President’s Corner April Issue 2025

Keeping Your Medical Certificate/Clearance – Now and in the Future

For aviation professionals, students, instructors, and hobbyists who require a medical certificate or clearance to participate in their occupation or avocation, a medical certificate is essential, with a few exceptions. We have worked hard to gain certificates, ratings, and qualifications. We have developed our knowledge, skills, and insights to make us safer and more proficient pilots and controllers. Except for those pilots flying gliders and balloons, those flying with BasicMed and Light Sport Aircraft, and possibly in the future with MOSAIC, medical certificates are required to continue exercising our passion for flying.

The 2024 FAA Reauthorization had two important sections affecting medical certification. One, Section 801, deals with the legal interpretation of what constitutes an investigation and what a pilot’s or controller’s medical status is pending completion of that investigation. The second, Section 411, creates a workgroup of medical experts to make reports to Congress on Aeromedical Innovations and Modernization to streamline the medical certification process while maintaining an acceptable level of safety.

The most relevant effect of Section 801 is the interpretation that incomplete information accompanying a medical application and the FAA’s requirement for additional documentation constitutes an investigation. Previously, the FAA would send a pilot, with a copy to the AME, a Request for Information letter giving the pilot 60 days to respond. During this period, a pilot could continue to fly using the privileges of any unexpired medical certificate. This created a significant backlog of cases and increased processing times for all cases forwarded to the FAA for review.

Under the new interpretation, pilots would no longer receive a Request for Information letter but would instead be sent a Denial letter for medical certification with a list of reconsideration criteria for future medical certification. The implications are that pilots could no longer exercise any flying privileges requiring a medical certificate or fly under BasicMed or LSA rules. This policy was to go into effect on January 1, 2025, but implementation has been postponed until March 1, 2025, and as of March 3, 2025, has been postponed indefinitely. Whether it ultimately comes into effect is unknown, but we should approach our medical exams as if it were in place. This approach will ultimately reduce the backlogs in processing at the FAA and reduce the number of deferred medical applications.

What should pilots do to preserve their medical certificates? The good news is that 95% of pilots leave their AME’s office with a medical certificate. For the 5% who don’t, the new interpretation would have grounded them immediately upon receiving the Denial letter. They would also have to report the Denial on all future medical applications through MedXPress.

The most critical action to avoid this potential future circumstance is to prepare for your medical examination similarly to the way you would make preflight preparations for using your aircraft. Like flying, one of the first steps is ensuring all documentation is available and correct. We check the aircraft Airworthiness Certificate and Registration to be certain the N-number and dates are correct. We check the aircraft logs to be sure required inspections and ADs are performed. We check weather, NOTAMs, TFRs, and review airport facilities, fuel (well… not fuel when I am flying my glider), and alternates. We do this before every flight. Why would we not do the same for our periodic medical examination?

We can. Preflight your medical exam. The Guide to AMEs is updated monthly with new policies. Since the 2024 FAA ARC on Aviation Mental Health and Aeromedical Certification, numerous checklists for pilots and treating providers have been added to the Guide to ensure documentation is complete and correct. Several changes have put the previous medical lexicon of the Guide into layman’s terminology. Granted, there is still a long way to go in updating the 800+ page Guide, but the changes are coming. If you have a medical condition, search the Guide in the PDF format for that condition and the required testing and documentation needed. Importantly, have your treating provider complete the Detailed Clinical Progress Note. Be sure each document has your name and, if applicable, PI number on it, as well as signatures and dates.

If you have a medical issue, check with your AME or a pilot aeromedical expert advocacy service before your exam to ensure you have complete documentation. An AME can only hold a medical application for 14 calendar days before deferring the application to the FAA. Under the proposed delayed policy, an AME deferral would have resulted in receiving a Denial letter. Be certain that your AME will upload the required documents to the MedXPress application forwarded to the FAA and make appropriate comments in block 60 of the application. Deferred medical applications receive priority at the FAA Aeromedical Certification Division or the Regional Flight Surgeon’s office. With the correct and complete documentation, this will generally result in the quick issuance of a new medical certificate. If incomplete or unfavorable information is provided, a Request for Information letter will soon be sent, increasing the backlog of case reviews at the FAA and delaying the issuance of your medical certificate.

Dr. Susan Northrup, the Federal Air Surgeon, is fully committed to reducing the aeromedical processing times to under 60 days, modernizing the IT infrastructure, updating policies and references, and moving the certification authority to the lowest appropriate level by empowering AMEs and educating aviation stakeholders about aeromedical certification policy and pilot health/safety.

It is very important for pilots and controllers to work with an AME who is familiar with the evolving policies, knows how to submit the appropriate documentation, and is willing to communicate with FAA physicians if a question arises. Our physicians at AMAS do this every day. There is no fee for members of the pilot and controller unions and many corporate flight departments we represent. For those who are not clients, services are available from our physicians or other advocacy groups. See Dr. Northrup’s Pilot Minute on this very important topic.

In my next newsletter, I will write about the efforts and progress of the FAA Reauthorization Act Sections 411/413 Aeromedical Innovations and Modernization Work Group, the Medical Portal Modernization Work Group, and the Mental Health Task Group. Dr. Susan Northrup and I co-chair the workgroup and will be joined by nearly 60 aviation medicine professionals and subject matter experts to report to Congress on changes made to streamline certification, increase transparency, and improve safety.

Finally, I want us to remember the pilots, cabin crew, medical professionals, and passengers who died in the recent aircraft mishaps: PSA Airlines flight 5342 and US Army 12th Aviation Battalion in Washington, DC; Jet Rescue Air Ambulance Rescue in Philadelphia; Bering Air near Nome, AK; and the Lear 35A at Scottsdale, AZ. Although aviation remains the safest form of transportation, we each have a responsibility to do all we can to be diligent about our performance and fitness to fly safely.

Be Well, Fly Safely,

Quay

N321QS