In issuing this opinion, we have relied solely on the facts and information presented to us. We have not undertaken an independent investigation of such information. This opinion is limited to the facts presented. If material facts have not been disclosed or have been misrepresented, this opinion is without force and effect. C.F.R. Part 1008.
Most Participants have, or are at risk for, cardiovascular disease or stroke.
In essence, the Proposed Arrangement is a preventive health program for chronic disease patients. Mentors counsel the Participants on how to alter their nutrition, exercise, and other lifestyle habits, and thereby improve their health. Using the risk reduction goals and the personal action plan as a guide, each Participant visits a Mentor approximately twenty times during the first year of enrollment in the Program. During each visit, the Mentor works with the Participant using various behavior modification techniques. Participants are required to keep diet and exercise diaries that the Mentors check during each visit.