In the first two installments of this series, I discussed the basic medical standards and the various protocols that are followed to comply with them. The differences between “generally disqualifying” and “specifically disqualifying” medical conditions were noted, along with the process of applying for a “special issuance authorization” of a medical certificate.
In the interim between required FAA examinations, please remember that FAR 61.53 is always controlling. A pilot must feel fit to fly and must also ensure that they have not been placed on disqualifying medications nor have a significant new medical condition that would require documentation of stability (to the FAA’s satisfaction) before resuming flight status.
While it is entirely the pilot’s responsibility to determine if they meet the ethics and responsibilities of FAR 61.53 on a day-to-day basis, the pilot may seek sage advice from their AME or aviation medicine consulting services to assist them when the situation is not simple to assess.
While the “paper chase” for the FAA is not an enjoyable task for the pilot—nor the AME—continuation of flight privileges may depend on it. Therefore, the sooner the pilot gets “on it,” the better. This could lessen any potential period of grounding while awaiting FAA review.
Once the pilot provides the AME or an outside aeromedical consultation service with the required data, it should be thoroughly reviewed before sending it to the FAA. When data is sent directly to the FAA without a prior AME or consultant review, afterward the pilot goes to their mailbox daily in eager anticipation of an FAA approval letter. Sometimes, however, what is received instead is a denial or a “nastygram” asking for additional data. This is where a comprehensive prereview of the data by the AME can be very important.
Why does this happen? The most common reasons are that the data was incomplete or there were additional medical considerations in the notes that are of interest to the FAA.
The documentation protocols may seem overly nitpicky. However, the FAA has determined that full compliance is the only way to ensure a proper review of the pilot’s aeromedical status.
When a pilot brings me data, I first ensure that all of the FAA protocols for that medical condition are fully complied with. All of the data. There are no aspects of FAA documentation protocols that are optional.
Even if the pilot’s treating physician does not feel that a certain part of the FAA protocol is medically indicated, the pilot will not get approved without that data. There are times I have to send a pilot back to their treating physician for the additional tests that were omitted during the evaluation stage. This takes additional time, of course, but usually, this kind of situation can be handled reasonably quickly.
A more distressing example of data glitches is when the documentation for the medical condition in question also references an entirely different condition that may be of concern to the FAA.
Common examples of this are notations in the “past medical history” of that pilot for other conditions not previously reported, such as kidney stones, sleep apnea, and hypertension. The AME then must ask the pilot to get the appropriate data for those conditions before sending anything to the FAA.
The FAA would have, of course, seen that these other conditions are being treated and would then send a nastygram asking for the appropriate data. A thorough prereview by the AME can often prevent this outcome. It is best to provide the FAA all of the data at once, in a gesture of full disclosure and compliance with the reporting requirements.
When minor oversights in reporting are noted, the FAA is usually pretty understanding. The FAA does not want to penalize pilots for telling the truth.
Even if the pilot was a bit tardy in reporting a medical condition, as long as there were no adverse in-flight consequences, then often there’s a bit of a “no harm, no foul” attitude in their response. Of course, more thorough and compliant reporting will be expected thereafter.
A more concerning version is when a specifically disqualifying condition is noted in medical records and the pilot never reported that condition. The FAA, quite understandably, is not happy when they find out that a pilot has been treated for years for diabetes requiring medication, for example.
A pilot is given three chances and reminders to report diabetes on the FAA MedXpress application form. Item 17a asks for medications, item 18k asks specifically about diabetes, and item 19 asks about healthcare visits.
A pilot with diabetes has therefore been reminded three times to report their condition at each and every FAA examination. We can get most pilots with diabetes certified under the special issuance program and being truthful from the get-go is the best path to follow.
Even in these cases, to the FAA’s credit, if the pilot then becomes fully and immediately compliant with reporting requirements, they are usually approved.
The FAA is less generous when it finds out—through medical documentation or from any other source—that a pilot has a history of drug or alcohol motor vehicle actions that were never reported. If the pilot has a formal history of substance abuse or dependence, or has been on psychiatric medications, and never reported the condition, that also raises the ire of the FAA.
Cases such as these may result in a denial. However, even in these less-than-pleasant situations, if the pilot complies with any medical and/or pilot certificate action placed by the FAA, medical certification may again be possible in the future.
I have also had the rare and dismaying experience of having to tell a pilot that a medical condition noted in their required records is not only specifically disqualifying but is a condition that would permanently preclude that pilot from flying. This is a very difficult and unpleasant situation for all involved.
Fortunately, there are not many permanently disqualifying conditions. The FAA’s opinion on these conditions, as noted also in the FARs, is that they compromise aviation safety beyond any reasonable confidence of approval. Examples would be for a pilot on antipsychotic medications or with an ongoing seizure disorder.
The takeaway message is that a pilot should be fully compliant with their reporting requirements from the outset. While certain medical conditions do require some documentation and effort to get approved by the FAA, the sooner this path is embarked on the better.
This ensures that any future review of medical documentation is not going to result in the surprise of finding out about yet other concerning medical conditions that had not been reported proactively. Having to play catch up at a later time is not only embarrassing and frustrating but leaves doubts about a pilot’s ethics.
I am not trying to scold nor be “the Grinch who stole your medical certificate.” I fully understand that reporting medical events to the FAA can at times be a tedious and frustrating experience. However, if a pilot does so proactively, things will not come back to haunt them in the future.
No different than operational FARs, the medical standards are regulatory. Compliance with both leads to a smooth aviation career.