By: Tom Green, HHRA Board Chair and Chuck Benbrook, former HHRA ED Farmers growing our major U.S. crops of corn, soybeans, wheat, rice, cotton and peanuts are facing record loses due to steeply depressed crop prices over the past few years, coupled with persistently high, and rising, production expenses. Today’s cost-price squeeze poses an existential threat for many farmers and all rural communities. Experts are projecting that per acre loses will likely grow, and exceed $100 an acre on many farms. Plus, loses are likely to persist for at least a few years, and may grow even larger. HHRA decided to compile and vet policy reforms to change the trajectory of U.S. agriculture for two reasons. First, we read the provocative September 30, 2025 piece by Chris Bennett in AgWeb entitled “Outraged Farmers Blame Ag Monopolies as Catastrophic Collapse Looms”. The frustration expressed, and heartful pleas of farmers for help in getting through the current crisis, struck a nerve. We urge everyone to read this piece. Second, as anyone working in food and ag is well aware, new tariffs imposed by the U.S. essentially shut off, or dramatically reduced, sales of soybeans, corn, and other crops to some of our major overseas customers. This has further undercut already depressed market prices, leading to ballooning surpluses. It has also triggered the need for another round of multi-billion dollar payments to farmers. We decided to craft and share the “Farm Economic Vitality and Environmental Recovery (FEVER) Act” since there was little or no discussion among ag community leaders, or in the Congress, of the systemic reforms in policy needed to avoid ever-larger bailouts in the not-too-distant future. The large sums of taxpayer money at play heighten the urgency of reaching agreement on substantive policy changes. Projected USDA payments in support of farm income in 2025 will exceed $50 billion, and will almost surely rise in 2026 when already-approved increases in target prices kick in. It is hard to imagine, given today’s political and economic realities, that the Congress and Administration will be able to rachet payments to farmers upward fast enough to prevent unacceptable loses and turmoil in rural America. But one thing might help forge the bipartisan support that will be needed – adoption of systematic policy reforms like those called for by the farmers quoted in Chris Bennett’s piece. We offer the FEVER Act as one path forward, and hope it broadens the vision of leaders in Washington D.C. who will soon have to pass legislation to fund the government and keep American agriculture in business. As made clear in thoughtful assessments by Bloomberg of the current economic and environmental crises facing rural America, farmers want to earn their living from markets, and end reliance on government bailouts. They also want to receive sufficient income to invest steadily in the people running and working on their farms, as well as in farming system changes that will enhance soil health and water quality. History Does Repeat Itself Until… The current crisis continues the long-standing pattern of gradual decline in farm numbers and farm profitability. Stubborn downward trends are punctuated by sharp, episodic contractions in the U.S. farm economy that require new bailouts and subsidy streams. Poor stewardship of our ag assets is reflected in the loss of so many U.S. farms since 1980, including 160,000 since 2017, coupled with ongoing slippage in soil health and water quality. But our food and farming problems are complex and intertwined, and rooted in policies far past their “best used by” date. Fixing problems that have worsened over decades will take time and money, both of which are in short supply. Hence, the need for aggressive and innovative policy reforms. We are pleased to share a document describing the “Farm Economic Vitality and Environmental Recovery Act” (FEVER Act). It brings together policy reforms that could be incorporated in future farm bill legislation to start the long-overdue reboot of food and ag policy in the U.S. We are soliciting reactions and better ideas to improve the reform ideas embedded in the FEVER Act. The FEVER Act describes a set of food and farm policy reforms of the scope and scale required to bring about meaningful, long-term improvements in the U.S. food and fiber system. Most of the suggested reforms are not new ideas, nor comprehensive. HHRA is also not the only organization advocating for systemic change. But we saw a need to assemble a set of policy reforms into a single document that collectively could bring about change of the magnitude needed, and soon enough to avoid irreparable harm to farmers, ranchers, and rural America. The policy reforms we hope to incorporate in the FEVER Act will be focused on immediate national priorities. These include: Getting farmers through the current net income crisis, while avoiding harm or undercutting farms and ranches that remain profitable, despite contemporary