With the remnants of the Covid pandemic (yeah, it is still affecting our lives!) and the number of retiring 121 air carrier pilots in the last few years, the demand for pilots is and will be high for quite a while yet. One good measure of that demand is evident in a place some might not think about top of mind—the number of applications for medical certificates processed by the FAA Aerospace Medical Certification Division (AMCD) in Oklahoma City. Prior to last year, 2022, the FAA received about 385,000 applications. Last year, that number was 418,000, and this year, it is projected to be more than 430,000. The bad news is the FAA isn’t staffed to handle that many applications, and the processing times reflect that reality, as most pilots who need a special issuance waiver will readily and unhappily attest.
It gets more interesting, if that’s the term to use, because many of those applicants who aspire to fly professionally also have medical conditions that need to be deferred to the FAA, a process that often requires additional information over and above what’s provided to the aviation medical examiner (AME) at the time of the physical exam. As we have mentioned before, the FAA has the most advanced policies and procedures to consider medical conditions that are not afforded to other international civil aviation regulatory bodies. The key tool is in the FARs, the Federal Aviation Regulations, Part 67.401, the discretionary language that allows the FAA to consider just about any medical condition (almost!) for a Special Issuance Authorization. These are discretionary and are time-limited medical certificates that require periodic reevaluation, usually annually, to extend the authorization for additional time.
We can maybe again attribute the pandemic to the number of people who are now being treated for mental health conditions, especially post-traumatic stress disorder (PTSD), depression, anxiety, and ADHD (attention deficit hyperactivity disorder). ADHD is not specifically considered a mental health condition but a “learning disorder.” Regardless of how it is identified, the number of younger people who have been diagnosed with, treated for, or were in the past treated with medications for ADHD just keeps on increasing. We see the increase in our member calls to the medical certification specialists in our Pilot Information Center.
The FAA has taken steps to address the challenge that should help quite a bit downstream. In my 30-plus years of working with the FAA, there was always only one chief psychiatrist at Headquarters in Washington plus a few psychiatric consultants to handle the more challenging cases. Now there are four full-time psychiatrists on staff to address this formidable increase in psychiatric cases. I’m told also that two additional contract psychiatrists will be added to the staff. The workload just for the psych cases is significant, and they’re not simple slam-dunk cases, either, but involve complex medical histories that often include multiple mental health diagnoses, but may also include other types of co-conditions like diabetes, heart disease, and cancer along with the psychiatric diagnoses that further complicate the review process. Also included among those cases are those requiring participation in the HIMS program for depression treated with medications and for substance misuse, abuse, and dependence.
PTSD cases are now reviewed based on a policy change that somewhat streamlines the review process. Although PTSD has long been associated with military- and combat-related symptoms, that is far from the case. PTSD can occur as a response to any type of trauma whether physical, emotional, or mental such as sexual assault, a motor vehicle accident, surviving or witnessing a natural disaster such as the massive and terrible fires that devastated the town of Lahaina on the island of Maui in August, floods, tornadoes, and other natural disasters that seem to be more prevalent with our changing climate, or bridge collapses like the one on I-35 in Minneapolis in August 2007. PTSD is a spectrum disorder that affects people differently and the FAA recognizes that with the policy that now allows for an AME-issuance in the office. The disposition table details the circumstances under which the AME, with proper documentation, can issue a medical at the time of examination. As is always the case, complete, thorough medical records are the key to making this work. We have touched on that before: Do your homework and gather good medical records to present to the AME at the time of the physical exam.
There is more change coming with respect to ADHD, and the FAA is drafting a “disposition table” that will allow applicants with a favorable history of ADHD to also be office issued. That may take a while yet, but this also will be a welcome change in policy.
We all wish that there was less bureaucracy in our government. That probably isn’t likely to change anytime soon—it’s just too lucrative for those in power—but the FAA is trying to make the process of medical certification a little less onerous. For now, though, it still takes patience and diligence to navigate the system. The good news is that after all the frustration and effort, the likelihood is high that you will get that special issuance!
Stay safe and sane!
