Food as Medicine in the United States: A Public Health Policy Analysis with Behavioral Health Systems Implications

Food as Medicine has gained increasing national attention as a strategy for addressing food insecurity, diet-related chronic disease, and the persistent disconnect between clinical nutrition recommendations and people's actual ability to obtain health-supporting foods. The basic premise is compelling: nutrition affects health, and telling people to eat differently has limited value when healthier food is unaffordable, inaccessible, or difficult to obtain.

For behavioral health systems, this is not a peripheral public health issue. People living with serious mental illness experience substantial cardiometabolic risk and premature mortality, and the burden becomes even greater when serious mental illness and diabetes occur together. A recent meta-analysis involving more than 161,000 people with co-occurring serious mental illness and diabetes found significantly higher all-cause and cardiovascular mortality compared with people who had diabetes without serious mental illness. Food insecurity is also consistently associated with poorer mental health, including higher rates of depression and anxiety, although these associations should not be interpreted as evidence that food insecurity alone causes psychiatric illness.

These intersections make nutrition relevant to priorities already central to behavioral health systems: whole-person care, health equity, social determinants of health, physical-health disparities, Medicaid, and coordination across behavioral health, primary care, and community services. They also raise an important policy question. If Food as Medicine is intended to help improve health among populations at significant risk, where exactly does it intervene in the pathway between the food environment and disease, and how much population-health change can reasonably be expected from it?

Overall, the evidence supports targeted use and continued development of Food as Medicine, particularly for populations experiencing food insecurity and nutrition-sensitive disease. Its longer-term population-health value, however, is best understood alongside—not in place of—policies that shape the broader food environment.

Key Data at a Glance

The scale of the underlying health challenge is substantial. 40.1 million Americans have diabetes, and 115.2 million adults have prediabetes; diabetes accounted for approximately 25% of U.S. healthcare spending in 2021. At the same time, 55% of calories consumed by Americans age one and older come from ultra-processed foods, rising to 61.9% among children and adolescents. Three in five Americans age two and older consume more added sugar than recommended, with adult men averaging approximately 19 teaspoons of added sugar per day and women approximately 15 teaspoons.

These statistics do not establish that any single feature of the American diet is responsible for the nation's chronic-disease burden. They do, however, illustrate the environment in which Food as Medicine is being developed: healthcare and behavioral health systems are attempting to improve health while diet-related disease is highly prevalent and heavily processed foods and excess added sugars remain common features of the food supply.

What Food as Medicine Actually Does

Food as Medicine is not entirely new federal policy. Following the 2022 White House Conference on Hunger, Nutrition, and Health, Congress funded an HHS Food Is Medicine initiative in fiscal year 2023 and directed the department to develop a federal strategy addressing nutrition-related chronic disease and food insecurity. HHS now uses a broad framework that includes nutritious food, healthcare, human services, community systems, education, and policy change.

Federal nutrition incentives and produce-prescription programs also predate the current legislation. USDA's Gus Schumacher Nutrition Incentive Program continues to fund produce-prescription initiatives, while states and health systems have experimented with medically tailored meals and related nutrition supports through Medicaid and other delivery systems. The emerging federal agenda is therefore better understood as an effort to expand, coordinate, standardize, evaluate, and integrate existing approaches than as the invention of a wholly new intervention.

A newer proposal, H.R. 8390, the National Food as Medicine Program Act of 2026, would move this work further into Medicaid by providing grants to states to plan, implement, expand, or evaluate Food as Medicine programs through Section 1115 demonstrations. The bill includes medically tailored meals, produce prescriptions, nutrition counseling, cooking education, health coaching, and other nutrition supports. As of August 28, 2026, however, H.R. 8390 remains an introduced bill rather than enacted law. It does not establish a universal Medicaid Food as Medicine benefit; a separate proposal, H.R. 8391, would create broader Medicare and Medicaid coverage requirements for certain food and nutrition services.

