When Health and Human Services Secretary Robert F. Kennedy Jr. unveiled the Make Our Children Healthy Again assessment this spring, he promised it would “attack the root causes” of America’s childhood chronic disease crisis and “follow the truth wherever it leads.”

Truth, like science, requires evidence. And according to a new independent review, the MAHA report falls short, badly.

The review, commissioned by Consumer Action for a Strong Economy, a nonpartisan advocate for free-market principles, concludes that the report’s recommendations are scientifically unsound and potentially dangerous as the basis for public policy.

Conducted by Dr. Mark Kern of San Diego State University, the analysis found fabricated citations, misrepresented research and seven significant areas where the report failed to meet its stated goal of building an “evidence-based foundation for policy interventions.”

“Considering the serious potential consequences to the U.S. economy, consumer choice and food prices, policymakers should not use the scientifically feeble MAHA report as a basis for regulation,” Kern said.

Kern’s analysis found seven areas where the MAHA report failed to follow its stated goal of establishing an “evidence-based foundation for policy interventions.” Those errors risk damaging the U.S. economy, food prices, jobs and consumer choice if the report’s findings are used to shape public policy.

Among the seven areas Kern flagged, one of the most concerning was the report’s treatment of ultra-processed foods (UPFs).

The report leveled harsh criticism at UPFs, suggesting parents were harming the health of their children by giving them UPFs instead of “nutrient-dense whole foods.”

This, it argued, caused children to consume fewer essential vitamins, minerals, fiber, and other things needed for optimal biological function.

“The convenience of ‘fast food’ and the food processing and delivery industry that facilitates them is viewed, internationally, as a distinctly ‘American’ innovation,” read the report.

That isn’t true, Kern said, noting food processing and refined foods have existed for more than a century. He said UPFs often include added fiber, vitamins and probiotics to potentially increase their nutritional value.

A 2023 study in The Journal of Nutrition found Americans who ate a diet made up mostly of UPFs had a higher Healthy Eating Index, initially developed in 1995 to assess dietary adherence, compared to the typical American.

Kern argued that clinical trials were needed to see if UPFs adversely affect health outcomes. Those trials can help people understand “the implications of including these foods in the diet,” he wrote.

Another controversial dietary recommendation in the MAHA report is its call to replace seed oils with animal fats — a position Kern says lacks scientific backing and practical feasibility. Animal fats have been known to increase LDL (bad) cholesterol, according to the American Heart Association. Some seed oils produce omega-3 fatty acids, which are considered essential. The animal fats mentioned in the report do not contain larger amounts of omega-3, according to Kern.

Ironically, Kern found the MAHA report doesn’t live up to President Trump’s executive order to follow gold standard science. Trump issued the declaration in response to actions by the Biden administration and Democratic-run cities during the COVID-19 pandemic.

Kern also noted report authors relied on narrative reviews that, unlike scientific studies, “are prone to the biases of those who have conducted the reviews.” He thought it was more important to establish policies and guidance that have a higher standard of scientific review so Americans do not suffer any consequences.

“Science is not storytelling,” said Matthew Kandrach, the president of CASE.

“Nutrition policy should be based on reproducible evidence, not cherry-picked claims or biased narrative reviews. This analysis is a call to return to evidence-based policymaking — where facts, not narratives, guide decisions that affect millions.”