WASHINGTON —Making modifications to or allowing flexibilities in the Dietary Guidelines for Americans (DGA) recommendations that would reduce or replace intake of grains may be harmful to public health and ineffective at leading more consumers to follow healthy eating patterns, said Erin Ball, executive director of the Grain Foods Foundation.

Ball offered the words of caution in an Aug. 20 letter to the 2025 Dietary Guidelines Advisory Committee. It was written in response to a presentation at the fifth meeting of the Dietary Guidelines Advisory Committee, suggesting that grain foods may be decreased in the Healthy US-Style dietary patterns (HUSS).

As defined by the US Department of Agriculture, a HUSS eating pattern “provides a framework for healthy eating that people in the US can follow,” based on the foods Americans typically eat.

“A modification to decrease grains by one ounce-equivalent per day in the HUSS could drive under-consumption and exacerbate nutrient deficiencies, such as dietary fiber, folate, thiamin, niacin, iron, zinc, magnesium and calcium among all Americans, including vulnerable populations and life stages,” Ball said. “Grains contribute more than 15% of these nutrients to the HUSS dietary pattern, as presented at meeting No. 5. Considering these nutrients’ under-consumption in individuals ages one and older, the importance of grains as a vehicle for nutrient adequacy was underlined and highlighted at meeting No. 5.”

Noting that Americans consistently fail to meet recommendations in the DGA, Ball said the committee, when considering possible changes to the dietary patterns, ought to consider the nutrient implications of making changes while also keeping in mind the way Americans actually eat.

Consumer research indicates consumers should be counseled “to make incremental, small steps to improve dietary behaviors — building on existing food preferences, like grain foods,” Ball said.

She was responding to a series of slides that were part of the meeting, including one asking the implications for nutrient intake if grains were “replaced with other staple carbohydrate foods (i.e., starchy vegetables: beans peas and lentils; starch read and orange vegetables)?”

The presentation, by Chris Taylor, a member of the committee and a professor of medical dietetics at The Ohio State University, Columbus, suggests food pattern modeling (FPM) provides support for “exploring a modification that reduces total grains in the overall synthesis that integrates the food groups in a healthy dietary pattern.”

He concluded nutritional goals “can generally be achieved,” if total grains intake were reduced by 1 ounce in the recommendation.

Negative implications were identified for toddlers (12 to 23 months), children from 4 to 8, women ages 14 to 50 and women who are pregnant. Specifically, Taylor voiced concern iron intake is less than 90% of recommended levels for these groups and folate intake does exceed 90% of the recommended daily allowance for women who are pregnant in the existing HUSS pattern.

Taylor also said food pattern modeling would support exploring flexibility increasing beans, peas and lentils above proposed quantities in a healthy dietary pattern while decreasing total grains.

Such a change would have positive implications for folate, iron, choline and fiber, Taylor said.

Regarding flexibility increasing starchy vegetables while decreasing total grains, Taylor said a switch would not have implications for whether nutrient goals are met. He went on to say, though, there would be positive implications for vitamin A and negative implications for iron and folate.

The conclusions appeared at odds with findings immediately preceding this discussion, which asked whether changes should be made to the mix of food groups in the guidelines. Taylor cited data showing grains are a major source of a dozen micronutrients, with percentages ranging as high as 63% for folate, 62% for iron, 53% for thiamin and 41% for niacin. He then showed a slide demonstrating, as an example, the major role grains play in the intake of iron followed by a slide showing how iron intake would be decimated in the absence of grains consumption.

Ball cautioned the committee guidance to replace grains with pulses is unlikely to be followed, if judged by perennially low rates of intakes of beans, peas and lentils.

“The DGA increased recommendations for beans, peas and lentils nearly 20 years ago — and then reversed this recommendation in the 2010 edition, due to lack of adherence,” Ball said.

Particularly objectionable, Ball said, are DGAC data interpretations vilifying sandwiches, burgers and grain-based mixed dishes as the top source of saturated fat and sodium in the diet. The Taylor presentation data actually showed grains contribute only 16% to 21% of saturated fat intake.

“The 2020 DGAC cited sandwiches as the No. 1 source of protein, calcium, potassium and fiber, and the second largest source of whole grains, dairy and vitamin D, as well as vegetables,” Ball said. “Close to half of all adults eat one or more sandwiches on any given day, and the 2020 DGAC noted that sandwiches could be a vehicle to support Americans in improving their diet quality, when nutrient-dense options are prioritized. In fact, GFF conducted a modeling analysis that indicated the ingredients inside the sandwich, and not the grain food product itself, are the most significant drivers of excess calories, saturated fat and sodium.”

Using theoretical conclusions from food pattern modeling to generate actual recommendations for dietary changes would be imprudent, Ball said.

“While FPM may be an important academic exercise, any resulting dietary pattern modifications and/or flexibilities must be based on actual consumer behavior insights, current consumption and preferences, and the potential for further exacerbating nutrient deficiencies, especially within vulnerable populations,” she said.

Ball also reminded the group of the importance of cultural sensitivity in its recommendations. She noted that Hispanic Americans currently on average score higher (60) on the Health Eating Index than the overall American population (58).

“This population subgroup consumes grain foods (e.g., corn and flour tortillas, rice, maize, amaranth) as a foundational part of their cultural foodways,” she said. “Similarly, the non-Hispanic Asian population subgroup traditionally consumes white rice frequently, and they have an average HEI score of 65.