Doctors do not receive enough training in nutrition. It has become a landmark in Make America Healthy Again (MAHA) and health care circles. Fair people can disagree about how much physician training should be in any particular field, but increasing the amount of nutrition education seems like an incredible idea. However, the devil is in the details of how any new medical education will be implemented.
HHS recently released its new qualifications for nutrition education within medical education. There are 71 competencies that institutions can use to help design curriculum. Some seem like common sense parts of nutrition education. However, a closer look at others reveals a trojan horse of unregulated health trends, questionable science, and the systematic purging of registered dietitians (RDNs).
Definitional fallacy: The problem with “ultra-processed” foods
Many qualifications directly focus on or refer to ultra-processed foods (#7, #18, #53). This may seem straightforward, but no one can agree on the definition. In fact, the document even refers to them as “highly” processed and “ultra processed”. Without a clear, consistent, and consistent definition, it cannot be discussed or studied, let alone abandoned.
The FDA and the Department of Agriculture are going through the process to develop a definition, but we won’t have an official definition from the agency until at least the end of this year. Once there is a defined definition, it will take time to do research and understand if there really is a difference in how we define highly processed foods and minimally processed foods. Nutritional research, notoriously, takes a long time to conduct.
Offering hours of guidance on a term (“highly processed” or “ultra-processed”) that the FDA and USDA have not even defined creates a vacuum where unproven science may fill in the blanks.
Clearance of a registered dietitian
The HHS framework claims to champion “professional referral” in competencies #41 and #43, yet in this section it clearly fails to name the most qualified member of the nutritional care team: the registered dietitian. Instead, the document expressly directs physicians to collaborate with “health coaches,” “functional nutritionists,” and “functional medicine” specialists.
It’s not just oversight; This 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 accreditation exam. In contrast, “health coach” and “functional nutrition” are largely informal titles. In most states, anyone can claim these titles without an hour of formal clinical training.
By relegating these unregulated roles to registered dietitians, HHS is effectively deprofessionalizing nutrition counseling. The framework treats nutrition as a wellness hobby rather than a clinical discipline. This irony is highlighted in qualification #71 — the only place where registered dietitians are mentioned. Here, they referred to “Billing for Nutrition Services,” suggesting that while registered dietitians are useful for office-based paperwork, the “real” intervention work should be outsourced to active practitioners.
There is a deep irony in the shoe-washing of illegal professions in medical education, which is one of the strictest rules in society. We require physicians to undergo years of rigorous residency, board certifications, and continued licensure to ensure patient safety.
Additionally, by overshadowing “functional medicine” practitioners — a field that often relies on unproven tests and expensive, unnecessary supplements — HHS is creating a “Trojan Horse” for alternative medicine. It asks students to treat lay doctors as clinical equals, undermining the very evidence-based rigor that medical school is designed to create.
The Health-to-Medicine Pipeline
I’ve written before about the concerns surrounding the Trump administration and the healthcare industry. And qualifications only heighten these concerns.
Throughout there is a wide range of vague terms (eg, epigenetic modulation) that have been co-opted by well-being influencers (see Capabilities #16-19, #30, and #35-37). These self-proclaimed “hormone” and “gut health” experts are ready to discuss how your diet is throwing your hormones out of whack and making you sick. This is where nutrition training can get very complicated. When “evidence-based” can be claimed by anyone with a link to a biased journal, medical students lose the ability to distinguish clinical fact from biohacking fiction. Nutrition threatens to become another area facing our junk science crisis.
It’s not just about curriculum; This is about the “deprofessionalization” of medical advice. These capabilities are not strictly focused on teaching our physicians using the best available expertise and information. If they were, registered dietitians would be an important specialty and unregulated professions would not be mentioned. Physicians in training should be trained by experts in the field and informed by the best available evidence. This means clear, consistent definitions, strong evidence, and using the nutrition experts we have.
Katie Solita, 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.
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