The significance of the current federal direction therefore lies primarily in institutionalization, financing, healthcare integration, infrastructure, evaluation, and potential scale. That is not an insignificant change. A promising program dependent on a local grant or individual champion has a very different capacity for sustained impact than one incorporated into financing and delivery systems.

What the Evidence Supports—and What It Does Not Yet Prove

The evidence base for Food as Medicine is legitimate, but the findings are not equally strong across all interventions or outcomes. A 2025 American Heart Association scientific statement reviewed 14 randomized U.S. Food Is Medicine trials and found relatively consistent improvements in food security and diet quality. Clinical outcomes, including measures such as HbA1c, blood pressure, and body mass index, were considerably less consistent, and the review identified important unanswered questions about intervention intensity, duration, population selection, scalability, and long-term effectiveness.

This distinction matters because Food as Medicine is often discussed as though it were a single intervention. In practice, a modest produce prescription for a food-insecure adult is substantially different from providing medically tailored meals to someone with complex diabetes or cardiovascular disease. An intervention may successfully improve food access without producing a measurable change in a clinical biomarker, while a more intensive intervention among a medically complex population may have a different effect altogether.

For behavioral health populations, the causal pathways can be particularly complex. Cardiometabolic health may be influenced by psychiatric illness, social and economic conditions, healthcare access, sleep, functional capacity, treatment factors, and other health behaviors in addition to nutrition. The fact that nutrition is important does not mean nutrition alone can resolve those risks.

A sound policy approach should therefore move beyond asking simply whether Food as Medicine “works.” The more useful questions are which intervention works, for which population, for which outcome, at what intensity, for how long, and at what cost. At present, Food as Medicine is most accurately described as evidence-informed and promising, with stronger evidence for food security and dietary improvement than for universal clinical or financial outcomes.

The Larger Public Health Question: Where Does the Policy Intervene?

Food as Medicine addresses an important problem by helping selected individuals obtain healthier food. Its primary mechanisms, however, have comparatively little direct effect on the composition, pricing, marketing, and routine availability of food across the population.

That distinction helps clarify both the value and the limitations of the strategy. Food as Medicine typically begins once nutritional, medical, or social risk has become identifiable: a person is food insecure, has diabetes or another nutrition-sensitive condition, or qualifies for a healthcare-based intervention. Food formulation, pricing, marketing, ingredient regulation, procurement standards, and commercial incentives operate earlier in the pathway by helping determine what foods people encounter and consume before disease develops.

This matters in a country where more than half of calories are currently obtained from ultra-processed foods. The term itself needs to be used carefully because processing is not inherently harmful. Frozen vegetables, canned beans, fermentation, pasteurization, and fortification are all forms of food processing that can enhance safety, affordability, shelf life, or nutritional access. The more useful public health question concerns overall food formulation, including added sugars, sodium, refined starches, fiber, fat composition, energy density, portion size, and the degree to which foods are designed for highly palatable, convenient consumption.

Experimental research remains limited, but it suggests that this distinction may be important. In an NIH randomized controlled feeding study, adults consumed substantially more calories and gained weight while eating an ultra-processed diet than while eating a minimally processed diet, despite efforts to match the diets on several conventional nutritional measures. The study was small and short-term, so it should not be generalized to every processed food; nevertheless, it suggests that the health implications of food may extend beyond the presence of one or two nominally healthy ingredients.

This is relevant to Food as Medicine because a prepared meal containing chicken and vegetables can vary considerably in nutritional quality depending on how it is formulated. If the purpose of the intervention is improved health, the characteristics of the final food delivered should remain central to how food quality is defined.

H.R. 8390 also places emphasis on local and regional sourcing and organic or regenerative agricultural production. Those goals may provide legitimate benefits related to sustainability, agricultural resilience, regional economies, and environmental health, but they rest on a different evidence base from clinical nutrition. Evidence that nutritious food improves health should not automatically be interpreted as evidence that a particular agricultural production method independently improves the clinical effectiveness of a Food as Medicine intervention. The two objectives can coexist, but they should be evaluated separately.