headwinds, Providing the justification that will be required to secure bipartisan support in Congress for what is bound to be a historically significant increase in taxpayer support for farmers over the next 5 to 10 years, Reducing dependence on government subsidies, bailouts, and food imports, and especially those that perpetuate the primary drivers of many of today’s systemic food and farm problems, Modernizing pesticide regulation, food nutritional quality testing and labelling, the National Organic Program, and most fundamentally, Assuring that the primary purpose, and major focus of government expenditures, is restoring soil health and public health and well-being, as opposed to sustaining farming systems and technology, and business models, that have become progressively less economically and environmentally viable and socially acceptable. At this time, the FEVER Act covers changes primarily in the commodity program, crop insurance, and conservation sections of a typical farm bill. Funding and reforms needed in the SNAP and food assistance programs, research and extension, rural development, and in most USDA-administered marketing and regulatory programs are not yet addressed, but should be. Reforms needed in certain areas of regulatory and food policy law will also be […]

By: Tom Green, HHRA Board Chair and Chuck Benbrook, former HHRA ED Note to Readers and Contributors The document below discusses policy reforms that could be incorporated in future farm legislation. We are soliciting reactions and better ideas to improve what we are calling the “Farm Economic Vitality and Environmental Recovery Act” (FEVER Act). The current version of the FEVER Act document is posted on the HHRA website at hh-ra.org/2025-MiniFarmbill.  It describes a set of food, farm, and regulatory policy reforms of the scope and scale required to bring about meaningful change in the U.S. food and fiber system. At this time, the document covers changes primarily in the commodity program, crop insurance, and conservation sections of the farm bill. Reforms and funding needed in the SNAP and food assistance programs, research and extension, rural development, and in most USDA-administered marketing and regulatory programs are not yet included in the document. Reforms needed in certain areas of regulatory and food policy law will also be addressed in future additions. The policy reforms in this document are focused on immediate national priorities. These include: Getting farmers through the current net income crisis, while avoiding harm or undercutting farms and ranches that remain profitable, despite contemporary headwinds, Providing justification for what is likely to be a historically significant increase in taxpayer support for farmers over the next 5 to 10 years, Reducing dependence on government subsidies, bailouts, and food imports, and especially those that perpetuate the primary drivers of today’s systemic problems, Modernizing pesticide regulation, food nutritional quality testing and labelling, and the National Organic Program, and most fundamentally, Assuring that the primary purpose, and major focus of government expenditures, is restoring soil health and public health and well-being, as opposed to sustaining farming systems and technology, and business models, that have become progressively less economically viable and socially acceptable. This is an organic document that will change and evolve regularly as new and better ideas are advanced. HHRA has developed the FEVER Act to integrate and sharpen policy reforms designed to meet the needs of the day. Please email any ideas to improve the policy proposals and suggestions in the FEVER Act to former HHRA ED Chuck Benbrook (cbenbrook@hh-ra.org). Concrete, specific changes in the policy reforms discussed below will be most helpful, in addition to policy reforms not yet addressed in the below document. Goals of the “Farm Economic Vitality and Environmental Recovery Act” (FEVER Act): Help farmers navigate steep market loses on commodity crops in the near-term, while beginning essential transitions in cropping systems, farm commodity and crop insurance policies, water use and quality, and food security and farm economic sustainability. Assure taxpayer dollars are invested in ways that will restore farmer and rancher profitability per unit of production, regenerate soil health, strengthen rural communities, and promote public health. Diversify crop rotations and income streams by reducing reliance on imports and heavily subsidized commodity crops. Phase out subsidies providing incentives for farmers to pursue excessively-high yield goals that result in production costs per unit above global market prices. Incrementally lessen subsidies, bailouts, and disaster payments, and increase farm financial security by raising the share of gross farm and ranch revenue received from competitive markets. Finance needed commodity program and water use changes required to shift regional farm production patterns with initial focus in 2026-2030 on reducing by at least one-half the acres devoted to the production of low-value, water-intensive animal feed crops in the arid west. Base Acre Land Use and Policy Changes In each of the next five crop years (2026-2030), farmers managing base acres in commodity programs may enter into “Base Acre Renewal and Profitability Contracts” with the USDA. The terms of such contracts shall include: Plant at least or a grass or legume forage crop.