If you search the Biden administration’s new National Strategy for the COVID-19 Response and Pandemic Preparedness for the term “Vitamin D,” you will come up with nothing.
Vitamin C? Nothing. Zinc? Nothing.

Nutrition? Yes, this word does appear three times, but only in the context of malnutrition and the need to strengthen federal food aid programs like SNAP and WIC.

How about the word “resilience?” It appears 18 times, but not in the way that most health-conscious people use it. The document calls for policies that will bolster supply chain resilience, and strategies to improve the nation’s resilience against “biological catastrophes.”

In short, this 200-page document says absolutely nothing about nutrition-based approaches for building immune system resilience and improving health status as a way to mitigate COVID risk.

The National Strategy, it seems, is all about “getting vaccines into arms,” ensuring that Americans have enough personal protective equipment, enforcing continued social distancing, and providing support for business sectors, as well as ordinary families being crushed by the economic impact of the pandemic.

All of the above are vital and necessary objectives. But I believe we need to do more.

From the outset of the pandemic, data from around the world pointed to a clear pattern: people with chronic diseases are at risk for coronavirus infection, and for having more acute or life-threatening cases. That’s true here in the U.S., in all communities that have been studied, and it’s true in every other country as well.

That’s not to say healthy people are risk-free, never get COVID, or never die from it. But the correlations between poor baseline health, compromised immune function, and bad COVID outcomes are very clear. Shouldn’t this simple truth have a place in public health policy?

Big Bet on Vaccines
The word “vaccine” appears in the National Strategy report 207 times. That’s more than once per page, on average. It is very clear that vaccines are where the government is staking its biggest bet.

“The national vaccination effort will be one of the greatest operational challenges America has ever faced,” the document states. “To ensure all Americans can be vaccinated quickly, the President has developed a plan for expanding vaccine manufacturing and purchasing COVID-19 vaccine doses for the U.S. population by fully leveraging contract authorities, including the Defense Production Act; deploying onsite support to monitor contract manufacturing operations; and purchasing additional FDA-authorized vaccines to deliver as quickly as possible.”

No doubt, wider vaccine distribution, along with masking and minimizing social contact will be important for controlling COVID. The Biden administration’s emphasis on them is neither surprising nor unreasonable. But many other modalities could also potentially play a role. Vitamin D is the best example.

There are not yet any published trials to show that vitamin D supplementation improves COVID outcomes, but one is currently underway: the VIVID (Vitamin D and COVID-19) trial, headed by JoAnn Manson at Brigham & Women’s Hospital in Boston.

There is also a wealth of epidemiologic data indicating that vitamin D deficiency raises COVID risk. Further, there is evidence that vitamin D can reduce the incidence of other types of pulmonary infections in vulnerable populations, and several plausible mechanisms to explain these effects.

Even Anthony Fauci—a longtime supplement skeptic—stated on Instagram Live last September that he takes vitamin D as part of his personal COVID prevention routine.

It is reasonable to think that this inexpensive, widely available vitamin would be worthy of at least a brief mention in the nation’s pandemic control agenda.

There are preliminary studies, epidemiologic data, reasonable biochemical mechanisms, and clinical case reports to suggest potential roles for: vitamin A, zinc, B vitamins, nicotinamide adenine dinucleotide (NAD+), n-acetyl cysteine, vitamin E, essential fatty acids, oil of oregano, curcumin, modified citrus pectin (MCP) and a host of other nutrients and botanicals. The Institute for Functional Medicine has compiled much of this evidence.

None of this is to suggest that vitamins, herbs or nutraceuticals can “cure” COVID-19 or prevent infection. But they could potentially mitigate its individual and societal impact. The questions are certainly worthy of serious research.

Yet none of this seems to register at the public policy level.

Policy Priorities
To be fair, the National Strategy does not claim to be a set of medical treatment guidelines, and it does not name remdesivir, baricitinib, convalescent plasma, hydroxychloroquine, or any of the other drugs under investigation as COVID treatments.

Rather it is a statement of general policy priorities aimed at quelling the pandemic, supporting the public through the prolonged containment period, preparing for future pandemics, and ultimately restoring the economy.

None but a fool would expect the White House to issue a ringing endorsement of supplements in the context of this pandemic. The federal government—regardless of which party holds power—has never been truly supportive of nutrition-based medicine or dietary supplements in any form.

