting in pediatric/young-adult cancers – to identify risks earlier, personalize interventions, and optimize trials. Complementary capacity-building steps include creating NIH offices focused on research innovation, validation, and application (a NAMs hub) and portfolio planning and meta-science (to improve prioritization, reproducibility, and replication). In short, the research agenda prioritizes methods and infrastructure that can deliver decision-grade evidence quickly, with tangible lines of sight to regulatory standards, coverage policy, and front-line clinical practice. 

Realigning Incentives and Systems to Drive Health Outcomes Research to Drive Innovation 

This pillar bundles rulemaking, program guidance, enforcement, deregulation, data policy, and organizational reform to move the health care system toward healthier defaults. On food and labeling, USDA/HHS will refresh the 2025–2030 Dietary Guidelines for Americans (DGA) and reform the advisory/process; FDA will work toward a front-of-pack final rule; and agencies will craft a U.S. definition of ultra-processed food to ground research and future policy. FDA will strengthen post-market review of food chemicals, pursue Generally Recognized as Safe (GRAS) reform (mandatory notification and transparency), and move to limit or prohibit petroleum-based food dyes while expediting natural-color petitions and clarifying related claims. FDA will also modernize infant-formula requirements and contaminant testing. Programmatic nutrition moves include raising breastfeeding support, aligning VA meals to DGAs, and promoting healthy hospital food with transparency for patients. 

Beyond food, the report leans heavily on targeted enforcement using existing authority. The FDA, FTC, and DOJ will increase oversight of direct-to-consumer (DTC) prescription drug advertising, including influencer and telehealth marketing on digital platforms. HHS/FTC will explore industry guidelines to limit child-directed junk-food marketing and scrutinize misleading imagery/claims. Governance proposals tighten conflict-of-interest controls (public reporting of payments, stronger recusal rules) and review agency participation in foundation-funded projects. NIH is tasked with curbing excessive open-access publishing payments and implementing “gold-standard science” mechanisms: systematic reviews, incentives for replication, and scholar programs to improve evidence quality. 

Coverage and measurement tools shift attention from utilization to outcomes. CMS, working with states, will refine Medicaid/CHIP pediatric quality metrics (e.g., predicted VO₂ max) and develop prior-authorization safeguards around common pediatric prescribing. The plan also calls for modernizing over-the-counter sunscreen policies, enforcing hospital/insurer price transparency, and expanding access to direct primary care within existing statutory flexibilities. 

A substantial deregulatory slate targets bottlenecks that burden small producers and slow innovation: streamlining organic certification and community-supported agriculture rules, digitizing USDA applications, improving access to credit and land, easing barriers for small dairy and very small meat processors, enabling mobile groceries in food deserts, and updating standards of identity and legacy paper submissions at FDA. At FDA specifically, process updates aim to accelerate safe access to medical products, including broader use of non-animal data, risk-based Phase I flexibilities, digital health modernization, support for regenerative medicine as evidence matures, and a national-priority voucher pilot for products aligned to public-health goals. EPA process improvements include faster predictable approvals for agricultural inputs and clarifying when rinse/wash water is non-hazardous to reduce unnecessary wastewater burden. 

Two cross-cutting organizational items close the section. First, Government Data for Research will review and revise policies that unnecessarily constrain publication/sharing of de-identified datasets. Second, HHS will develop a plan to create the aforementioned AHA to coordinate chronic-disease actions; EPA will refocus applied science functions; and NIH will stand up new offices (innovation/validation and portfolio/meta-science). 

Increasing Public Awareness and Knowledge 

This pillar tackles the credibility gap head-on by pairing trusted messengers with practical, plain-language tools that families and schools can use immediately. At the center is a Make American Schools Healthy Again campaign, a partnership among USDA, HHS, the Department of Education (ED), and the President’s Council on Sports, Fitness & Nutrition (PCSFN). States and districts will receive toolkits to increase daily physical activity and improve school nutrition options, connecting classroom routines with broader community health goals. 