[1] The acres planted to such crops on a given field must differ year to year, resulting in at least one year of soil building crop on a minimum of 60% of a farm operation’s base acres over the three-year contract period. Farmers may propose planting greater than 20% of commodity program base acres in cover and forage-based crops, and will become eligible for incentive payments per acre. Such incentive payments shall be set at the local level in accord with regional guidance, and shall fall between 10% and 20% of the applicable payment in the absence of an agreement to increase the percentage of commodity program base acres planted to cover or soil building forage crops. Farmers shall manage cover or forage crops in ways that assure weed suppression benefits, improved water quality, and soil health benefits, and in compliance with local requirements and guidelines issues by county committees and in accord with USDA requirements. Farmers may graze or harvest cover and soil-building forage crops, and extend the period a field is producing a cover or forage crop beyond the three-year program in accord with payment rates and requirements specified by Congress and the USDA in future legislation. Within 30 days of signup, farmers will receive year-one payments equal to 150% of their established payment per commodity program base acre in 2026. Hereafter, such payments are referred to as “enhanced program payments”. Up to 50% of the enhanced payment made in the first quarter of 2026 shall be deducted from any future Agricultural Risk Coverage (ARC) and/or Price Loss Coverage (PLC) payment due to the farm operation in the last quarter of 2026 as a result of provisions in the OBBB. (Example: Base commodity program payment per acre = $100. Enhanced payment = $150/acre. If $80/acre is due to be paid under ARC/PLC in the fall of 2026, the USDA would deduct 50%, or $40/acre from the ARC/PLC. This provision allows for earlier payment of ARC/PLC payments due in 2026, while reducing a portion of overlapping and additional payments). Farmers who fail to adhere to contractual obligations calling for the planting of soil building cover or forage crop, or the management of soil building crops at any point during the contract […]

Defining and Delineating Ultra-Processed Foods  These comments are submitted on behalf of the Heartland Health Research Alliance (HHRA), a non-profit organization conducting research on the impacts of farming systems on the environment and public health (hh-ra.org), and the Swette Center for Sustainable Food Systems at Arizona State University. HHRA and the Swette Center submitted comments dated July 15, 2025 to the FDA on its proposed front-of-package nutrition labeling system. In February, 2023, HHRA and the Swette Center submitted comments to the FDA on the definition of “healthy” food and related measurement challenges. In our 2023 comments, we recommended adoption of novel metrics to quantify food nutritional quality as part of an analytical system called NuCal; two co-authors of these comments (Benbrook, Mesnage) published a paper describing NuCal in 2024. The co-authors of these comments on ultra-processed foods are (alpha): Mr. Dan Barber, Chef and Co-Owner, Blue Hill Restaurant at Stone Barns. Dr. Charles Benbrook, former Executive Director of HHRA. Anne Biklé, science writer who, with David Montgomery, authored What Your Food Ate: How to Heal Our Land and Reclaim Our Health (2022). Dr. Asa Bradman, University of California, Merced and member of the HHRA Board of Directors. Dr. Steven Chen, Chief Medical Officer of the Recipe4Health, a food-as-medicine program in Alameda County, California. Dr. Donald R. Davis, retired nutrition scientist who has conducted extensive research on historical changes in food nutrient content. Mr. Alan Lewis, Vice President for Government Affairs, Stakeholder Relations, and Organic Compliance at Natural Grocers. Dr. Kathleen Merrigan, Executive Director of the Swette Center, Chair of HHRA’s Public Policy Advisory Committee, and former USDA Deputy Secretary. Dr. Robin Mesnage, scientist conducting genomics and metabolic research on food safety and nutritional quality at the Buchinger Wilhelmi Clinic in Uberlinger, Germany. Mesnage and HHRA science advisor. Dr. David Montgomery, professor of geomorphology at the University of Washington in Seattle, and expert on how soil health impacts food nutritional quality and human health. Ms. Mary Purdy, MS, RDN, Managing Director of the Nutrient Density Alliance and Adjunct Faculty at the Culinary Institute of America. Mr. Bob Quinn, PhD, founder of Kamut International, and an organic farmer in Montana who has recently founded a regenerative organic research institute on a portion of his farm. Dr. Adam Shriver, Director of Wellness and Nutrition at the Harkin Institute at Drake University in Des Moines, Iowa. Dr. Andrew Smith, Chief Scientific Officer of the Rodale Institute. Mr. Tom Willey, retired California organic farmer and host of the “Down on the Farm” podcast. Access to multiple documents drawn upon in the preparation of these comments is provided via hyperlinks in the text. Citations to published papers appear in “References”.   