The More Things Change ...

For most of us, with the possible exception of Millennials and GenZs who probably have never heard the expression above, “. . . the more they stay the same” jumps immediately out from our long-term memory repository to complete the sentence that titles this article.

We’ve also heard that “change is good,” and I guess that’s the case if we actually perceive the change as good, but timing has to play into that conclusion, and sometimes the good that comes from change isn’t apparent for some time after the change is enacted.  However, when it comes to playing in the FAA’s world of regulatory medical certification processing, the needle hasn’t moved much.  The needed changes that would significantly improve the efficiency of the review and timely issuance of medical certificates have been slow to come.      

Now, to be fair, in the evolving continuum of medical certification policy and procedure, initiatives to improve the overall experience both for pilots and the FAA have brought about modest success.  The first big cut at it came about in the late 1990’s with the introduction of the AME-Assisted Special Issuance program (AASI).  Pilots with certain medical conditions requiring special issuances would no longer be required to send their periodic evaluations to the FAA and then wait, and wait, and wait until the FAA granted them a new authorization.  Under AASI, Aviation Medical Examiners are authorized to reissue subsequent medical certificate special issuances after the FAA has granted the initial authorization.  Certain forms of arthritis, atrial fibrillation, bladder, breast, and prostate cancers, minor heart arrhythmias, hypo and hyperthyroidism, and migraine headaches are conditions that still fall in the AASI category. 

After several years of studying the metrics of how their workflow throughput changed, the Federal Air Surgeon and his team determined that more yet could be done to reduce the workload bureaucracy. Some of those same “low fruit” conditions that were part of the AASI have been eliminated from special issuance designation altogether and became Conditions AMEs Can Issue (CACI).  The CACI program today allows AMEs to office issue for nineteen conditions using worksheets that specify parameters that qualify for the office issuance.    

The FAA has committed to increasing the number of CACI conditions, but that process probably won’t be a walk in the park because all the “easy” ones are done; the subsequent ones will really challenge the FAA’s Office of Aerospace Medicine to balance the equation of less oversight without compromising safety.

Annually, the FAA has between 30 and 35 thousand pilots under special issuance authorizations.  BasicMed became effective in May 2017 (and yes, if you qualified for BasicMed when it first took effect, it’s time to renew your medical self-assessment course) and many pilots, more than 48,000 currently, who were under the thumb of a special issuance no longer are required to provide costly medical testing and evaluations to the FAA.  That provided some relief for the FAA’s Aerospace Medical Certification Division and the nine regional medical offices. However, the problem persists, and many of those pilots still affected by the backlog are professional pilots facing the loss of their livelihood brought on by issuance delays.

The coup de grâce was the federal government furlough late last year.  Prior to the shutdown, AOPA was observing an average of about 90 calendar days to process deferred applications.  We’re now into April and the FAA doesn’t appear to be closing the gap, so longer delays are the norm.

There are so many factors that play into the processing of medical applications.  In some respects, the FAA Office of Aerospace Medicine is a victim of its own success.  Although safety is the number one priority, the FAA’s certification philosophy, driven in part by who the Federal Air Surgeon is at the time, is to look for every way possible and reasonable to get to a “yes” for as many applicants as possible.   However, based on the conservative regulatory policies and practices that immerse the aerospace medicine community here and abroad, the pathway to a “yes” is often expensive, frustrating, always time consuming, and frequently subject to the conservative mind-set of those regulators who make the decisions.

As flying season is upon us, delays will likely continue.  If you hold or expect to need a special issuance medical, plan for a lengthy delay.  Do your homework on the medical condition you are reporting.  Have the required information with you when you visit the AME, retain copies of everything, and mail the records yourself to the FAA.  Your Pilot information Center medical certification staff can help you with the process so give us a call:  800-USA-AOPA.

Portrait of Gary Crump, AOPA's director of medical certification with a Cessna 182 Skylane at the National Aviation Community Center.
Frederick, MD USA

Gary Crump

Gary is the Director of AOPA’s Pilot Information Center Medical Certification Section and has spent the last 32 years assisting AOPA members. He is also a former Operating Room Technician, Professional Firefighter/Emergency Medical Technician, and has been a pilot since 1973.

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