Time Passages

Happy New Year, everyone, even though by the time you read this we are nearing the end of the first quarter of 2022. I am fascinated, puzzled, confused, and befuddled about how fast the days, weeks, and months are zipping by amid all that is happening to alter our sense of perception of time passage! But rather than lament about the “Days of Future Passed” immortalized by the 60’s rock band the Moody Blues, we seem to run to keep up with the moment we’re in now, with just an occasional fond recollection of the “good ol’ days” when the pace of life seemed a bit more sane and tranquil.

This month I’m going to shotgun a lightning round on some topics that have come up in questions to our PIC medical certification staff and update you on some recent news.

BasicMed continues to attract attention from pilots, many of whom are on FAA-granted special issuance authorizations, so I will cover those first. On the CMEC, the Comprehensive Medical Examination Checklist, item 16 in Section 2, the individual information part of the CMEC, you’re asked to provide the date of your last FAA Medical Application. That doesn’t mean the date of your last BasicMed physical exam that is required every 48 months, but the actual date of your most recent application for an FAA-issued medical certificate. If you continue to use BasicMed, the date of your last FAA medical application won’t change until/unless you go back and apply for a new FAA-issued medical someday, then decide to go back to BasicMed after that.

Recall that the CMEC Section 2 is virtually identical to the MedXpress application done online when applying for an actual FAA medical certificate. You will provide the completed Section 2 to the doctor who performs your BasicMed exam, and the doctor will then perform the examination in Section 3. Be sure to keep the exam form handy for two reasons; it’s required under the BasicMed rules, and you will need it two years down the road when you retake the online medical self-assessment course and complete a new certificate form to update the FAA on your eligibility. 

The CMEC exam date and the self-assessment course dates are independent of one another. The exam is valid for 48 months to the day, while the course is valid for 24 calendar months (to the end of the month). Because those dates are not really tied together, it’s a good idea to do both the physical exam and the course in the same month. That way you just have to remember the years each is renewed rather than the month and the year. Most users of the AOPA course will opt in to receive an email reminder in the month your renewal is coming. You can do that at the very end of the renewal process.

As far as when you want to renew, you can retake the course and/or the physical exam as often as you want. Some pilots have an annual physical and ask their physicians to sign the form each year. That’s more a “belt and suspenders” approach, but it’s fine to do that.

On the CMEC Section 3 exam form, the physician is asked to look at and check each of the 22 items listed. Item 20, “Vision,” includes parenthetical references to distant, near, and intermediate vision, field of vision, color vision, and ocular alignment. These items are not associated with a “standard” as with a regular medical certificate application. Your doctor does not need to evaluate any of those. That language is a carryover from when the FAA was tasked by the congressional legislative language to create the examination form for BasicMed. BasicMed doesn’t include any “standards” that must be met before the physician can sign your form. The Physician’s Signature and Declaration only requires that the doctor has conducted the examination and determined that there is no medical condition that “could interfere with the individual’s ability to safely operate an aircraft.”

The adequacy of vision needed to meet the BasicMed requirement is based upon any limitations on your driver’s license. If your DL requires that you wear corrective lenses while driving, or restricts you to “no night driving,” the same limitation applies to BasicMed. Remember the concept of “medical self- assessment” that’s required under FAR 61.53.

OK, enough about BasicMed. We met with the Federal Air Surgeon and her Aerospace Medicine staff in January as part of the government/advocacy/industry partnership to improve the medical certification process. The call resulted in some good updates on how the Office of Aerospace Medicine is working to improve the processing times for deferred medical applications and special issuances. The news is good – they are making progress, but it will take some time to get rudder response on the Titanic. Chronic, legacy bureaucratic policies and procedures in Washington, especially now, don’t turn on a dime.

In the interim, if your case is pending with the FAA, trying to reach the FAA customer service call center is no different than calling your bank to request a replacement debit card. At least with the bank you will hear a disgustingly boring loop of terrible music and periodic messages hinting that you should just try online banking instead of waiting for a live agent. At FAA, your message is, we’re just too busy to help you now – call back later.

The best way to reach the FAA is through the nine Regional Flight Surgeons. Although these offices are very busy with trying to keep the ATC facilities fully staffed through the lingering pandemic, emailing them with questions will probably yield a better response than trying to get through to the Aerospace Medical Certification Division (AMCD) in OKC. The Regional staffs, in our experience, are really helpful and will do their best to get you what you need to know. In most cases, the regions will respond to your email within a couple of days.

HIMS cases involving use of approved SSRIs or any psychiatric cases that are with the FAA Medical Appeals section in Washington should begin to see faster response times. The FAA has added two new psychiatrists to the staff so we are optimistic that cases requiring psychiatrist review will be handled more efficiently. Remember, though, that there is still the backlog that has been there for a long time so it will take a while to clear that out as well.

Processing of other cases at AMCD should by this summer begin to see positive changes, too. A major enhancement to their internal workflow system is in the works now so again, there is reason to be optimistic that the delays that have plagued us since before COVID will be less prevalent.

Enjoy the last few weeks of winter and stay safe!