Does The FAA Trust Its AMEs?

by Dr. Bill Blank
Aviation Medical Examiner (AME)

There are a number of selected medical conditions that are initially disqualifying for a pilot medical if the applicant does not meet the issue criteria, and must be deferred to the Aerospace Medical Certification Division (AMCD), located at the Civil Aerospace Medical Institute in Oklahoma City, Oklahoma, or to the Regional Flight Surgeon (RFS) for which the applicant resides (i.e. Great Lakes and Central Regions in the Midwest). If this is a first-time application for an Aviation Medical Examiner (AME) Assisted Special Issuance (AASI) for the applicable disease/condition, the examiner must defer and submit all of the requisite medical information necessary for a determination to the AMCD or RFS for the initial determination.

Following the granting of an Authorization for Special Issuance of a Medical Certificate (Authorization) by the AMCD or RFS, a local examiner (AME) may reissue a medical certificate to an applicant with a medical history of an initially disqualifying condition once the AASI’s specialized criteria is met and the applicant is otherwise qualified. An examiner’s decision or determination is subject to review by the FAA, however.

While this all sounds like a reasonable process, the system is bogged down with an overload of applications, and too few physicians in Oklahoma City, resulting in delays for first-time applicants for a special issuance. While an applicant may put up with this delay the first-time around, additional delays and required testing and retesting is usually enough to discourage the applicant from ever applying again, and he may quit flying, which is a disappointment for the applicant and a loss to aviation at a time of diminishing pilot numbers.

I estimate that when an FAA physician at the regional or national offices looks at the records on the computer of an airman requesting a special issuance, he might need about 20 minutes for a simple, straight-forward case when all of the records are there. The first problem is that the records may have been in the FAA’s possession for 6-8 weeks before the physician even sees them. If the decision is favorable, there may be a delay in getting the response typed and back to the airman.

In the FAA’s defense, almost 35,000 special issuances were issued in 2013. About 2/3 were for First and Second Class Medicals, which receive priority over Third Class Medicals. Only ten (10) FAA physicians based in Oklahoma City work on special issuances. Another problem is that as many as 60% of the requests arrive without all of the needed information, causing an additional delay. If the FAA receives all of the information requested, about 99% of the requested special issuances are eventually issued.

The FAA is certainly aware of the problem with delays and attempts are being made to speed up the process. In fact, the Aeromedical Division of the FAA monitors its delays every two weeks. So what is being done to speed up the process?

First, FAA physicians previously would never discuss an airman’s medical application with him, but that has changed. In many cases today, a review officer will call an airman to ask him to fax additional information. This is a big time saver.

Second and probably more helpful, the FAA has been increasing the authority of local AMEs to initially issue medicals, including some, which previously required special issuance through Oklahoma City. This is being accomplished by the Conditions AMEs Can Issue (CACI) program.

Guidelines have been established and published in worksheets. These worksheets are available online. The airman’s physician can complete the form and the airman can take it to his local AME. If the answers are satisfactory, the AME can issue a regular certificate then and there.

Currently, about 90% of airmen receive their certificates when they leave the office. Dr. James Fraser, the new Federal Air Surgeon, is hoping to reduce the 10% remaining to 5% via the CACI program. His plan is to greatly increase the number of conditions on the CACI list.

Currently there are 10 conditions, which can be issued via CACI and two others, “prostate” and “testicular cancer,” which are not on the list, but which a knowledgeable AME can now initially issue. If you would like to learn more about this, you can find the most recent Federal Air Surgeon’s Bulletin, Vol. 52, #2 online and read Dr. Fraser’s article.

There are other possible solutions to the problem of delays. How about out-sourcing the backlog to specially trained AMEs? After all, the FAA physicians go to the same medical schools the rest of us do. If they can be trained, so could we.

Several years ago the FAA thought about training what were then going to be called “Super AMEs” to accomplish this. Unfortunately, the FAA’s legal department decided this would be illegal!

An additional FAA concern is, of course, erroneously issued medicals. The FAA has 60 days to revoke such a medical. If they fail to do so within that time limit, legal action is required with the medical being in effect until the legal process is complete.

I have no idea how the need for “Third Class Medicals” will be resolved, but since almost 13,000 special issuances are issued for Third Class Medicals each year, decreasing this number would obviously help with delays and reduce costs for both airmen and the FAA.

However, part of the FAA’s motivation to reduce delays, I think, is to avoid the delays from being used as a justification for eliminating Third Class Medicals.

I will comment here on the issue of certain pilots being able to fly without Third Class Medicals.

I suspect that the FAA does not like the “Sport Pilot” exemption and would rescind it if they could. Their problem is that while they know the number of Sport Pilots having accidents, they don’t know how many Sport Pilots are flying. Since they don’t have a denominator, they can’t calculate an accident rate to support their position.

I will now look into my crystal ball and speculate a little. The FAA got burned on the proposed changes to regulations affecting “Sleep Apnea.” The agency was accused of being precipitous and not following procedures. That certainly won’t happen with the Third Class Medical. They will wait and see what Congress does. If Congress doesn’t act, neither will the FAA.

To return to the original question: Does the FAA trust its AMEs? I think the answer is yes, they do. By developing the CACI program, they are demonstrating this trust. But as you know, the government moves slowly, frequently too slowly, but at least progress is being made.

Certainly, my article here didn’t solve the problem, but I hope it made you more aware of what is going on. By understanding the process a little better, you should be better prepared if you ever need a special issuance medical or a CACI.

Happy Flying!

This entry was posted in August/September 2014, Columns, High On Health and tagged , , , , . Bookmark the permalink.

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