The MAHA Strategy Report’s 12 Dangerous Rabbit Holes

Why the US research community needs to avoid endorsing these MAHA conspiracy theories

Source: Loony Tunes (before they took Elmer Fudd’s guns away)

This week, the Make America Healthy Again (MAHA) Commission released their second report: The MAHA Strategy. It aims to focus the United States research community (via programs, policies and funding) to work on many of Robert F Kennedy Jr’s key conspiracy theories and naturopathic biases. The MAHA Strategy Report essentially drills a large number of rabbit holes that they want to send scientists to follow the MAHA activists down.

While the media largely covered how the MAHA activists were unhappy with many of the soft positions in this strategy report (mainly on pesticides, farming and chemicals) or that it lacked teeth, there was enough in the document to terrify even the most moderate science advocate. As RFK Jr’s position on vaccines draws the most attention, and there is enough anti-vax propaganda in this report to scare people (like a special commission to document and study vaccine harm and plans to revisit the vaccine program), other bat-shit crazy conspiracy theories and anti-science dogma also need attention.

What follows are 12 passages from the report (outside of the MAHA anti-vax strategy) with brief Firebreak analyses of their actual implications, biases and presuppositions.

On Research Priorities

1. Electromagnetic Radiation
   HHS, in partnership with other departments and Federal agencies, will undertake a study on electromagnetic radiation and health research to identify gaps in knowledge, including on new technologies, to ensure safety and efficacy.

This refers to RFK’s “5G gives you cancer” campaign. Deeper down that conspiracy rabbit hole is the belief that power lines, microwave ovens and other low level electromagnetic fields are carcinogens (despite decades of evidence that has refuted such claims made by fringe academics and conspiracy theorists like RFK Jr). Some MAHA Moms like Zen Honeycutt were struggling to maintain their devotion levels on that June day when RFK Jr said all Americans should be using wearables. Perhaps he didn’t read the report on how heart-rate monitors give people heart attacks, or cancer, … or something bad.

In any case, the game is simple. Money will be available to fringe activist scientists who will produce evidence to demand a precautionary approach to anything electric or Internet of Things related, people will get afraid but no regulatory response would be reasonable or possible. What is the point, then? The MAHA movement will use this as one more case where some captured regulatory agency is ignoring the scientific evidence and failing to protect the public in favor of some industry greed in imposing electricity and Internet connections on the unsuspecting public.

It would not be a stretch for this study, done by the HHS and other Federal agencies, to also look into the health effects of chemtrails?

2. Artificial Intelligence
   HHS will prioritize research into the appropriate integration of AI to assist in earlier diagnosis, personalized treatment plans, real-time monitoring, and predictive interventions that prevent hospitalizations, reduce costs, and reduce the economic burden of chronic disease. Improving pediatric and young adulthood cancer will be an initial focus area:

• HHS will include a specific focus on research that harnesses AI to uncover causes, identify risks early, and take action in childhood and young adulthood to prevent cancer.

• HHS, NIH, and the Office of Science and Technology Policy will develop an evidenced-based and AI driven approach to harnessing the data and technology available to transform research and clinical trials on pediatric cancer. This can be a model for future research in other critical areas.

AI is a very useful tool to aid researchers in many of the manual, repetitive functions, but it is worrisome to think that the agencies responsible for health research are putting it forward as a research priority (ie, to replace human research and diagnosis). AI models can be wrong, just confidently wrong, and in the field of disease diagnosis, this is dangerous. How many needless mastectomies need to be performed, for example, before the model self-corrects? In the medical research field, synthetic data is being used to train AI models. While the results at the moment mimic real data, there is a heightened risk of data collapse if the models rely too confidently on non-existent data. How can a government so confidently and quickly automate healthcare management?

This is the tail wagging the dog. In the United States, healthcare is far more expensive and far less efficient than in most other developed countries. To worsen the situation, the Big Beautiful Bill will make significant cuts in healthcare budgets, meaning that AI will too often be the only game in town. Claiming that such technological “interventions … prevent hospitalizations” is important as many hospitals, particularly in rural America, are being shut down. But are the risks worth it with an emerging technology and have the ethical ramifications of such AI applications been sufficiently thought through?

After the embarrassment of the first MAHA Commission Report, where a large number of passages and citations were found to be AI generated (and wrong), the MAHA Commission should be a bit more conservative on letting Artificial Intelligence be the only intelligence in the room.

On Policy Reforms

3. Food Dyes
   FDA will continue to advance and implement policies to limit or prohibit the use of petroleum-based food dyes (FD&C certified colors) in all food products approved in the U.S. The USDA will apply the framework to food served through Federal nutrition programs, especially the school lunch program. USDA and HHS will work to develop research and policies to support domestic agriculture production of plants used as natural color sources. FDA will continue to expedite its review and approval of color additive petitions for colors from natural sources and explore ways to provide greater flexibility in connection with the use of “no artificial color” and other labeling claims.