To anchor communication in transparent facts, EPA – supported by other agencies – will expand America’s Children and the Environment (ACE), a national indicator platform focused on environmental and child-health metrics. ACE will compile and visualize data from multiple sources, generate periodic reports, and publish story-map-style explainers so technical information is digestible for the public while remaining squarely within statutory roles. HHS and EPA will also co-lead the President’s Task Force on Environmental Health Risks and Safety Risks to Children, using it as an interdepartmental clearinghouse to align messages, coordinate timelines, and avoid mixed signals. 

USDA and HHS will run a multi-theme DGAs education push – “Food for Health,” “Real Food First,” and “Healthy Foods and Healthy Families” – emphasizing whole-food patterns, cooking skills, and the link between diet and chronic disease. Complementary risk-communication tracks clarify the roles of agencies on fluoride and water safety and explain how pesticide reviews work (e.g., modes of action, cumulative exposure), so families understand what’s being done and why. 

The report also restores national fitness branding. For example, the PCSFN will relaunch recognition programs, such as a Presidential Fitness Award, consistent with a recent executive order. Meanwhile, the Surgeon General will lead campaigns on screen time and the effects of alcohol, controlled substances, vaping, and THC on developing brains – areas where clear, consistent messaging can shift behavior quickly. 

Several items blend communications with protective action. FDA will increase enforcement against illegal vapes and issue a public warning on dangerous substances such as 7-hydroxymitragynine marketed online. FDA will also update OxyContin labeling to warn about chronic-use risks, while HHS funds overdose-response training and naloxone supplies for schools and public libraries. Finally, NIH will publish public-facing clinical transparency reviews, defined as concise, balanced evidence summaries to help patients and clinicians make better treatment choices. 

Fostering Private Sector Collaboration 

The collaboration pillar treats industry, providers, and community organizations as force multipliers for healthier defaults – favoring voluntary, scalable partnerships over new mandates. HHS will leverage available funding (consistent with statute) to catalyze community-level transformations aimed at measurable reductions in childhood chronic disease. A typical bundle pairs school-day activity (e.g., movement blocks and after-school programs) with pediatric-team counseling that engages parents on nutrition, sleep, and screen time, supported by community health navigators who help families adopt and sustain changes. Success is defined by concrete outcomes (fitness, healthy weight, school attendance), not program volume. 

The government will also use its purchasing and convening power to expand access to whole, healthy foods. HHS, USDA, ED, VA, DOJ, and the Department of Defense will coordinate across government-funded meal programs – from schools to VA hospitals to corrections – to raise the nutritional floor and normalize better defaults for populations in need. In the private marketplace, HHS and USDA will partner with restaurants to promote age-appropriate kids’ options consistent with DGAs, leveraging menu-labeling norms, point-of-sale nudges, and industry toolkits that make healthier swaps easy to implement without eroding margins. 

Recognizing that family formation is a health outcome too, the plan launches a fertility-health track: a national education campaign on modifiable risk factors for women and men; an HHS Root Causes of Infertility prize challenge to spur prevention-focused research and solutions; and a new Infertility Training Center to equip Title X clinics to better screen, counsel, and coordinate care for patients seeking to conceive. 

On the supply side of healthier food systems, USDA and EPA will scale producer-friendly conservation and productivity partnerships. Priorities include soil-health stewardship and expansion of voluntary programs such as the Environmental Quality Incentive Program and Conservation Stewardship Program; disseminating field-tested practices that improve yields while reducing erosion and nutrient loss; and promoting pollinator-friendly habitat. Technical assistance will be modernized with mobile/digital planning tools so producers get site-specific advice quickly. 

Finally, the pillar embraces precision agriculture to reduce total pesticide volume while maintaining yields, such as targeted drone applications, computer-assisted spray systems, robotic monitoring, and adjacent innovations. Federal partners will help de-risk adoption by coordinating research, validation, and cost-share mechanisms with states, producers, and ag-tech firms.  

What’s Next? 

Already, the administration has acted on a long-time goal of the MAHA movement and promised a crackdown on DTC pharmaceutical advertisements. We should expect this to be an opening salvo of regulatory activity aimed at addressing the declared childhood chronic illness crisis. Industry should be prepared for shifting metrics of compliance and accountability, regulatory actions on labeling and safety disclosures, and product and chemical reviews. Implementation uncertainty around the goals in the Strategy Report, including from the agency desire for voluntary and compulsory action and sometimes questionable interagency authority, will remain the default policy environment for the foreseeable future.