But by staking the nation’s COVID response almost exclusively on vaccines and masks, while ignoring the role of negative lifestyle factors, the administration is ignoring a lot of science, and it is missing a once-in-a-generation opportunity to address deeper health issues.

Sure, we may be able to vaccinate our way toward at least partial containment of SARS-CoV-2—though the emergence of viral variants and haphazard vaccine distribution are already blunting the impact. But we’ll never be able to vaccinate our way out of the chronic disease pandemic—mostly driven by diet and lifestyle factors—that renders such a large percentage of our population vulnerable to SARS-CoV-2 and other pathogens.

Seven Pillars
The Biden COVID-19 strategy is based on seven “pillars”:

1. Restore trust with the American people;
2. Mount a safe, effective, and comprehensive vaccination campaign;
3. Mitigate spread through expanding masking, testing, data, treatments, healthcare workforce, and clear public health standards;
4. Immediately expand emergency relief and exercise the Defense Production Act;
5. Safely reopen schools, businesses, and travel while protecting workers;
6. Protect those most at risk and advance equity, including across racial, ethnic, and rural/urban lines;
7. Restore U.S. leadership globally and build better preparedness for future threats.

The administration states that decisions will be “driven by scientists and public health experts who will regularly speak directly to you, free from political interference as they make decisions strictly on science and public health alone.” To that end, the administration promises to:

• Conduct regular expert-led, science-based public briefings;
• Release regular reports on the state of the pandemic;
• Mandate CDC to develop clear, evidence-based, metric-driven public health guidance and effectively and frequently communicate guidance to the American people;
• Publicly share data around key response indicators;
• Enhance federal agencies’ collection, sharing, and analysis of data “to support an equitable COVID-19 response and recovery”;
• Maintain a public dashboard tracking COVID-19 cases at the county level, so that Americans can gauge the level of transmission in their own communities to make their own informed choices.

These are welcome changes, and the fact that the Biden administration has issued a coherent and coordinated containment strategy is already a step in a positive direction after the chaos of 2020. Assuming the intention is sincere, the excision of partisan politics from public health—to the extent that is even possible in a legislative process dominated by special interests—would be a welcome development. Likewise, a movement toward policy truly guided by science.

Defining ‘Science’
The problem is that “science” in the context of this pandemic has become very narrowly defined. Basically, the word now means “vaccine science,” and much else is being excluded from consideration.

Science is a process, not an object. And that process begins with systematized observations leading to testable hypotheses.

Exclusion of entire sets of observations—such as “vitamin D deficiency correlates with worse COVID outcomes, while people with high vitamin D levels have lower odds of getting sick”— reduces the scope of hypotheses to be studied. That, in turn, limits the practical solutions that emerge.

That is precisely what is happening with COVID. Many potentially helpful modalities that might have impact either in directly combatting the virus, bolstering human immune responses to it, or improving overall resilience and thus reducing susceptibility, are not getting studied and never make it into public health policy discussions.

This makes sense from the perspective of expedience. This is a crisis—a far-reaching and economically devastating one. The world’s governments must act, and leaders are betting on the modalities they believe will deliver the biggest impact in the shortest time. If that means other options get sidelined, so be it. 

Historically, mass vaccination campaigns have turned the tides on serious infectious diseases. Consider polio. 

With its New Deal-style graphics, and terse “vaccines in arms” promises in bold red, white, and blue, the Biden administration’s COVID vaccine promotion materials evoke the cultural memory of FDR, and the can-do spirit of the 1930s and 40s, when federal polio vaccine efforts more or less ended that awful scourge, and the nation rolled up its sleeves for common good.

Given the massive government and private sector investment in developing COVID-19 vaccines, it is not surprising that they are the cornerstone of the new administration’s National Strategy. Operation Warp Speed, the federal COVID vaccine program initiated by the Trump administration, had an $18 billion budget as of last October; it darn well better deliver!

Germ Theory Writ Large
The National Strategy is the net result of a collective myopia that began centuries ago.

Since the earliest days of epidemiology in the 16th century, people recognized that in any given epidemic some people get sick and others do not. This simple truth led to the long-running intellectual battle between those who believe the primary power to cause illness lies with pathogens—bacteria, viruses, or fungi—and those who contend that individual susceptibility is the key determinant.

This debate is famously capsulized in the 19th century rivalry between Louis Pasteur, who argued that germs were king, and Pierre Béchamp, who held that it was the “terrain”—the individual’s overall health status—that determines whether a germ can actually trigger illness.