Kudos that the Food Babe, Vani Hari, is now writing food regulations in the United States but shouldn’t someone in any of the other government agencies within the MAHA Commission have noticed this rabbit hole? The “appeal to nature fallacy” believes that natural is always better than synthetic, to the point that we do not test or need to approve natural substances, even if they, as chemicals, may be far more dangerous than well-tested synthetic alternatives. Poison ivy may be a natural alternative to red dye, but should we be feeding that to our children? Perhaps it can counter-act the natural pathogens in the raw milk we will be feeding them (see Rabbit Hole 10 below).

To repurpose agricultural land away from food production to grow natural color sources that are not proven to be safer than well-tested synthetic alternatives is just one more layer of ridiculous in this MAHA strategy. Add that to the farmland wasted to grow plants to produce natural pesticides for organic farmers when synthetic alternatives are safer. Congratulations Vani, you have brought the United States scientific community down to your intellectual level.

4. Ultra-Processed Foods
   USDA, HHS, and FDA will continue efforts to develop a U.S. government-wide definition for “Ultra-processed Food” to support potential future research and policy activity.

The label: “ultra-processed food” was recently created by activists to isolate a class of convenience foods to fit their campaign against additives and food companies. Outside of political ideology, it does not mean anything so it will be interesting how RFK Jr’s scientists will define this activist concept. Will they define it by the level of refined sugars or other carbohydrates? By processing that reduces the food’s natural fibers? Or just any food that comes in a package?

Except for vegetables picked fresh from the fields (and raw milk) most food production involves some processing to preserve the food or protect the consumer. An additive to prevent spoilage can be removed, but then food waste or E. coli epidemics will increase. Pasteurization of milk removes deadly pathogens. Yeasts and enzymes have processed wonderful foods and drinks for millennia. But this rabbit hole was drilled on the cult presupposition that anything man does to nature is bad, and that includes food processing.

Something tells me Calley and Casey Means have been hard at work here. They sell some products to help the confused consumer here.

5. Direct-to-Consumer Pharma Advertising
   FDA, HHS, the Federal Trade Commission (FTC), and Department of Justice will increase oversight and enforcement under current authorities for violations of direct-to-consumer (DTC) prescription drug advertising laws. Egregious violations demonstrating harm from current practices will be prioritized, including by social media influencers and DTC telehealth companies (including dissemination of risk information and quality of life through misleading and deceptive advertising on social media and digital platforms).

Any visitor to the United States will be mesmerized by the multitude of TV commercials for pharmaceutical products (especially the reassuring images and music when the vast array of potential side effects are rapidly listed). Such pharmaceutical advertisements are not allowed in most other countries, and rightly so. Medical decisions should be made in the trust-bound relationship of patient and doctor.

But visitors are then equally mesmerized by the multitude of TV commercials for tort law firms guaranteeing millions in damages in MDL or class action lawsuits against these same pharmaceutical companies. Such tort litigation advertisements are not allowed in most other countries, and rightly so. They falsely promise potential victims high returns when the objective is to amass tens of thousands of cases to force (extort) the company into settling out of court. This increases litigation insurance premiums, pushing medical costs higher than any pharmaceutical company price gouging ever could. It should not go unnoticed that RFK Jr is a tort lawyer who has made millions working at a one of the worst Predatorts, WisnerBaum (whom his son is now working in his place) so we can expect no change in policy here.

6. On conflicts of interest
   NIH will establish a publicly accessible researcher payment database tracking health industry payments to researchers, similar to CMS’s Open Payments system for physicians.

7. Agency Foundation Capture
   The HHS Secretary will direct the FDA, CDC, and NIH to review participation in any projects or initiatives funded by food and pharmaceutical companies through the CDC Foundation, Foundation for the NIH, or the Reagan-Udall Foundation. The Secretary of HHS will require more transparency, as well as additional guardrails needed to protect public health from corporate influence.

It is interesting to see that the European double-standard will soon become a global hypocrisy. There is nothing wrong with industry research as long as these scientists maintain their commitment to Good Laboratory Practice (GLP) principles. Industry data is as valuable as other data sources. And there is nothing wrong with industry funding academic research as long as it is transparent. Today we see an anti-industry bias (dare I say “witch-hunt”) that is torturing the research community, and this MAHA Commission Report is willfully fueling this prejudice.

The world of research funding has therefore evolved as new interest groups fill the void. NGOs like the Environmental Working Group (EWG) take funding from tort law firms to produce evidence they then can use in lawsuits once the EWG publishes their results. They are not transparent about the source of the funding or the objectives (they fund research to amplify their campaigns, not for the value of scientific discovery).

