detailed. They have the advantage of screening prospective clients to assess their level of health risk and, on that basis, recommending individualized, multidisciplinary approaches that include nutrition, exercise, and behavior modification. The Michigan guidelines attempt to forge a match between program and client that is dictated by the client's health needs. It was the hope of the task force that its guidelines would be adopted as standards of health care in weight-loss programs throughout Michigan. Adoption of the guidelines would mandate that potential clients be screened for health risks prior to beginning a calorie-restricted diet and that weight-loss programs and clinics be staffed by qualified professionals capable of delivering appropriate levels of health care.

Federal Trade Commission

In contrast to guidelines aimed at defining essential components of programs, the Federal Trade Commission's (FTC) efforts address and challenge specific, allegedly deceptive advertising claims that companies have made to promote their weight-reduction programs and diet aids. The FTC actions seek to place the companies under an order designed to remedy those allegedly deceptive claims. By the end of December 1993, the FTC had either begun litigation or settled complaints it had issued against 11 commercial weight-loss companies (personal communication with Richard F. Kelly, Esq., Assistant Director for the Division of Service Industry Practices, Federal Trade Commission).

In each of the cases that have been settled through a consent agreement, the FTC's order requires that any statements made about "success of participants of any weight loss program in achieving or maintaining weight loss or weight control" be based on data representative of either all participants or a clearly-defined subset of participants (personal communication with Richard F. Kelly, Esq.). When a claim is made that participants in a program successfully maintain lost weight, the order requires in most instances that the claim be accompanied by a disclosure of data that reflects the actual experience of program participants and a general statement about the temporary nature of most weight loss. An example given by FTC of "acceptable disclosure" is: "participants maintain an average of 60% of weight loss 22 months after active weight loss (includes 18 months on maintenance program). For many dieters weight loss is temporary" (FTC, 1993).

NIH Guidelines for Evaluating Weight-Loss Programs

The NIH Technology Assessment Conference on methods for voluntary



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