As many of you already know, on December 4, 2024, the FAA announced two major changes to the medical certification process. Having attended many Aviation Medical Examiner (AME) conferences this past year, I was aware that some changes were planned. I wasn’t sure of the details. We had been told that we would receive plenty of advanced notice. The changes were scheduled to go into effect January 1, 2025.
The changes are supposed to solve two problems: the certification backlog and perceived problems with color vision testing. When the government makes changes, it is important to be alert. My feeling is that both changes failed to solve the problems and probably will make things worse.
The first policy change is intended to address the long delays in certification of applications requiring review by FAA personnel prior to final approval. Ninety-six percent (96%) of medical certificates are issued by the AME at the time of the exam. The remainder involve situations where the exam must be deferred to the FAA, along with required medical information for the FAA to be able to make the final decision. This information can be uploaded by the AME with the exam. If not uploaded, the FAA sends the applicant a letter requesting the information and gives the applicant 60 days to comply. In some cases, the applicant may be able to continue to fly while this is being processed. All of these applications are part of the backlog. Currently, the average time to process these cases is approximately 60 days. Congress has been complaining to the FAA about these delays. The real reason for the delays is, of course, the FAA’s cumbersome processes and the shortage of FAA staff, both physicians and ancillary personnel.
The FAA’s proposed solution is to DENY all of these applications, if the required information has not been uploaded with the exam. Problem solved. No backlog. Of course, all of these applications will still eventually need to be processed. When pilots apply for jobs or for insurance, one of the first questions they are asked is if they have ever had a medical application denied. That is a red flag. In addition, a denied pilot cannot fly using his FAA medical or under Basic Med or Light Sport. Fourteen pilot organizations sent a letter to the FAA requesting a delay in implementing this policy. Congressman Sam Graves of Missouri, Chairman of the House Committee on Transportation, has become involved. The effective date has been pushed back to March 1, 2025, for further discussions. I’m not sure how this will finally be resolved.
The second policy change involves which color vision tests are approved by the FAA for use by AMEs and who needs to be tested. What is the perceived problem the FAA is trying to solve? Keep in mind that there has only been one civil aviation accident thought to be caused by defective color vision. In that case, everyone agrees that the cause of the accident was not defective color vision, but the National Transportation Safety Board (NTSB) found otherwise. Some in the FAA believe that airmen are cheating on the color vision tests and that AMEs are passing people who they shouldn’t. This is the problem needing to be solved. As of January 1, 2025, ALL of the color tests which the FAA had approved for AMEs to use were eliminated, although they still must be used on FAA employee controller physicals. That includes all color vision test books and machines. The only approved tests would be three computer-based ones, only one of which an AME might decide to get. It is called the Waggoner CCVT. An AME can purchase a monthly subscription to it for about $40 per month or purchase it outright for $999. An AME only needs to have it available.
Who now is required to be tested? Only new applicants. Anyone who somehow passed their last FAA medical without a color vision restriction, will be considered to be color vision qualified. No further testing is ever required unless they develop certain eye or systemic diseases or start taking medications known to sometimes compromise color vision. Holders of color vision Statements of Demonstrated Ability (SODAs) or Letters of Evidence (LOEs) will be considered qualified, too. Persons who fail the test will be restricted to 3rd Class Medicals and daylight flight only. What is unclear, is whether people who fail will be able to try to obtain an LOE as is currently possible. The FAA would not answer that question. The only advantage I see so far is no longer needing to test for color vision on every medical. My feeling is that it will be easier to cheat with this new system. The FAA’s goal could be accomplished without computer testing. When the final color vision policy has been issued, I plan to write an article on color vision.
Happy flying!
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