Table of Contents I. Summary and Key Recommendations. II. Why Define, Measure, and Label Food by Degree of Processing? A. Evidence Linking Processed Foods to Adverse Public Health Outcomes Has Not Been Matched by Efforts to Reverse the Decline in Food Quality and Safety. B. Classifying Foods by Degree of Processing. 1. Food-as-medicine Programs Bring New Focus on Food Nutritional Quality. 2. A Key Challenge Confronting the FDA and USDA. C. Terminology and Focus. III. Taking Account of Food Manufacturing in Delineating the Degree of Processing A. Key Concerns and Metrics Needed to Identify UPF. 1. What’s Lost? 2. Nutritional Quality Should be the Bedrock Metric. 3. What’s Added? 4. New Risks? B. Classifying the Degree of Processing in Food Products. 1. Generic Food Processing Classification Criteria Applicable to All Products. 2. Food Group Specific Criteria Needed in Classifying the Impacts of Processing. C. Vetting the System to Achieve Continuous Improvement. IV. Questions Posed by the FDA-USDA. A. Supporting Cohesive Research, Continuous Improvement, and Consistent Guidance to Consumers B. Responses to Questions 1-5 Posed by the FDA-USDA. V. Conclusions and Recommendations. References.   I.             Summary and Key Recommendations Improving the safety and nutritional quality of ultra-processed foods (UPF) is among the most promising — and attainable — options to enhance the health of the American public. Doing so will require major changes in policy, technology, consumer awareness, and market dynamics. Manufacturing and selling unhealthy UPFs is profitable and accepted in the US. For this reason, chronic diseases rooted in unhealthy food and dietary patterns, including metabolic syndrome, Type 2 diabetes, and cardiovascular disease, are undermining well-being. Health costs will also continue rising. We commend the FDA and USDA for seeking guidance on how to define and classify foods based on the impacts of processing. Government action will be essential to achieve meaningful improvements in public health. Left unchecked, current trends will exacerbate already serious health, policy, and fiscal crises. To turn the tide, manufacturing safe and nutritious UPF must become the most profitable option for the food industry. Forging consensus on how to define and measure the degree of processing is an essential first step. We argue this must be done through the lens of public health. Metrics used to measure the degree of processing in a finished food product must be grounded in changes in the nutritional quality and safety of food products, and ultimately, impacts on public health outcomes. Defining and classifying mostly whole and fresh foods is straightforward. The degree of processing in a finished processed food product, and its impacts on public health, should be determined as a function of: Nutrients and health-promoting phytochemicals that are lost or altered as a result of processing, What is added in recipes, or via processing technologies, and Whether, and to what extent, milling, oil extraction, other processing methods, and cooking creates new, or exacerbates existing, food safety hazards. The foundational metric should be the percentage loss of nutritional quality as a result of processing. Such a calculation should be made across all individual nutrients with a Recommended Dietary Allowance, or an equivalent daily intake benchmark required to sustain good health. The total amount of each essential nutrient in the raw ingredients required to manufacture a serving of processed food should be measured, just as the food industry now does for nutrients featured in […]

