BasicMed Documents

BasicMed is now four years old, so for pilots taking advantage of the alternative medical eligibility requirements or considering making the switch, here is a reminder of the documents you are required to have and what to do when asked by the FAA to demonstrate BasicMed compliance.

BasicMed, which became effective May 1, 2017, allows for an airman to act as pilot in command of an aircraft without a current medical certificate so long as the pilot and the aircraft meet certain conditions. Most notably, the airman must have held an FAA medical certificate at some point after July 14, 2006. Further, the most recent medical certificate cannot have been suspended or revoked, any special issuance authorization cannot have been withdrawn, and the most recent medical certificate application cannot have been denied. For a recent article regarding medical eligibility requirements relating to BasicMed, see here.

There are two unique documents necessary to establish your qualification to fly under BasicMed. The first is the certificate of completion from an authorized online BasicMed medical education course. AOPA and Mayo Clinic are currently the only two providers of FAA authorized BasicMed medical education courses—they are available here and here, respectively. Once issued, the certificate of completion must be “available” in your logbook when flying under the BasicMed rules.

The second unique document is a completed BasicMed Comprehensive Medical Examination Checklist (CMEC). The CMEC is in many ways similar to the ordinary medical certificate application. Notably, however, the CMEC is not required to be completed by an Aviation Medical Examiner (AME) and is not sent to the FAA Aerospace Medical Certification Division for review. Instead, the CMEC must be signed by a state-licensed physician and, like the medical course certificate, must be “available” in your logbook to fly under the BasicMed rules.

While the medical course certificate and the CMEC must be in your logbook, only certain pilots need to carry their logbook while flying. If you hold a private pilot or higher certificate, you need not carry your logbook onboard an aircraft in most circumstances; so, if you are not carrying your logbook, there is no need to carry the BasicMed documents. In fact, unless you are required to, it is generally a good idea to leave your logbook at home so as not to risk anything happening to this important document. Rather, your logbook with your medical course certificate and CMEC must be presented upon a reasonable request.

In addition to the medical course certificate and CMEC, you must have a current and valid U.S. driver’s license in your possession or readily accessible while acting as pilot in command of an aircraft under the BasicMed rules. A passport or other form of identification is not an acceptable substitute. If your driver’s license is suspended or revoked, you are not eligible to fly under BasicMed until your driver’s license is fully reinstated. Further, you must comply with any restrictions on your driver’s license (such as requiring the use of corrective lenses or prosthetic aids or limiting its use to daylight only).

Importantly, while your must have held a valid medical certificate after July 14, 2006, you are not required to maintain or provide proof of a previously issued medical certificate or special issuance authorization in order to demonstrate compliance with the BasicMed rules. Anyone thinking that they can skirt the requirement to have a previously issued medical certificate, think again. The FAA maintains a database which reveals whether you had a previously issued medical certificate and whether the medical certificate had been suspended or revoked, any special issuance authorization had been withdrawn, or a medical certificate application had been denied. The FAA has been known to send threatening letters to pilots flying under BasicMed when the FAA has reason to believe they do not meet the BasicMed eligibility requirements.

Now you might be wondering what to do with your BasicMed documents once they expire or after they are superseded by new documentation. There is no specific requirement for you to keep your old BasicMed documents in those circumstances, and neither does there appear to be any guidance from the FAA on the subject. However, while some favor destroying any documents that are not required to be maintained, others argue that if you are ever called upon to establish eligibility for a previous flight, these documents could prove useful.

That brings us to how to handle an FAA request to demonstrate that one holds a BasicMed qualification. Common situations in which this may occur include ramp checks, practical tests, and accident or incident investigations. Fortunately, the FAA has issued guidance to its Aviation Safety Inspectors (ASI) for these situations, so we have a pretty good idea of what to expect. This guidance can be found in FAA Notice N 8900.420. One quick note—this notice expired as of May 3, 2018. However, the FAA explicitly represented that the information in this notice would be incorporated into the monstrosity that is FAA Order 8900.1 before May 3, 2018. Despite such a representation, the FAA has apparently not yet done so.

If approached by an ASI for a ramp check and asked about your medical qualification to fly, you should indicate that you are flying under the BasicMed rules. You must be able to produce a current and valid U.S. driver’s license and must be able to explain how you meet the BasicMed requirements. However, you are not typically expected to produce your BasicMed medical course certificate or the CMEC. Again, this is because these documents are to be “available” in your logbook, and your logbook is typically not required to be carried onboard the aircraft. However, if you are unable to explain your BasicMed eligibility or the ASI has reason to doubt your eligibility, the ASI may demand that you produce your medical course completion certificate within a reasonable time. Note that the ASI generally should not require you to produce your CMEC due to the sensitive medical information contained in your CMEC.

If submitting to a practical test for a new certificate or rating, the ASI or Designated Pilot Examiner (DPE) will generally require you to produce a valid U.S. driver’s license and your medical course certificate. As your medical course certificate must be with your logbook and your logbook is generally reviewed by the ASI or DPE in conducting the practical test, this is not unreasonable. However, the ASI or DPE must not require you to produce your CMEC—again due to the sensitive medical information therein.

If being investigated by the FAA following an accident or incident in which you were involved, you should be prepared to produce your U.S. driver’s license and BasicMed medical course certification. Like in the above instances, the ASI generally should not require you to produce your CMEC.

However, if during the course of an investigation or ramp check the ASI has a reason to question the validity or existence of your CMEC, the ASI may demand its production. Given the sensitive information therein, the ASI must take steps to ensure the information in the CMEC is protected.

Any time you are piloting an aircraft, it is important to know what documents you are required to carry and what you should expect if asked to present them.

photos of AOPA employee Ian Arendt
Ian Arendt
Ian Arendt is an in-house attorney with AOPA’s Legal Services Plan. He provides initial consultations to aircraft owners and pilots facing aviation related legal issues through the LSP. Ian is a private pilot and aircraft owner. The AOPA Legal Services plan is offered as part of AOPA’s Pilot Protection Services.

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