Special Issuances… Why organization, completeness and timeliness is so important.

by Dr. Bill Blank
Aviation Medical Examiner
Published in Midwest Flyer – April/May 2017

In the past several issues of Midwest Flyer Magazine, I have been talking about the FAA certification process. I have discussed Regular Issuances (RI) and CACIs (Conditions AMEs Can Issue). Now I want to talk about Special Issuances (SI). It may surprise you to learn that SIs have been around since 1926! It sure did me.

The FAA lists 15 conditions, which it calls specifically disqualifying. They are: Angina Pectoris; Bi Polar Disease; Cardiac Valve Replacement; Coronary Heart Disease; Diabetes Mellitus requiring medications; Disturbance of Consciousness; Epilepsy; Heart Replacement; Myocardial Infarction; Permanent Cardiac Pacemaker; Personality Disorder; Psychosis; Substance Abuse; Substance Dependence; and Transient Loss of Control of Nervous System Functions.

What does this mean? Whether you are an airman applying for first-time certification or hold a medical certificate, when you become aware that you have one of these conditions, you do not meet the standards. If you hold a medical certificate, it is automatically invalid. You must convince the FAA that you can fly safely and not put the public at risk in spite of the condition. This is done through the SI process.

The FAA has developed a list of information for each of these conditions, which they need to provide certification. If the FAA is satisfied with the information provided, they will send you a letter of authorization and a medical certificate. The medical certificate will be time limited. The letter of authorization will tell you that your certificate is “Not valid for any class after a certain date.” It will also say that the authorization will expire in 5 years.

Why the limitation “Not valid for any class after a certain date?” All unlimited medical certificates are valid for at least two years as a third class. When the FAA grants an SI, it usually requires annual follow-up reports. Provided that they are satisfactory, the SI is continued for another year.

The original SI is issued either by a physician in Oklahoma City or a regional flight surgeon. Subsequent re-issuances can sometimes be done by your Aviation Medical Examiner (AME). That will by spelled out in the letter. If the AME is permitted to do so, it is called an AME Assisted Special Issuance (AASI.) You have the option of submitting the follow-up information to the FAA or your AME. If he is satisfied that the information meets the requirements in the SI letter, he can issue the medical and forward the reports to Oklahoma City. All AASIs are reviewed by the FAA staff.

If you hold a Third Class Medical Certificate, the AME only needs to perform an exam at the required interval, usually two years. When he issues the AASI without performing an exam, it will be dated the date the original exam was performed, but the “not valid for any class after” date will be extended for a year. Holders of Second and First Class Medical Certificates would normally have an exam performed when the AASI is issued. It is free if the FAA evaluates your follow-up information. Your AME may charge to do it.

I don’t know any AMEs who charge much for this service. In general, you are better off taking it to your AME. He can issue it the day that he sees you. If you are late in getting the information to the FAA, or they are backlogged, you could be without your certificate for awhile.

It is important that you read carefully the authorization letter. It tells you exactly what the FAA will want. Your doctor must provide you EVERYTHING they ask for. I suggest that you underline the required information, make a list of it, and give it to your physician, then verify that you have received everything you need. Better yet, have your AME review it before it is submitted to the FAA. If you do not have everything required, don’t be afraid to ask for it, because you will need it. If you fail to do so, the FAA will request the information not provided and the process will be delayed. Your medical will be dated the day you saw your AME, so if there is a delay, you may lose a couple of months. Be sure to take your SI letter to your AME every time. He is not supposed to issue your certificate if you do not have it.

Let’s talk in general about the reports needed for the initial SI. You can find this information on the FAA and Aircraft Owners & Pilots Association (AOPA) websites. In general, the FAA wants to know what happened, when, what was done about it, and how you are doing. If you were hospitalized, this means you’ll need your admission history and physical exam, operative and pathology reports, and the discharge summary. In many cases, there is a waiting period before consideration, and follow-up testing is required.

A recent letter from your treating physician is important. It should summarize the complete history of the problem, how you are being treated, medications taken, lack of side effects, your compliance with instructions, and steps you are taking to improve your health. This letter can make or break the request. A while back a physician wrote: “Joe is a nice guy and in good health.” I had told the airman to let me look at the letter before he sent it in, but he didn’t think that it was necessary. It took two months to get that untangled with a new letter.

How long does an initial SI take? The FAA will tell you about two months. If your AME really knows what he is doing, sometimes by having all of the information needed and making a phone call, you can have your medical in 2-3 weeks.

Unfortunately, as we age, it becomes increasingly likely that we will need a CACI or an SI. The good news is that the FAA is certifying conditions that previously they would never have considered. Hopefully most of us will never need an SI. If so, I hope that this information will be of help.

As you know, on May 1, 2017, medical certification via the Alternate Pilot Physical Exam and Education Requirement (APPEER) will be available. I have not officially seen the final version of the physician’s form, but will review it in time for my next column.

EDITOR’S NOTE: William A. Blank is a physician in La Crosse, Wisconsin, and has been an Aviation Medical Examiner (AME) since 1978, and a Senior AME since 1985. Blank is a retired Ophthalmologist, but still gives some of the ophthalmology lectures at AME renewal seminars. Flying-wise, Blank holds an Airline Transport Pilot Certificate and has 5300 hours. He is a Certified Instrument Flight Instructor (CFII), and has given over 1200 hours of aerobatic instruction. In addition, Blank was an airshow performer through the 2014 season, and held a Statement of Aerobatic Competency (SAC) since 1987.

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