Group 1 is those airmen who already have a special issuance for OSA. They just follow the requirements in their authorization letter. Obstructive sleep apnea on CPAP falls under the AME Assisted Authorization for Special Issuance-type waiver that allows your medical examiner to reissue you a medical certificate annually providing you comply with the requirements of the letter.
Group 2 airmen reveal to their AME that they have been diagnosed and are being treated for OSA. The airman must provide to the FAA the results of the initial polysomnogram and split studies, a status report from the treating physician, and the results of a current compliance report. The AME is allowed to issue the airman a medical certificate, and the airman will have 90 days to provide these records and testing.
Group 3 category airmen are those who are determined by their AMEs, based upon questioning and examination, not to have sleep apnea. The AME annotates this on the FAA examination and issues the medical certificate. The airman goes on his or her happy way!
Group 4 airmen are those who AME feels are at low risk for having OSA. The AME must discuss the risk with the airman and will provide the airman with educational literature published by the FAA, and issue the medical certificate in the office, if the applicant is otherwise qualified.
In Group 5, the AME feels the airman is at high risk for having OSA. The AME gives the airman information detailing the required evaluation from the pilot’s treating physician. The AME may still issue the airman a medical certificate. The FAA will follow up with a letter to the pilot requesting more information. The airman will have 90 days to provide that information.
Group 6 airmen are those whose symptoms are severe enough that the AMEs are instructed to defer issuing the medical certificate. Here the AME is supposed to feel that the airman's condition is an immediate risk to aviation safety. These airmen will need to see a Board Certified Sleep Specialist and have a sleep study. If the study is positive, they will need to initiate treatment and provide all the testing results, a letter from the sleep specialist, and a current compliance print out report to the FAA. The FAA will then send them a special issuance letter.
The new FAA policy on obstructive sleep apnea addresses many of the concerns raised by AOPA. AOPA had strongly objected to requiring thousands of pilots to go through expensive and intrusive testing based exclusively on body mass index (BMI).