Multiple lines of evidence point to consumer food choices as major contributors to diet-related disease, and poor health and fitness. In a peer-reviewed journal article published today, authors Chuck Benbrook and Robin Mesnage cite studies indicating that “Some 90% of the estimated USD 4.3 trillion in annual health care costs in the US is triggered or made worse by poor food quality and diet-related disease.” Benbrook is the founder and former executive director of the Heartland Health Research Alliance (HHRA). The authors recommend novel metrics on both the nutrient density of food, and how to more accurately and usefully characterize the degree of food processing and its impacts on public health. The article is open access in the journal Foods and entitled “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets.” The core nutrient density metric is a ratio: the percent of daily nutrient needs satisfied by a serving of food relative to the percent of a 2000 calorie daily diet taken up by the serving of food. This single metric is unmatched in comprehensively reflecting the nutritional quality of food. A graphic option to convey the metric on packaging is presented in Figure 3 in the new paper: A novel graphic is presented in Figure 5 to which integrates both the nutrient density and food processing metrics and graphics in a single graphic, shown below. The impacts of ultra-processed food (UPF) on public health outcomes is among the hottest topics in nutrition, medical, and public health journals, and media coverage on food quality and health outcomes. At the request of the journal, the authors developed a video abstract that explains the paper’s goals, methods, and key findings and recommendations. The authors conclude their paper with these observations: Transparent and accurate food product-specific ingredient and nutrient composition data should determine the content of nutrition health labeling. Efforts to soften the message should be resisted in light of the overwhelming need for new food labels that help bring about substantial improvements in food nutritional quality and dietary choices. Benbrook and Mesnage’s paper builds on public comments HHRA submitted in response to the US Food and Drug Administration (FDA) proposed rule in 2023 to update the definition of the term “healthy” on food labels. The proposed role would require foods labeled “healthy” to contain minimum amounts of foods recommended by USDA’s Dietary Guidelines, and to limit saturated fat, sodium, added sugar and other less healthy nutrients. Entitled “Food Labeling: Nutrient Content Claims; Definition of Term `Healthy’”, the comments recommended new  nutrition/health messaging on the front of food packaging. Co-authors of comments included the chair of HHRA’s Policy Advisory committee Dr. Kathleen Merrigan, HHRA science advisors, and other experts working on how changes in farming systems and technology can increase the nutritional quality of food: Dr. Hannah Flower, Dr. Donald R. Davis, Dr. David Montgomery and Anne Biklé. In the comments, the authors introduced “NuCal” as a name for their new system. Resources HHRA February 2023 comments to the FDA. Benbrook and Mesnage (2024). Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets, Foods. https://doi.org/10.3390/foods13213377 Video Abstract: “Enhanced Labeling to Promote Consumption of Nutrient Dense Foods and Healthier Diets”

HHRA and ORG-Tracker, represented by Dr. Chuck Benbrook and Dr. Brian Baker, submitted comments to the Agricultural Marketing Service at the USDA in advance of the National Organic Standards Board (NOSB) meeting in Portland, Oregon, from October 22nd to 24th, 2024. Drs. Benbrook and Baker will both attend the conference and deliver public comments. ORG-Tracker is a project carried out by HHRA. It aggregates pesticide residue data from inspections of organic farms carried out by certifiers. The tables generated by ORG-Tracker utilize the results of certifier testing to compare residue frequency and risk levels to food produced on conventional farms. The team is working to more effectively highlight gaps and challenges faced by certification agencies to answer questions like What crops should we be testing, and where? Is a pesticide residue found in an organic sample likely caused by accident, pesticide drift, or an intentional and illegal application? How can we modify organic programs to better mitigate risk? The comments delivered to the USDA discuss risk-based certification, pesticide residue testing, and policies impacting the incorporation of so-called inert ingredients in the biopesticides approved for use on organic farms. They argue for a more rigorous, comprehensive, and health-focused approach to risk oversight. Regarding residue testing, they advocate for more expansive and effective data aggregation to inform consumers and the organics community. Finally, for inert ingredients, they recommend further review of current policy, including increased transparency of ingredients in pesticide products. Thank you to Drs. Benbrook and Baker for your advocacy and hard work!   The three sets of comments are posted on HHRA’s website as part of our policy program: Comments to the NOSB on the Risk-Based Certification Discussion Document Under Consideration During the October 2024 Meeting in Portland, Oregon Written Comments on the NOSB Discussion Document “Residue Testing for the Global Supply Chain” Comments on the Inert Ingredients in Organic Pesticide Products Proposal dated August 13, 2024   Drs. Benbrook and Baker also submitted and presented comments at the Spring 2024 meeting of the NOSB, which are available on HHRA’s Policy and Regulatory Reform page.