Human Intervention Motivation Study, or HIMS, is a program developed by the FAA to get primarily commercial pilots back into the cockpit after identification of alcohol or drug addiction and recovery from treatment. The program was developed in the early 1970s as a joint venture by the Air Line Pilots Association (ALPA), the largest airline pilot union, and the FAA, and funded by the National Institute for Alcohol Abuse and Alcoholism. Although the “study” is over, the HIMS term has persisted as the name of the ongoing certification procedure.
HIMS is classified as a safety program with a goal of continual monitoring and support of the pilot patient, and is considered a team effort between the pilot, the treatment program, support groups or individuals, and specially designated AMEs called HIMS AMEs. A HIMS AME has completed a weeklong initial training program with refresher updates every three years.
About 20 years ago, the program was opened up to noncommercial pilots seeking third-class medical certification for private flying. This was a difficult change for the FAA because noncommercial pilots do not have Chief Pilots and other integral monitoring and support systems that airlines and other commercial operators generally have, and this continues to be a challenge for private pilots today.
Moreover, the initial process of a pilot getting a Special Issuance (SI) after a determination of an alcohol or drug problem is onerous. Inpatient treatment is usually required for a minimum of 28 days followed by a regular aftercare program which includes AA/NA or equivalent programs acceptable to the FAA. Random alcohol and/or drug tests are required, as are annual psychological and psychiatric evaluations from specifically approved psychologists and psychiatrists. As you can imagine, this is time consuming and expensive.
Things can get a little crazy when a third-class initial applicant had a problem twenty years before and has been sober since. They obviously do not need an inpatient treatment program, but without good documentation of an ongoing aftercare program and continued sustained abstinence and sobriety as well as the other requirements the FAA imposes, these airmen are at a distinct disadvantage in working with an FAA that has little latitude in their approach to these pilots.
In 2010, the FAA adopted a policy for special issuance consideration with use of one of four specific SSRI medications, a reasonable change considering that so many alcohol and drug disorders are associated with co-occurring mental health disorders. Although the policy was well received at the time, the 2015 crash of Germanwings Flight 9525 unfortunately created a setback. The National Transportation Safety Board, in a recommendation to the FAA from many years ago, considers substance dependence (including alcohol) a “lifelong disorder,” and that airmen should be continuously re-evaluated to ensure their flying is safe. After more than 10 years since the recommendation came out, the FAA recently adopted the recommendation, and that leads to years of monitoring and for some pilots, lifelong monitoring under a HIMS special issuance authorization.
How does a pilot with a third-class medical end up being required to enter the HIMS program? The most common reason is a DWI/DUI for a second time or a DWI/DUI for the first time with a breath alcohol test (BAT) of 0.15 or greater, or a refusal to take the BAT, which the FAA assumes as pleading guilty to driving under the influence. The 0.15 level is considered by the FAA to show tolerance, not just a one-time event, and thus an ongoing alcohol problem. FAA medical standards, Part 67.107, .207, and .307 include specific definitions for mental health conditions that are different from the current Diagnostic and Statistical Manual (DSM-5) standards which is the diagnostic criteria used by psychologists and psychiatrists, and is only one area where the DSM and the FAA disagree.
After the initial SI is granted, the requirements for ongoing alcohol/drug SIs include complete abstinence of alcohol and mood-altering drugs, minimum of once a week or more of AA meetings or equivalent, attendance at a formal aftercare program weekly, and an annual psychiatric and psychologic evaluation. In addition, there will probably be a requirement for 14 random drug tests in a 12-month period and at least a quarterly meeting with a specific HIMS AME (a formal request must be submitted to change HIMS AMEs). As you can see, this is an expensive and time-consuming endeavor. Depending upon the circumstances, this monitoring can last five to seven years as long as the pilot continues to fly.
More frustrating for pilots and HIMS AMEs alike is the length of time required for initial SI certification and recertification. Most of the process is on paper and not transmitted electronically. Much of the delay is related to physical files being transmitted by mail from OKC to Washington, DC, and back. The process relates to how the paperwork is examined. Here is an email from an FAA official who explains the delays with suggestions for preventing them (words in parentheses are mine):
First, let me acknowledge what you all know---appeals take much longer than we would all like. In the case of Drug and Alcohol cases, the process is made much more cumbersome because part of the process occurs at AMCD (Airman Medical Certification Division—OKC) and part occurs at FAS (Federal Air Surgeon—DC). In addition, our consultants have historically only been able to handle “paper cases” because they do not have access to our electronic medical records. Add to that, here in AAM-240, we have no administrative staff. This makes it extremely difficult for us to handle “mixed” cases, that is, cases where part of the case is electronic and part is hard-copy/paper. In addition, up until the beginning of 2020, none of our internal processes were electronic. Fortunately, this changed just in time for Covid to drive all the analysts out of the office and into telework. Currently, I go to the office most days, but I am not an analyst. When you mail us a package, I turn around and mail to it Dr. Sager just as it is, unless it is obviously missing something. Here are some things you and your staff can do to ensure this process goes as smoothly/quickly as possible:
Besides implementing the Huddle process, we have made a few other, less obvious changes to try to speed things up. For example, even though AMCD issues the final determination in these cases, we no longer forward the consultant reports to them if they are requesting more information or a neuropsych consult. We are issuing the Additional Information letters and sending the cases needing neuropsych directly to Dr. Georgemiller. This saves weeks or more. We have also implemented enhanced tracking in order to reduce the chances of cases getting “lost.”
If anyone can understand that email, please let me know.
We all know that alcohol and drugs are forbidden while piloting an aircraft. Most of these drugs can affect a pilot even when they are not using them. If you abuse alcohol or drugs, you need to get help. That is an absolute. Unfortunately, the process to fly again is difficult but worth it.
If you are on one of the four approved antidepressants (Lexapro, Celexa, Prozac, & Zoloft), although the process is unduly onerous, it should be followed so you can be legal. The AOPA Pilot Protection Services program can help you with the process.