Added Sugar Illustrates What Upstream Policy Can Accomplish

Added sugar offers a useful example of the distinction between helping an individual navigate the food environment and changing the environment itself. Americans consume substantial amounts of added sugar, and excess intake contributes to excess energy consumption and is associated with obesity, dental disease, diabetes, and cardiovascular risk. CDC currently reports that three in five Americans age two and older consume more added sugar than recommended.

The United States is beginning to address this more directly. FDA's 2026 Human Foods Program includes development of an added-sugar reduction strategy, alongside continued work on sodium, food labeling, food chemicals, and other contributors to diet-related disease. The current sugar strategy emphasizes encouraging industry to lower added sugar, developing labeling approaches and nutrient claims, consumer education, and examining sugar alternatives.

The United Kingdom's Soft Drinks Industry Levy provides a useful contrast because it changed the economic incentives surrounding product formulation. Beverage manufacturers whose products exceeded specified sugar thresholds could pay the levy or reformulate their products, and reformulation became a substantial industry response. Between 2015 and 2019, approximately 65% of soft drinks initially above the lower sugar threshold had been reformulated below it. By 2024, the sales-weighted average sugar concentration of beverages within the levy had declined by approximately 47% compared with 2015.

The significance of this example is not that the United Kingdom has solved obesity or diet-related disease. It has not. Rather, the levy illustrates the population-health potential of changing default exposure. When widely consumed products contain less sugar, millions of people can experience lower exposure without first receiving a diagnosis, qualifying for Medicaid, enrolling in a health program, understanding a nutrition label, or deliberately sustaining a different choice every time they purchase a beverage.

There is also emerging evidence of measurable health effects. UK evaluations have associated the levy with reductions in hospital admissions for childhood dental extractions and with improvements in obesity outcomes among some groups, although these findings come from natural experiments and should not be interpreted as demonstrating uniform causal effects across all children or health outcomes.

The policy distinction is therefore useful: Food as Medicine offers targeting and precision, while reformulation and other upstream policies offer population reach. Those are complementary rather than competing approaches.

European food policy provides additional examples of upstream intervention through additive authorization, pesticide standards, labeling requirements, and precautionary risk-management approaches. These comparisons should not be simplified into a conclusion that European food systems are uniformly superior, but they demonstrate that governments have a range of tools for shaping the conditions under which food is manufactured and sold rather than relying exclusively on consumers or healthcare systems to manage risk after exposure occurs.

Why This Matters for Behavioral Health Systems

For behavioral health leaders, the relevance of Food as Medicine lies primarily in whole-person health rather than in the proposition that food itself is a treatment for mental illness. Food insecurity, diabetes, cardiovascular disease, and premature mortality intersect with the lives of many people served by behavioral health systems, particularly those living with serious mental illness and complex social needs. The association between food insecurity and depression and anxiety further illustrates how nutritional and behavioral-health vulnerability frequently coexist.

Food as Medicine may therefore become a useful component of integrated behavioral health systems by addressing food insecurity and cardiometabolic risk, strengthening connections with primary care, and helping reduce physical-health disparities. Its value should not be overstated, but neither should nutrition be treated as outside the legitimate scope of behavioral health simply because it is not a psychiatric intervention.

The Medicaid context makes this particularly relevant. H.R. 8390 proposes using Medicaid Section 1115 demonstrations as a primary vehicle for expansion, while broader enacted federal policy is simultaneously expected to reduce Medicaid enrollment and spending relative to previous projections. CBO estimates that the 2025 reconciliation law will reduce projected Medicaid outlays by approximately $1.2 trillion between 2026 and 2035 and reduce enrollment by 13.1 million people in 2035 relative to its prior baseline. These are separate policies and should not be portrayed as an internal contradiction within Food as Medicine legislation, but the broader financing environment may affect states' capacity to build and sustain new nutrition services.