Most modern public health experts recognize that an infectious disease is the result of three factors: the nature of the pathogen, individual susceptibilities, and environmental conditions.

But from a practical—and commercial—standpoint, Pasteur’s germ theory won the day, and continues to dominate medical thinking. The history of modern medicine is largely the history of germ theory. We expend extraordinary resources trying to destroy or fight off pathogens, and far less on understanding the “terrain” in which a pathogen does or does not cause disease. This tendency is plain to see in the COVID context.

Yes, there really is a virus and it really does cause harm. Though it does sometimes sicken and kill young healthy people, it is far more likely to kill those with compromised immune systems or chronic metabolic disorders.

Yet the entire public health dialog is about detecting and routing the virus. At this point, we are not even paying lip service to the concept of bolstering the terrain.

Yes, we need safe and effective vaccines to slow the spread of COVID, and good drugs to mitigate the acute symptom cascade. But neither drugs nor vaccines are 100% efficacious. Strain matches for ordinary flu vaccines are consistently below 50% year to year. What makes us think that a 2020 coronavirus vaccine will be fail-safe against 2021’s strains? Or 2022’s?

Then there’s the matter of convincing—or mandating—everyone to take the shots. Vaccine distribution, which has been chaotic and very uneven, is already meeting strong resistance in some communities. Though early experience suggests that the new vaccines are quite safe, many people remain wary and understandably so: the technology is new, and there are no long-term safety or efficacy studies.

Absent from the Dialog
There’s much to applaud in the new administration’s plan:

• It provides guidance for coherent, coordinated inter-agency responses;
• It creates a consistent message on key containment measures like masking in public—including all federal properties;
• It promises to increase accessibility of COVID tests, including provision of free tests for uninsured Americans;
• It explicitly acknowledges racial, ethnic, and socioeconomic health disparities, and proposes potential solutions;
• It funds basic research on potentially effective new antivirals;
• It addresses supply chain continuity, and promotes domestic production of PPE and medical equipment;
• It dedicates funding to support public school districts, colleges, and universities through the crisis;
• It mandates paid leave for workers who must quarantine if they test positive for or become symptomatic with COVID-19;
• It strengthens social safety net programs for food assistance, housing, and child care.

But the absence of any directives for improving health and resilience is a glaring oversight. Unfortunately, it was all too predictable.

The truth is holistic and functional medicine are not even at the table when lawmakers come together to discuss healthcare policy. Neither are the dietary supplements and natural
products industries.

The organizations representing holistic medical professionals are still small, and lack the funding or the political connections to ensure that their perspectives are given due consideration.

Though the dietary supplements industry is quite large at this point—total U.S. revenue was estimated at over $32 billion in 2019, and by all accounts sales accelerated in 2020—the industry has not put a lot of energy or resources toward developing relationships with legislators or public health policymakers over the last 20 years.

Public interest in nutrition and natural medicine has never been higher, yet they remain marginalized and largely excluded from policy discussions.

Supplement critics often claim that the industry has undue influence in Washington, and that with the Dietary Supplement Health and Education Act (DSHEA), it basically bought its way to a regulatory “get-out-of-jail” card. That’s laughable. The truth is, the industry’s main allies—Senators Tom Harkin and Orrin Hatch—retired years ago, and at this point it seems like we’ve got more enemies than friends in the halls of power.

Merger and acquisition deals in the supplement sector have reached multi-billion dollar levels. Why do we pretend that this is still an “emerging” industry of maverick boot-strappers? Millions of Americans seek the care and counsel of holistic, naturopathic, and functional medicine doctors. Why do we still act like a fringe movement with no voice and no power to impact the great issues of our day?

There’s a new administration at the helm. There’s a major health crisis raging, and few effective conventional treatment options. Our field now has a unique opportunity to demonstrate the merits of our products, and the principles and philosophies behind them.

Have we got the will and the resources to meet the day? 

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Erik Goldman is co-founder and editor of Holistic Primary Care: News for Health & Healing, a quarterly medical publication reaching about 60,000 physicians and other healthcare professionals nationwide. He is also co-producer of the Practitioner Channel Forum, the nation’s leading conference focused on opportunities and challenges in the practitioner segment of the dietary supplement industry. He can be reached at erik@holisticprimarycare.net.