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ACP Position Paper on Dietary Supplements

jjcush@gmail.com
Jul 15, 2026 10:00 am

More than half of U.S. adults use dietary supplements, yet only a quarter use supplements recommended by a healthcare professional, and current law lets supplements reach the market with no premarket safety evaluation, unlike drugs or food additives. The paper notes that under DSHEA, dietary ingredients receive none of the premarket scrutiny applied to drugs or food additives, leaving patients exposed to contamination, mislabeling, and unrecognized drug interactions. ACP President Jan K. Carney, MD, MPH, MACP, framed the problem as one where skewed public perception of supplement safety combined with low rates of patients disclosing supplement use to clinicians compounds the risk of adverse outcomes, which the paper's recommendations are designed to address from a policy standpoint. Medical Xpress + 2

The 10 Recommendations

  1. Modernize DSHEA to require evidence-based review, registration, and FDA premarket approval before supplements reach the market.
  2. Mandate USP quality standards — supplements must meet identity, purity, and potency standards set by the United States Pharmacopeia.
  3. Adequately fund and resource the FDA for ongoing oversight of supplement manufacturing, quality, safety, and labeling.
  4. Bolster FDA postmarket surveillance authority to better detect adulterated, contaminated, or mislabeled products already on shelves.
  5. Grant FDA mandatory recall authority — amend DSHEA so FDA can bypass the current voluntary recall process when notified of adverse events or mislabeling, enabling faster removal of dangerous products. Medical Xpress
  6. Strengthen FTC oversight of marketing, with particular attention to supplement promotion by paid social media influencers, and empower swift enforcement action against violations. Medical Xpress
  7. Build a public supplement database with standardized product and ingredient information to improve transparency and traceability.
  8. Standardize supplement-use documentation and EHR integration so clinicians can systematically capture and share patient supplement use.
  9. Expand professional and patient education on supplement risks, interactions, and evidence gaps.
  10. Sustain NIH Office of Dietary Supplements funding — ACP urges Congress to continue funding the NIH Office of Dietary Supplements to ensure ongoing safety research and public awareness efforts. Medical Xpress

Overview

The paper's throughline is that DSHEA (1994) built a regulatory gap: supplements are defined as products containing a "dietary ingredient" — vitamins, minerals, amino acids, probiotics — spanning uses from basic nutrition to athletic performance, yet they bypass the premarket safety review applied to drugs and even ordinary food additives. ACP's response is a coordinated overhaul touching four domains: regulatory authority (premarket review, quality standards, recall power), enforcement infrastructure (FDA funding, FTC marketing oversight), clinical integration (documentation, EHR capture, education), and research infrastructure (public database, sustained NIH funding). This is consistent with ACP's prior public-health advocacy stance and mirrors long-standing IOM/National Academies critiques that DSHEA's "history of use equals safety" assumption is scientifically unsound. Medical Xpress

Conclusion

ACP is positioning dietary supplement reform as a patient-safety and public-health imperative rather than a niche regulatory issue — relevant to rheumatology given how often patients self-initiate supplements (glucosamine, fish oil, turmeric/curcumin, vitamin D) that can interact with DMARDs, biologics, or anticoagulants, often without disclosure. The paper's call for standardized EHR documentation of supplement use is particularly actionable at the practice level, independent of whether Congress acts on the legislative asks.

Key Takeaways

  1. Supplements currently reach market with no FDA premarket safety review — ACP wants that changed via DSHEA modernization and USP quality standards.
  2. ACP recommends mandatory (not voluntary) FDA recall authority for adverse events or mislabeled products.
  3. FTC marketing oversight, especially of influencer-driven promotion, is flagged as an enforcement gap.
  4. Clinically, the push for standardized, EHR-integrated supplement documentation is a call rheumatologists can act on now, given how often patients don't volunteer supplement use.

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Disclosures
The author has no conflicts of interest to disclose related to this subject
The author used AI to research and organize this content, and maintains responsibility for its accuracy
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