For behavioral health and public health systems, that creates an important implementation question: not simply whether an intervention improves outcomes for the people who receive it, but whether the program can reach a sufficiently large and appropriate population to produce meaningful system-level impact.

A More Complete Public Health Frame

Food as Medicine represents a credible and potentially valuable development in the relationship between nutrition, healthcare, public benefits, and community systems. Its strongest evidence supports improvements in food security, food access, and dietary quality, while its clinical and cost effects remain more variable and require continued rigorous evaluation.

The underlying intervention models are also largely established. The federal opportunity lies in creating more durable infrastructure, common standards, sustainable financing, stronger integration, and better evaluation so that effective approaches can move beyond isolated programs.

At the same time, Food as Medicine addresses only part of the pathway between diet and disease. It can help people obtain healthier food within the food environment in which they currently live, while upstream policy can change characteristics of the environment itself. The UK sugar-reformulation experience is particularly useful because it demonstrates that public policy can change what is consumed without requiring each person to become the primary agent of prevention.

For behavioral health systems, both perspectives matter. Individual patients need meaningful support now, particularly when food insecurity and cardiometabolic illness compound already complex behavioral-health needs. Population health also requires attention to the conditions that continually generate risk across communities.

Conclusion

The central public health question is not whether food matters to health; the evidence that nutrition and food access matter is substantial. The more important policy question is where we choose to intervene in the pathway between the food environment and disease.

Food as Medicine provides a valuable mechanism for helping people experiencing food insecurity, nutrition-sensitive illness, and elevated medical risk. For behavioral health systems, it may strengthen whole-person care by addressing nutritional access, metabolic risk, and physical-health disparities among populations already experiencing significant behavioral and social complexity.

Its long-term impact, however, will be greatest when targeted nutrition interventions are paired with population-level prevention that addresses food formulation, added sugars, sodium, ingredient oversight, pricing, marketing, and other characteristics of the food environment.

A coherent national strategy does not require choosing between Food as Medicine and broader food policy. It requires recognizing that the two operate at different points in the same system: one helps people obtain healthier food within the environment that exists today, while the other seeks to create an environment that produces less preventable disease in the future.

Selected References

• Centers for Disease Control and Prevention. National Diabetes Statistics Report. Updated 2026.

• Centers for Disease Control and Prevention. Be Smart About Sugar. Updated April 2026.

• Williams, A. M., Couch, C. A., Emmerich, S. D., & Ogburn, D. F. Ultra-processed Food Consumption in Youth and Adults: United States, August 2021–August 2023. NCHS Data Brief No. 536. 2025.

• Seligman, H. K., Angell, S. Y., Berkowitz, S. A., et al. A Systematic Review of “Food Is Medicine” Randomized Controlled Trials for Noncommunicable Disease in the United States: A Scientific Statement From the American Heart Association. Circulation. 2025.

• U.S. Department of Health and Human Services, Office of Disease Prevention and Health Promotion. Food Is Medicine: A Project to Unify and Advance Collective Action.

• U.S. Congress. National Food as Medicine Program Act of 2026, H.R. 8390, 119th Congress. Introduced April 20, 2026.

• U.S. Food and Drug Administration. Human Foods Program 2026 Priority Deliverables. 2026.

• Office for Health Improvement and Disparities, Government of the United Kingdom. Sugar Reduction in Drinks: 2015 to 2024 and Strengthening the Soft Drinks Industry Levy: Summary of Responses.

• Moosavian, S. P., et al. The Association Between Food Insecurity and Adverse Health Outcomes in Adults: An Umbrella Review of Systematic Reviews and Meta-Analyses. Nutrition Reviews. 2026.

• Risk of Mortality and Complications in Patients With Severe Mental Illness and Co-occurring Diabetes Mellitus: A Systematic Review and Meta-analysis. 2024. PMID 39612727.

• Congressional Budget Office. The Budget and Economic Outlook: 2026 to 2036. 2026.