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4 Assessing the Potential Implications of Fully Implementing the 2017 Recommendations to Redesign the Process to Establish the Dietary Guidelines for Americans: Committee Findings and Conclusions
Pages 63-102

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From page 63...
... . CRITICISMS THAT LED TO THE 2017 NATIONAL ACADEMIES REPORT RECOMMENDATIONS The 2017 National Academies report included a set of seven recommendations that, when implemented together, were designed to enhance the process to create the DGA by "improving transparency, promote diversity of expertise and experience, support a deliberative process, promote independence in decision making, and strengthen scientific rigor" (NASEM, 2017a)
From page 64...
... . The 2017 report committee recommended "strengthening and adopting appropriate and strategic methodologies to align with current best practices," related to systematic reviews, food pattern modeling, descriptive data analyses, and the integration of systems approaches (NASEM, 2017a)
From page 65...
... RECOMMENDATION 1 The committee views recommendation 1 from the 2017 National Academies report as a key, cross-cutting recommendation for redesigning the process for establishing the Dietary Guidelines for Americans. That recommendation proposed a redesign of the DGA process to prioritize topics to be reviewed in each cycle and to redistribute the current functions of the DGAC into three new groups (Box 4-1)
From page 66...
... Dietary Guidelines Planning and Continuity Group (DGPCG) to monitor and curate evidence generation, to identify and prioritize topics for inclu sion in the DGA, and to provide strategic planning support across DGA cycles; b.
From page 67...
... created for monitoring and curating the scientific evidence. Prioritizing topics for inclusion in the systematic reviews and providing strategic planning across cycles continued to be provided by federal staff members.
From page 68...
... , as needed; previous DGACs and TECs [Technical Expert Collaboratives] (by using/ updating their existing NESR [Nutrition Evidence Systematic Review]
From page 69...
... The 2017 National Academies report was delivered to USDA in July 2017, the middle of the second year of the 5-year DGA cycle. At this point, it was too late to create an explicitly constituted TEP to conduct advance preparation for the DGAC, create a new FACA-governed committee, and re-charter an existing FACA-governed committee (see Chapter 2, Appendix B)
From page 70...
... . Specifically, additional staff would be needed to support the activities of a TEP; TEPs are not subject to FACA requirements for transparency; and the systematic reviews that they might support would be undertaken sooner than they are at present, rendering them less timely by the time the DGA are published.
From page 71...
... The committee found that such external expert input is not currently available in the strategic planning process or the prioritization of systematic reviews because the committee does not view public comments as providing input equivalent to that obtained from greater engagement with external subject-matter experts. The committee found that there were barriers related to the timing and cost of implementing this recommendation during the process to develop the 2020–2025 DGA, as well as other, non-trivial barriers to creating an additional federal advisory committee (i.e., the DGPCG)
From page 72...
... .2 Reaching the general public also calls for the support of many different kinds of scientists and healthcare providers. Thus, the committee finds it essential that strategic planning for the DGA and prioritization of the systematic reviews include the perspective of experts who are external to the federal government.
From page 73...
... Before the 2017 National Academies report, stakeholders (e.g., the public, the scientific community, and Congress) expressed concern about the differences between the DGAC Scientific Report and the DGA.
From page 74...
... . The committee's midcourse report highlighted a few additional areas where discrepancies might be interpreted as existing between the 2020 DGAC Scientific Report and the 2020–2025 DGA beyond intakes of added sugars and alcohol (NASEM, 2022a)
From page 75...
... The committee also interpreted this recommendation as a call for the NESR systematic reviews to be conducted with input from experts (i.e., in the form of TEPs as needed) and peer-reviewed by experts who are external to the federal government.
From page 76...
... (NASEM, 2017a) For recommendation 3c, the 2017 report committee specified the role of the proposed DGSAC to be focused on integrating results derived from multiple types of analyses (e.g., original systematic reviews; existing systematic reviews, meta-anal yses, and reports; food pattern modeling; and descriptive data analyses)
From page 77...
... (DGAC, 2020) Recommendation 3b Recommendation 3b is for NEL systematic reviews to be externally peer reviewed prior to being made available for use by the DGSAC.
From page 78...
... (DGA, 2021) In addition, the Departments stated that the DGAC, without support from NESR, Integrated the evidence by looking across all of its conclusions -- from systematic reviews, data analysis, and food pattern modeling -- to develop overarching advice for USDA and HHS to consider as the Departments developed the next edition of the Dietary Guidelines.
From page 79...
... For recommendation 3b, the committee found that peer review of the systematic reviews occurred for the first time (in the history of the DGA) , but it did not have information to identify constraints that would explain why experts external to the Federal government were not included in the review as recommended by the 2017 National Academies report.
From page 80...
... . Alignment with best practices does not mean that NESR must align all practices with those of other leading systematic review groups, as NESR systematic reviews are created for a unique purpose.
From page 81...