Foundations are becoming big donors of activist scientific research, but they not only have deep pockets to manufacture evidence to fit their agenda, they have many tools to hide their funding. The Firebreak did an exposé into how a group of tort lawyers formed the Heartland Health Research Alliance and then used dark, donor-advised funds within foundations to channel money to a small group of activist scientists to produce lawsuit ready evidence. It should not go unnoticed that RFK Jr is a tort lawyer who has made millions working at one of the worst Predatorts, WisnerBaum (whom his son is now working in his place) so we can expect no change in policy here.

I suppose this is what MAHA means by “Gold Standard Science”.

8. Gold Standard Science in Research
   The NIH will establish new mechanisms to strengthen Gold Standard Science, as required by Executive Order 14303 of May 23, 2025, including capacities for high-quality systematic reviews, incentives for replication and reproducibility, the identification of evidence gaps and the development of a Scholars Program to address the quality crisis in scientific peer-review and publishing.

That executive order, signed among many, was an interesting but unnoticed declaration against traditional scientific methods. It essentially restricts any industry involvement in the research process. See a quote from a recent Firebreak analysis into MAHA tactics.

NGO and foundation-funded research which raise fear and doubt is now Gold Standard, even though their research objectives are politically agenda-driven.

The leading innovators employing the best scientists are now being ostracized from the research process. When industry researchers invest in a project, if a theory works, they create new products that consumers want and enjoy. If it doesn’t work, they see if there are other applications or learnings for further research (many scientific discoveries come from mistakes or failed hypotheses). When academic researchers invest in a project, if a theory works, they form into a company. If it doesn’t work, they run out of funding.

9. Medical School Curriculum and Accreditation
   HHS and CMS will address the current monopolies that exist for the accreditors of medical education programs by using their regulatory authorities to bring in competing accreditors of medical education programs, including those with a focus on treating the root causes of chronic disease in the United States. Accreditation reform can also increase nutrition education and ensure medical school curricula better align with making America healthy again.

In other words, naturopaths are doctors too, as are chiropractors, wellness gurus, herbalists and shamans. The Deadly Duo of Casey and Calley Means evidently have their thumbprints all over this MAHA Strategy Report. “Stanford can’t teach nutrition, so anyone with an MD from that dreadful school can’t be trusted. Buy our book, diet plan and glucose monitor instead!”

Certifications recognize expertise and since COVID, the medical expert is perhaps the most hated profession in the United States. It is one thing to say that good food leads to better health (that is common sense), but it does not then justify the conclusion that any conventionally-trained medical practitioner who relies on the body of scientific knowledge that his or her long academic career has proven to work should be attacked because they did not prescribe herbs, juices or essential oils to cure an illness. This praise of the fringe non-expert is a dangerous, confusing and irresponsible rabbit hole that no serious government agency should promote. This is pure MAHA madness that will only generate more distrust.

10. On Food Deregulation
    Remove barriers preventing small dairy operations from processing and selling their own milk products locally.

The point of this recommendation is to promote the consumption of raw milk. The scientific illiteracy and cult bias here is stunning. Small local raw milk illness outbreaks won’t make the national news and no one will bother to compile a body count. Instead, people will just stop drinking milk. For many in the naturopath community, that is just fine.

On Communications Campaigns

11. Fluoride
    Following the completion of studies on fluoride, CDC and USDA will educate Americans on the appropriate levels of fluoride, clarify the role of EPA in drinking water standards for fluoride under the Safe Drinking Water Act, and increase awareness of the ability to obtain fluoride topically through toothpaste.

State and local authorities decide on water fluoridation requirements. RFK Jr can’t do anything about this. But he can use federal funding (taxpayer dollars) to launch a widespread communications campaign to “educate” Americans to buy into his ridiculous conspiracy theory against fluoride. According to the activist playbook, the outraged public should then turn on their local authorities (even without any evidence or sound rationality). If ever a reason was needed to not put an anti-science lunatic in charge of public health policy, this would suffice.

12. Pesticides
    EPA, partnering with food and agricultural stakeholders, will work to ensure that the public has awareness and confidence in EPA’s pesticide robust review procedures and how that relates to the limiting of risk for users and the general public and informs continual improvement.

Any activist running an anti-chemical campaign knows that when the public hears the words: “toxic, chemical, poison, pesticide, food and farming”, they recoil in fear regardless what you actually say. It does not take much to understand that if you run a communications campaign with the intention to “work to ensure that the public has awareness and confidence” in pesticides on their food, you will achieve the exact opposite. Let the farmers talk to the public and stop enabling the organic food industry lobby’s disinformation campaigns.

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Scanning the media coverage on the MAHA Strategy Report this week, I am beginning to wonder if I was the only one to have bothered to read its dismal 20 pages? The main media groups missed these 12 glaring rabbit holes. Perhaps it was not as interesting as the Epstein Files.