With the 2020 election season comes the latest lineup of federal legislators holding positions within the Congressional Dietary Supplement Caucus, the main policymaking arm of the legislative branch looking most closely at developments in the dietary supplements space, and tentative regulatory changes that impact the way this industry operates.
 
Four trade associations: the Council for Responsible Nutrition (CRN); the American Herbal Products Association (AHPA); the Consumer Healthcare Products Association (CHPA); and the United Natural Products Alliance (UNPA), participated in a briefing for legislators aimed at introducing them to pertinent issues affecting companies, consumers, and other participants in the dietary supplements industry.

Tieraona Low Dog, MD, an author, researcher, practitioner, and spokesperson with a career in dietary supplements and complementary medicine, as well as a former appointee by President Bill Clinton to the White House Commission on Complementary and Alternative Medicine Policy, shared her perspectives regarding what role dietary supplements should play in public policy, especially at a time when the health crisis posed by the COVID-19 pandemic is still at a fever pitch.

Essential Nutrients
Low Dog spent the majority of her focus on essential vitamins and minerals which serve as the basis of nutritional supplementation. These micronutrients, she said, should be a key component of public policy centered around prevention, and what overall supportive measures institutions should be advising with or without the presence of a public health crisis.
 
“I want to focus on some of the chief vitamins and minerals important to immune health because, at this point, I don’t think there should be much debate about the role that vitamins D or C might play, or whether they are important to us, or to immunity,” she said. “People don’t eat the way they should – they love fast food, processed foods, and refined carbohydrates, especially in response to stress. There’s a huge disconnect between what we need to be eating and what we do, and the populations most affected by nutrient deficiencies today have less access to fresh fruits and vegetables, and, in food deserts, some people have zero access.”
 
Largely sourcing NHANES data, as well as non-governmental research, Low Dog specifically looked at four essential micronutrients for which inadequate intakes among U.S. adults, and the risks associated with deficiency, are especially high and concerning: vitamins A, C, D, and zinc. For vitamin A, 45% of American adults do not meet the estimated average requirement (EAR). Further, 21 million Americans are fully deficient in vitamin C, 66.8 million Americans are fully deficient in vitamin D, and 35-45% of adults over the age of 60 are deficient in zinc. Mounting evidence suggests that each of these micronutrients are essential for both innate immunity, as well as the development of adaptive immune responses, she said, pointing to such studies as a 2019 clinical trial at St. Jude’s Research Hospital which found that children dosed with 2,000 IU each of vitamins A and D at the onset of a flu vaccine maximized the efficacy of response to that vaccine.

Nutrition Screening 
Low Dog advocated that, at the very least, evidence suggests that people should be screened for these micronutrients upon being admitted to a hospital for clearly positive associations in infection outcomes.
 
“Cochrane, one of the most prestigious review groups, said that we don’t need to continue doing studies after concluding that supplementation to children in developing nations reduced all-cause mortality by 24%. Vitamin A reduces infection and saves lives, and NHANES data shows that we need to be looking at developed nations such as our own,” she said. “Marginal [nearing levels of deficiency] status of vitamin C can be difficult to identify, and infection rapidly depletes our levels. One study revealed that 35% of Scottish elders hospitalized for respiratory infections had vitamin C levels comparable to scurvy. How can we expect people at scurvy levels to heal?”
 
Low Dog said she believes vitamin D screenings should be more standardized as a component of healthcare that is included in coverage by insurance providers and Medicare, especially heading into flu seasons, citing her experience with clients who were surprised to find that vitamin D screenings they received at routine checkups were not covered by their insurers. She said ensuring that vitamin D levels are fit for the purpose of receiving a vaccine will ensure that the vaccines we provide for any respiratory illness will be efficacious.
 
Lastly, she questioned whether awareness of the degree to which zinc deficiency impacts people in the U.S. is accurate. “Suboptimal zinc levels increase the risk for infection, and lots of people say that zinc deficiency’s not a problem, because mild deficiency tends to be subclinical, but the standard testing methods we use often don’t reflect tissue levels of zinc.”
 
Further, there are many people at chronic risk of zinc deficiency, including men, obese individuals, and people suffering from diabetes and chronic conditions which require the use of drugs such as antihypertensives.

Policy Priorities
Low Dog said she hoped the takeaway from the discussion was clear-cut, in that her aims are at reducing nutritional deficiencies which have clear implications for immune health responses down the line. Whether it be having policies in place that guarantee coverage for patients with prediabetes hoping to prevent the disease from manifesting, or allowing patients to have affordable access to nutritional testing and counseling, Low Dog ultimately stated that adequate nutrition has a hugely beneficial role to play in a healthcare structure focused on proactive and preventative measures.  
 
“We’re talking about deficiencies here,” she said. “We’re talking about the need Americans have to improve their diets, the potential that subsidizing the production of fruits and vegetables rather than corn can play, and what can happen if healthcare practitioners aren’t penalized by insurers if they want to test a vulnerable patient who they think might have a nutrient deficiency.”
 
“There’s so much we can do to maintain good health,” she continued. “It’s very reasonable for many people to supplement their diet with a multivitamin, and it’s very reasonable for us to have a reimbursement structure in place that allows for basic nutrient testing, especially in populations at the greatest risk. Vitamins and minerals have the greatest health benefits in people who are deficient, and I hope that today I conveyed the risks that some populations are facing.”

The 2020 Congressional Dietary Supplement Caucus Briefing was recorded, and is available on-demand here.