... are identified and selected by NESR based on after-action input from experts and NESR staff following the completion of each NESR review project, monitoring of evolutions occurring in the fields of systematic review and nutrition science, and from other key resources, such as the 2017 National Academies report.
From page 82...
... Recommendation 4b Recommendation 4b is enabling engagement with, and learning from, external groups on the forefront of systematic review methods. CQA-IGs are a primary avenue for engaging external systematic review BOX 4-5 Examples of Continuous Quality Advancement Interest Group Topics Topic Addressed Before the DGAC Convened for the 2020–2025 Dietary Guidelines •  isk-of-bias methodology (2017–2019)
From page 83...
... The NESR systematic review methodology was also evaluated by external systematic review experts as part of peer review for publication of NESR systematic reviews in scientific journals. Recommendation 4d Recommendation 4d is investing in technological infrastructure.
From page 84...
... . However, the committee  found methodological differences between NESR practices and those of some leading systematic review organizations, particularly in the method to use and/or update  existing systematic reviews, continuous evidence monitoring, and methodology for assessing evidence quality (NASEM, 2022a)
From page 85...
... population. The 2017 report committee recognized that the food pattern modeling used in the DGA process was generally appropriate and useful for informing decision-making by the DGAC and federal writing team but thought that the modeling could be strengthened (NASEM, 2017a)
From page 86...
... Accordingly, while some modeling might be conducted in advance of the first meeting of the DGAC, the food pattern modeling might be iterative throughout the development of the DGAC Scientific Report and the DGA. The 2017 National Academies report recommended that TEPs be used to supplement the expertise of individuals who make decisions about food pattern modeling groups, specifically to help verify key assumptions in the development of food patterns.
From page 87...
... (Appendix D) In addition: the FPM IG has also evaluated the analytic methods and development of data inputs and constraints for food pattern modeling and are in the process of completing landscape and comparative analyses to compare methods used in the development of guidance in other countries, as well as other modeling exercises described in scientific publications and the recommendations in the 2017 NASEM report.
From page 88...
... However, the lack of full implementation of this recommendation is expected to have implications for the capacity of the food pattern models to reflect the heterogeneity of the population and variability of food patterns and thus, the rigor of the DGA. RECOMMENDATION 6 The 2017 National Academies report called for standardizing the methods and criteria for establishing nutrients of concern both within and across DGA cycles (NASEM, 2017a)
From page 89...
... The 2017 National Academies report suggested that TEPs could be employed to supplement the expertise of groups conducting descriptive data analyses (e.g., to refine research questions so that results would be available for the DGAC [or proposed DGSAC] when it first convenes (NASEM, 2017a)
From page 90...
... Findings As noted in the committee's report, Evaluating the Process to Develop the Dietary Guidelines for Americans, 2020–2025: A Midcourse Report (NASEM, 2022a) , the committee found that the 2020 DGAC Scientific Report (DGAC, 2020)
From page 91...
... . Therefore, the 2017 National Academies report may have served as partial documentation of descriptive data analyses used in prior DGA cycles in the interim.
From page 92...
... . The 2017 report committee did not anticipate that all available systems approaches and methods would be incorporated immediately and instead recognized "that the development and implementation of systems approaches will be gradual, iterative, and occur over a number of years, the foundation for the process will ideally begin with the 2020–2025 DGA cycle" (NASEM, 2017a)
From page 93...
... However, these two constraints likely would not have prevented some movement toward implementation. For example, the expert convening and workshop recommended by 2017 National Academies report should not have been too costly or time consuming to implement.
From page 94...
... The committee also concluded that not having created a DGPCG during the process of developing the 2020–2025 DGA means that the subsequent DGA process has begun without the strategic planning and insights from external scientific experts that could be valuable for the 2025–2030 DGA edition. Conclusions for Recommendation 2 The committee concluded that recommendation 2 was substantially implemented, as the 2020–2025 DGA were largely aligned with the 2020 DGAC Scientific Report.
From page 95...
... Conclusions for Recommendation 4 The committee concluded that recommendation 4 was substantially implemented. The strong CQA initiative to align NESR processes with best practices led to significant refinements prior to conducting the 2020 DGAC systematic reviews.
From page 96...
... These include working with NESR staff members to identify needs for updating NESR's methods and provide oversight of updating of systematic reviews (NASEM, 2017a)
From page 97...
... , food pattern modeling (recommendation 5) , and descriptive data analyses and identification of nutrients of concern (recommendation 6)
From page 98...
... These recommendations were intended to provide the public with a clear explanation when the DGA differed from the DGAC Scientific Report (recommendation 2) , ensure that the systematic reviews created for the DGA align with best practices (recommendation 4)
From page 99...
... and the DGSAC [still operating as the DGAC] relative to the systematic reviews)
From page 100...
... 2022. Modeling dairy-free vegetarian and vegan USDA food patterns for non pregnant, non-lactating adults.
From page 101...
... 2022. Perspective: USDA nutrition evidence systematic review methodology: Grading the strength of evidence in nutrition- and public health-related systematic reviews.


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