The Wellness Devil in the Details: HHS’ Nutrition Plan

Physicians don’t receive enough training in nutrition. This has become a flashpoint in Make America Healthy Again (MAHA) and healthcare circles. Fair-minded people can disagree about how much training physicians should have in any particular area, but increasing the amount of nutrition education seems like an unobjectionable idea. However, the devil is in the details of how any new medical education would be rolled out.

HHS recently published its new competencies for nutrition education within medical education. There are 71 competencies that institutions can choose from to help design a curriculum. Some seem like commonsense parts of nutritional education. However, a closer look at others reveals a “Trojan Horse” of unregulated wellness trends, questionable science, and the systematic erasure of registered dietitians (RDNs).

The Definitional Void: The Problem with “Ultra-Processed” Foods

Many of the competencies directly focus on or allude to ultraprocessed foods (#7, #18, #53). This may sound straightforward, but no one can seem to agree on a definition. Indeed, even the document refers to them as both “highly” processed and “ultra-processed.” Without a clear, coherent, and consistent definition, this cannot be discussed or studied, let alone taught.

The FDA and the Department of Agriculture are undergoing a process to create a definition, but we won’t have the administration’s official definition until at least the end of this year. Once there is an established definition, it will take time to conduct research and understand if there is actually a difference between how we’ve defined highly processed foods and minimally processed foods. Nutrition research, famously, takes a very long time to conduct.

Suggesting hours of instruction on a term (“highly processed” or “ultra-processed”) that the FDA and USDA haven’t even defined yet creates a vacuum where unconfirmed science may fill the gaps.

The Erasure of the Registered Dietitian

The HHS framework claims to champion “Interprofessional Referral” in competencies #41 and #43, yet, in this section it conspicuously fails to name the most qualified member of the nutrition care team: the registered dietitian. Instead, the document explicitly directs physicians to collaborate with “health coaches,” “functional nutritionists,” and “functional medicine” practitioners.

This is not a mere oversight; it is a dangerous departure from clinical standards. Registered dietitians are the only health professionals legally and educationally qualified to provide Medical Nutrition Therapy. To become a registered dietitian, one must now earn a Master’s degree, complete 1,000+ hours of supervised clinical practice, and pass a national credentialing exam. In contrast, “health coach” and “functional nutritionist” are largely unregulated titles. In most states, anyone can claim these titles without a single hour of formal clinical training.

By substituting these unregulated roles for registered dietitians, HHS is effectively de-professionalizing nutrition advice. The framework treats nutrition as a wellness hobby rather than a clinical discipline. This irony is highlighted in competency #71 — the only place registered dietitians are mentioned. Here, they are relegated to “billing for nutrition services,” seeming to imply that while registered dietitians are useful for back-office paperwork, the “real” interventional work should be outsourced to functional practitioners.

There is a profound irony in shoehorning unregulated professions into medical education, which is one of the most strictly governed fields in society. We require physicians to endure years of rigorous residency, board certifications, and continuous licensing to ensure patient safety.

Additionally, by including shadowing of “functional medicine” practitioners — a field that often relies on unvalidated tests and expensive, unnecessary supplements — HHS is creating a “Trojan Horse” for alternative medicine. It asks students to treat unregulated practitioners as clinical equals, undermining the very evidence-based rigor that medical school is designed to instill.

The Wellness-to-Medicine Pipeline

I’ve written before about concerns around the Trump administration and the wellness industry. And the competencies only heighten those concerns.

Spattered throughout are jargon laden terms (e.g., epigenetic modulation) that have been co-opted by wellness influencers (see competencies #16–19, #30, and #35–37). These self-identified “hormone” and “gut health” experts are willing to discuss how your diet is throwing your hormones out of whack and making you sick. This is where the nutrition training could get very dicey. When “evidence-based” can be claimed by anyone with a predatory journal link, medical students lose their ability to discern clinical fact from bio-hacking fiction. Nutrition threatens to become yet another area afflicted by our junk science crisis.

This isn’t just about curriculum; it’s about the “de-professionalization” of medical advice. These competencies aren’t strictly focused on teaching our physicians using the best available experts and data. If they were, registered dietitians would be a prominent feature and unregulated professions wouldn’t be mentioned. Physicians-in-training should be trained by experts in the field and informed by the best available evidence. That means clear, coherent definitions, strong evidence, and utilizing the nutrition experts we do have.

Katie Suleta, DHSc, MPH, MS, is a public health expert and science writer specializing in epidemiology and informatics, with a focus on infectious diseases, graduate medical education, and Medicaid data.