Vaccines
The MAHA Strategy lays out planned changes to our nation’s vaccination policy. Plans include potential changes to the childhood vaccine schedule, new approaches to vaccine injuries, pursuing alleged conflicts of interest, and hinting toward requiring placebo trials for vaccinations to get FDA approvals. These are all dangerous changes. Changing the childhood vaccine schedule would unnecessarily put children at risk of disease. The scientific consensus is that vaccines are safe, effective, and life-saving. The childhood vaccination schedule is proven, safe, and works with children’ s immune systems to build immunity to dangerous illnesses. Given RFK Jr.’s history of advocacy against vaccinations, we are concerned about the integrity of future vaccine injury research at HHS, and about what could be considered a “vaccine injury” even without evidence. The changes that the Strategy recommends could be used to deter future vaccine production and development because of liability concerns for vaccine manufacturers. We may also see efforts to discredit vaccine researchers and manufacturers by alleging conflicts of interest even when there are none. We saw this play out when RFK Jr. fired the entirety of the Advisory Committee on Immunization Practices (ACIP). Requiring vaccines to undergo additional placebo-controlled trials before being approved would force researchers to unethically restrict evidence-based protection from some patients. All of these things may make it harder for people with disabilities to access the vaccines we need to be safe from dangerous diseases.
Autism
The Strategy mentions a plan to investigate the root causes of autism, including the usage of the new Real World Data Platform (RWDP). We have previously expressed concern about this platform and asked the administration to tell us how this will be used and what privacy protections there will be. HHS has failed to give satisfactory responses to our requests for more information so far. As we await HHS’ announcement of its theory on the root causes of autism in the coming weeks, the Autistic Self Advocacy Network (ASAN) reminds government officials and the public alike that vaccines do not cause autism.
Changes to Research Practices
A key focus of the Strategy is HHS’ approach to research. HHS hopes to implement new study methodologies and several new initiatives, such as the RWDP. Secretary Kennedy’s repeated medically-misinformed actions and statements on vaccines, autism, racist pseudoscience, and more do not generate confidence that HHS’s strategies will live up to their promise. Since Kennedy and his colleagues have started their tenure, we’ve seen them take actions—without supporting scientific evidence—that limited access to COVID-19 vaccines, ended mRNA vaccine development, and approved the removal of thimerosal from multi-dose influenza vaccines. The MAHA Strategy also calls for the revision of policies that limit the government from sharing de-identified data. ASAN would like to know more about the administration’s metric for adequately de-identified data, the planned accountability measures to protect its storage, and its use in the hands of researchers.
We are disturbed by the possibility that the proposed projects and methodologies may be used to justify policymaking that lacks credible scientific evidence.
Artificial Intelligence
The Strategy talks about the integration of artificial intelligence (AI) throughout HHS. AI is a catch-all term that can be used to describe a variety of algorithmic techniques. For example, machine learning is a type of AI that has been an incredibly useful tool to help identify drug interactions at the molecular level. That said, we are concerned about some of the ways HHS plans to integrate AI into health care. AI’s performance is only as good as its dataset. This can lead to discrimination. For example, we have concerns about AI’s use as a diagnostic tool or for developing predictive interventions, because people with disabilities and people with complex or rare medical conditions are unlikely to match the dataset the AI was trained on. This can lead to people receiving the wrong kind of health care. We’re also concerned about using AI to identify root causes of conditions. While some applications of machine learning could be useful, predictive AI could identify associations or causes that do not really exist. We will monitor the administration’s use of AI and address concerns as they arise.
Medicaid
There are several proposed changes to Medicaid administration that could worsen children’s health. The Centers for Medicare and Medicaid Services (CMS) plans to collaborate with states to establish new quality metrics for Medicaid managed care plans that would track predictive health data. We are concerned how this data could be used by managed care plans or third party buyers to discriminate against beneficiaries with preexisting conditions and poor health. ASAN will be monitoring new metrics and measures CMS develops and will assess whether they accurately measure improvements in children’s health outcomes or instead discriminate against children with disabilities.
CMS also plans to work with states to create stricter prior authorizations for psychiatric drugs, such as stimulants prescribed for ADHD. This is part of a broader Strategy to restrict access to necessary and clinically approved psychiatric drugs for children. This is a major concern for ASAN because ADHD, depression, and anxiety are often co-occurring with autism.
Prescription of Psychiatric Drugs
As mentioned, the Strategy makes the claim that psychiatric medication such as selective serotonin reuptake inhibitors (SSRIs), antipsychotics, mood stabilizers, stimulants, and other drugs are over-prescribed for children. This builds upon the Report’s earlier fearmongering that children are being overdiagnosed and “overmedicalized” for learning disabilities and mental health disabilities. The MAHA Report and Strategy are especially alarming in the context of RFK Jr.’s previous statement that people taking mental health medication should instead be institutionalized in forced labor farms. Children with ADHD and mental health disabilities do not need the administration making their lives more challenging by taking away medications or stigmatizing their use.
Nutrition and Water Quality
The Strategy places a major emphasis on the food we eat and the water we drink, and yet hardly touches on the main issue with both: access. The administration’s priorities become apparent as they set goals such as increasing breastfeeding rates, rather than eliminating infant malnutrition. This perpetuates a culture of stigmatization and reflects a wider disregard for parents and infants with disabilities and complex health conditions who are unable to breastfeed.
The Strategy casts doubt on the quality of drinking water by insinuating that the presence of fluoride is harmful, despite the vast amount of evidence showing no negative health effects. This follows the MAHA Report’s claim that fluoride has been linked to an increase in intellectual disability, which is false and based on a flawed study. This concern about fluoride’s safety comes after attempts in Congress to roll back regulation to reduce lead in drinking water and HHS firing the members of CDC’s lead poisoning prevention team. The implication that fluoride in drinking water is harmful is particularly ironic as the Strategy makes no mention of addressing dental cavities, one of the most common childhood chronic diseases that fluoride plays a crucial role in preventing. This is only one of multiple childhood chronic health issues that the Strategy overlooks.
