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The Leaked Draft MAHA Strategy Report Falls Short By Not Adding Powerful New Common Sense Solutions to Address the Celiac Crisis for 729,000 American Kids

  • Writer: Jon Bari
    Jon Bari
  • 4 days ago
  • 5 min read
Jax Bari and Calley Means
Jax Bari and Calley Means

Unlike the MAHA Assessment Report released on 5/22/25 which expressly mentioned Celiac Disease, food allergies and autoimmune diseases, the leaked copy of the draft MAHA Strategy Report was silent on these chronic childhood diseases (see section "Policy Reforms" starting on page 6).


The key takeaway is that we are very disappointed with the draft MAHA Strategy Report, however, it is just that, a draft.


President Trump's Executive Order: The MAHA Strategy Report

According to the President's Executive Order to establish the Make America Healthy Again Commission on 2/2/25, "The [MAHA] Strategy [Report] shall address appropriately restructuring the Federal Government's response to the chronic childhood disease crisis, including by ending Federal practices that exacerbate the health crisis or unsuccessfully attempt to address it, and by adding powerful new solutions that will end childhood chronic disease."


Celiac Journey's Common Sense Solution for the MAHA Strategy Report

We had respectfully requested that the MAHA Commission include something along the lines of these 120 words:


"To Make America Healthy Again for 3.3 million Americans with Celiac Disease, including about 729,000 children, the Secretary of Health and Human Services will prioritize a public health problem long overdue for robust action: reducing chronic diet-related disease by requiring the labeling of Gluten-containing grains (wheat[1], barley, rye and oats) on all packaged foods in the United States, just like gluten must be declared on all food labels in 87 other countries. It's time for FDA to address this critical consumer protection food safety issue with the urgency it requires and issue rulemaking requiring the labeling of gluten as a "Major Food Allergen" based on the Secretary of HHS's existing statutory authority under the Food Allergen Labeling and Consumer Protection Act of 2004."


Celiac Journey's Common Sense Solution Comports with President's Executive Order on the Content of the MAHA Strategy Report

  1. Our common sense solution to require Gluten labeling falls squarely in line with "restructuring the Federal Government's response to the chronic childhood disease crisis" with Celiac Disease as reported in the MAHA Assessment Report on 5/22/25:

    "Celiac disease rates have increased 5-fold in American children since the 1980s." 


  2. Our common sense solution to require Gluten labeling falls squarely in line with "ending Federal practices that exacerbate the health crisis or unsuccessfully attempt to address it": the voluntary labeling of Gluten as a food allergen. Since Gluten is not declared as a Major Food Allergen in the United States, Celiacs have been forced to rely on products that are voluntarily labeled Gluten Free. Often times, these products are ultra-processed foods that have been specifically created to be marketed in a premium marketplace of high-priced Gluten Free food items.


  3. Our common sense solution to require Gluten labeling falls squarely in line with "adding powerful new solutions that will end childhood chronic disease."


Jax and Jude: Eating Without Fear - Out of the Mouths of Babes

Jax and Jude can help the MAHA Commission show its real impact on kids with chronic disease. With the White House's platform, Jax and Jude tell a powerful story and speak to the chronic childhood disease crisis with diet-related disease.


Our work remains unfinished and ongoing to get the Secretary of HHS to use his existing statutory authority to require the labeling of all Gluten grains since food is our only medicine (for now).


MAHA Strategy Report's Focus on Nutrition & Not Food Safety

The MAHA Strategy Report is more focused on nutrition than safety, at least from the Celiac and food allergy perspective.


Nutrition is fundamental for everyone, and it is important to understand nutritional elements (i.e., calories, ultraprocessed foods, food dyes, etc.). However, for those with food allergies, the concept of making healthy choices is secondary to making safe choices that are free of the said allergen to which their immune system mounts a potentially life-threatening and life-debilitating response. In other words, before even worrying about the nutritional value, those with food allergies must cross a safety threshold as to safe ingredients. Just because some food may be healthy for some, that does not mean that these are safe choices for the those with food allergies.


The Stats Cited by President Trump's MAHA Executive Order & Relevance to Celiac Disease

The following data cited in President Trump's MAHA Executive Order "applies urgently to America’s children," and following each bullet point are notes as to the data's significance and applicability to the Celiac community:

  • 30 million U.S. children (40.7%) have at least one health condition, such as allergies, asthma, or an autoimmune disease. (Note: There are an estimated 729,000 U.S. children with Celiac Disease.)

  • 60% of Americans have at least one chronic disease, and 40% of Americans have two or more chronic diseases. (Note: There are 3.3 million Americans with Celiac Disease, and for example, the estimated prevalence of Celiac Disease in patients with Type 1 Diabetes is approximately 6%. Upwards of 15% of Celiac patients will develop other autoimmune diseases.)

  • 78.8 years is the average life expectancy in the United States, which is below that of other comparable countries where the life expectancy averages 82.6 years. This equates to 1.25 billion fewer life years for the United States population. (Note: A study published in the Journal of the American Medical Association in 2020 found a small but significant increased risk of mortality in people with Celiac Disease.)

  • The United States has the highest age-standardized cancer incidence rate among 204 countries, nearly double that of the next highest rate, with an 88% increase from 1990-2021. (Note: Research published in December 2024 showed that there is a high risk of digestive cancers in patients With Celiac Disease.)

  • 77% of young adults do not qualify for military service in the United States. (Note: According to the U.S. Department of Defense, DoD Instruction 6130.03, Celiac is a disqualifying condition from service in the military (Medical Standards for Appointment, Enlistment, or Induction into the Military Services, Section 5.12.c.(3), May 6, 2018.)


Alternative Pathways to Make America Healthier Again for Celiacs

In addition to the MAHA Strategy Report, there are other pathways that can be taken to Make America Healthy Again for Celiacs including HHS Secretary Kennedy using his existing statutory authority to require the labeling of Gluten as a Major Food Allergen. Alternatively, President Trump could issue an Executive Order to require the labeling of Gluten as a Major Food Allergen.


Additional Resources

  • 3.3 million Americans have Celiac, including 729,000 kids, and must avoid Wheat, Barley, Rye and most Oats.

  • Another 2.4 million have a potentially life-threatening IgE-Mediated food allergy to Wheat, with have a high cross reactivity rate with Barley, Rye and Oats.

  • Another 20+ million Americans eat Gluten Free because of Non-Celiac Gluten Sensitivity and can't eat Wheat, Barley, Rye and most Oats.






[1] Since 2006, Wheat has been required to labeled as a Major Food Allergen, but not Barley, Rye and Oats.

 
 

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Celiac Journey advocates to foster inclusion for those with Celiac Disease in life's everyday activities that involve food, to get more Federal funding for Celiac research that is proportionate to its disease burden and lack of treatment options (health equity), and to get Gluten named as the 10th major food allergen in the US (like Gluten is in Europe and Canada).

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