Largely, yes.
But partially, the concept of driving testing based on "rooting out" undiagnosed conditions. Where do you stop?
I understand that >40 BMI and >17 in neck has a very tight correlation. But that's only a temporary waypoint. They have already decided they will ratchet the BMI cutoff down as time goes on. Where is the level of correlation that is sufficient? And who decides?
Can the next air surgeon decide there is a correlation between age and coronary disease, and that all pilots over 60 years old must have a stress test (at their own expense, of course)? Or screening for cataracts? Or some other screening? How about requiring post-partal pilots to get screened for depression prior to exercising their airman privileges?
What is the limiting principle that there must be some evidence of a problem, rather than shotgun testing of airmen?