Be Sure You Have All of Your Ducks In Order

by Dr. Bill Blank, M.D.
Published in Midwest Flyer – February/March 2019 issue

Over the past several months, I have become aware of several certification issues which prompted this article. Pilots can now meet the medical certification requirements with a valid U.S. driver’s license, basic medical exam, or regular FAA Medical. The type and size of aircraft you can fly is determined by the category of medical certification that you hold. In all cases, you are not permitted to fly if you know or have reason to know of any medical condition that would make you unable to operate an aircraft in a safe manner. 

Before you ever apply or reapply for a FAA Medical Certificate, you should understand the likelihood of certification with any medical condition you may have. You may be able to safely fly a light sport aircraft as a sport pilot, but not be certifiable for an FAA Medical. Therefore, it is important that you not ignorantly apply to see what would happen, get turned down, and then discover that you cannot fly as a sport pilot. 

When you complete FAA Form 8500-8 online, question 18 in all of its subparts, asks you if you “have ever been diagnosed with.” That means if you had an appendectomy at age 7, you must keep reporting it on every exam, even if you are now 70. You might ask why. It is because the FAA legal bureaucracy has decided to prevent an Aviation Medical Examiner (AME) from looking up information you put on any previous exams he did not do. He will be able to see what you checked yes to, but not the details. Go figure. With modern electronic medical records, any doctor in a large health system could look up your records which are in his system. 

When you check yes to any subpart of question 18, you must comment on it. Your AME must also do so. This is where I suggest being careful. If you have a condition that you are unsure of, do some research. Check with AOPA or ask your AME. Find out what information you need to provide. Get it ahead of time. It can be gathered up to 60 days prior to the flight physical. Read it. Make sure it provides all information needed and there are no deal stoppers. If so, stop right there and do not proceed until any issues have been addressed so that you can be certified. When your AME submits your exam, he should indicate that supporting information is being submitted.

This brings up the confirmation number. Doctors generally look up patient’s old records prior to seeing them. I have become aware that some AMEs or their staffs are requiring your confirmation number ahead of time. The problem here is that when the confirmation number is entered into the FAA computer system by the AME or his staff, the exam is considered to have started. You may not get in for a few days. In any case the exam must be competed within 14 days after the confirmation number was entered and submitted to the FAA. If not, it must be deferred. A better option is to print the completed form and email it or bring it to your AME. That way he can still look at it ahead of time. Unfortunately, many AMEs or their staffs are not always aware of the implications of what they do. If your AME insists on entering your confirmation ahead of time, you may want to find another AME. This is especially true if you need clarification ahead of time before deciding to proceed.

As you know the FAA works slowly. I am hoping to help you get certified more quickly. Therefore, if you have a condition where deferral will be necessary and more information required, submit the information the day the exam is done. Otherwise, the FAA will need to request more information, you will need to gather and submit it, and the FAA will need to evaluate it. This could easily add three (3) months to the process. I am aware of a recent situation in which eight (8) or nine (9) months could have been saved by doing it my way. 

ADHD (Attention Deficit Hyperactivity Disorder), formerly ADD (Attention Deficit Disorder) is becoming an issue. People who have this condition cannot be certified. Symptoms of the condition include limited attention, hyperactivity, and impulsivity. Normal people demonstrate these traits too.  There is a spectrum from normal to abnormal. It is treated with medications such as Ritalin, which is itself disqualifying. 

The problem is that in the past ADHD was frequently and incorrectly over diagnosed. Not paying attention in school, or getting poor grades, frequently resulted in a diagnosis of ADHD with Ritalin being prescribed. Some demanding parents even requested that their children who were making good grades, but not straight As, be put on Ritalin to improve their performance. The diagnostic criteria have now been better defined. The symptoms must have lasted more than 6 months and occurred in more than one setting. The symptoms must have been present after the age of 12.

From the FAA point of view, if you have ever been diagnosed with ADHD, you must be off medications for 90 days, and have passed psychological testing. A new ADHD/ADD evaluation protocol was issued November 28, 2018. Since many people have had this erroneous diagnosis, I would not report it unless I was sure that I had it. If you took medication for two (2) years 20 years ago and saw no improvement, you probably did not have it. FAA Form 8500-8 doesn’t ask if you had ADHD. If you need to report it, use question 18l regarding neurologic disorders, etc. 

Prior to seeking FAA medical certification, be sure you have your ducks in order. What I hoped to do with this article is tell you how to get ahead of the certification process before you ever see your AME. That will, I think, speed up the process. 

Happy flying!

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.

Dr. Blank is a retired Ophthalmologist, but still gives some of the ophthalmology lectures at AME renewal seminars. Flying-wise, Dr. Blank holds an Airline Transport Pilot Certificate and has 5600 hours. He is a Certified Instrument Flight Instructor (CFII) and has given over 1200 hours of aerobatic instruction. In addition, Dr. Blank was an airshow performer through the 2014 season and held a Statement of Aerobatic Competency (SAC) since 1987.

DISCLAIMER: The informatin contained in this column is the expressed opinion of the author only, and readers are advised to seek the advice of others and refer to the Federal Aviation Regulations and FAA Aeronautical Information Manual for additional information and clarification.

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