With BasicMed now up and running, more than 51,000 pilots no longer contend with the FAA Form 8500-8 airman medical application, aka “MedXpress.” However, for commercial pilots, new student pilots, pilots who don’t meet the BasicMed “eligibility” requirements like having held a medical certificate after July 15, 2006, or fly outside the scope of BasicMed, MedXpress is alive and well and is a fact of life.
On August 13th, the FAA published in the Federal Register a request for comments on three FAA Forms: the airman medical application, Form 8500-8; and two eye evaluation forms, 8500-7 and 8500-14. The scope of the request is to collect data on the necessity of information requested on the medical application form, the accuracy of the estimate of burden on the applicant who completes the form, ways that the FAA can “enhance the quality, utility and clarity of the information collection,” and ways the burden “could be minimized without reducing the quality of the collection information.”
The MedXpress form has for decades been problematic for airmen because of the complexity of the language used and the amount of detailed medical information the FAA requires of airmen. Because it is a federal legal document, the potential penalties are severe for anyone who “knowingly and willingly falsifies, conceals or covers up by any trick, scheme, or device a material fact, or who makes any false, fictitious or fraudulent statements or representations, or entry….”
With this request for comments, the public and AOPA have the opportunity to offer the government their thoughts on essentially the whole medical certification process that begins with submission of the medical application and completion of a physical exam with an AME. As I’ve said in previous comments, the regulatory process of medically qualifying pilots is complicated by virtue of the very bureaucracy of the system and the FAA’s mandate for aviation safety. The data we disclose on the application becomes the basis of an “investigation” conducted by the FAA based upon the information provided on the 8500-8 and supplemental medical information provided by the pilot.
A medical “history” that is considered inconsequential and benign by your physician or specialist who is treating you as a patient may be viewed as potentially disqualifying by the FAA. And by the nature of the process, the FAA knows their policies (“rules of engagement”) but that information certainly isn’t public knowledge and becomes known to the airman only when the FAA asks for more information or issues a letter of denial. That’s the value of our Pilot Information Center medical certification staff who live in this world every day and work to make sense of and educate our members about how the system works, or, as they say in Washington, “how the sausage is made.”
AOPA has met with FAA officials to express our serious concerns about the medical application, identify needed improvements, and will be filing its official comments by the October 15th deadline. A primary concern is the “dropdown” examples that were added to the form relatively recently, which materially change the scope of the questions being asked on the form. Take for instance Question 18j, which asks the applicant to check yes or no to “Kidney stone or blood in urine” that now is accompanied by a dropdown that states, “For example: Kidney stone, kidney cancer, kidney transplant, blood in urine, chronic recurrent urinary tract infections, urinating frequently at night.” Examples that go beyond what the question is asking about create confusion for pilots filling out the application, and AOPA is working to identify and correct these issues. This is another work in progress, and we will keep you updated as the process moves along!