Special Issuance Certification for Depression with Antidepressant Usage

Special Issuance Certification for Depression with Antidepressant Usage

Effective April 5, 2010, the FAA began considering individuals for special issuance medical certification who are being treated for depression with one of four specific antidepressant medications.  All classes of medical certification will be considered, but individuals who are granted a special-issuance medical certificate under this policy may take only one type of antidepressant medication limited to the following four medications:  Fluoxetine (Prozac), Sertraline (Zoloft), Citalopram (Celexa), or Escitalopram (Lexapro).  All these medications are SSRIs, antidepressants that help restore the balance of serotonin, a naturally occurring chemical substance found in the brain.

Increasingly accepted and prevalently used, these four antidepressants may be used safely in appropriate cases with proper oversight and have fewer side effects than previous generations of antidepressants.  While the focus of this policy statement is on individuals being treated for depression, the FAA realizes that these four medications may be used to treat conditions other than depression.  It should be noted, therefore, that, in all instances, the FAA will continue to consider applicants and make determinations on a case-by-case basis under the special-issuance process just as it always has.

In addition to treating psychiatrists, AMEs who have specialized training under a program called the Human Intervention and Motivation Study (HIMS) also will assist the FAA by making recommendations about certification cases to be considered under this new policy.  The HIMS program is a safety-critical aviation program established nearly 40 years ago.  The program, developed specifically for commercial pilots, was designed as an alcohol and drug assistance program to coordinate the identification, assessment, treatment, and medical certification of pilots in need of help.  Under HIMS, pilots who successfully meet rigorous FAA protocols may be returned to duty in accordance with 14 CFR 67.401 (Special Issuance).  The FAA will apply the basic HIMS evaluation and monitoring approach to this new policy and HIMS AMEs will participate in a specialized training program tailored to evaluating and monitoring applicants who wish to be considered under this new policy. According to AOPA's sources, the initial cost of the battery of testing required under the policy change averages between $2,000 and $3,000, depending on the geographic location of the providers. 

No regulatory changes are being made under this policy.  Further, the FAA continues to believe that applicants requiring use of multiple antidepressant medications or use of any other psychotropic medication in conjunction with any one of the four specified in this policy will not meet the criteria set forth under this policy.  The use of psychotropic medication continues to be disqualifying under the medical standards and special-issuance certification will be granted only after thorough analysis of each individual case presented and only when appropriate conditions and limitations are in place so that the applicant may safely be permitted to operate an aircraft.  It should be noted that as new information becomes available and recommendations from the medical community change it may be necessary for the FAA to again revise its policy. 

The FAA special-issuance policy will include consideration for depression treated with certain antidepressant medication under the guidance set forth as follows:

 

This protocol applies to considerations for special-issuance medical certification for airmen requesting first-, second-, and third-class special-issuance medical certificates, for the exercise of privilege under 14 CFR Parts 121,135, or 91, who are being treated with certain antidepressant medications.

Criteria to be Considered:

Diagnoses:
Mild to moderate depressive disorders, such as

  1. Major Depressive Disorder (mild to moderate) either single episode or recurrent episode
  2. Dysthymic Disorder
  3. Adjustment disorder with depressed mood

Pharmacologic Agents Considered:
(single-agent use only)

  1. Fluoxetine (Prozac);
  2. Sertraline (Zoloft);
  3. Citalopram (Celexa); or
  4. Escitalopram (Lexapro)

Specifically Unacceptable diagnoses and or symptoms:

  1. Psychosis
  2. Suicidal ideation
  3. History of electro convulsive therapy (ECT)
  4. Treatment with multiple antidepressant medications concurrently
  5. History of  multi-agent drug protocol use (prior use of other psychiatric drugs in conjunction with antidepressant medications)

Psychiatric status:  

  1. All symptoms of the psychiatric condition for which treatment is indicated must be ameliorated by the single medication and the condition must be stable with no change in or exacerbation of symptoms for 6 months prior to certification;
  2. Airman must be on a stable dosage of medication for a minimum of 6 months prior to certification; and
  3. Airman must have no aeromedically significant side effects of prescribed medication.

Required Reports and Consultations: 
(initial consideration)

  1. A consultation status report (and follow-up reports as required) from a treating psychiatrist attesting to and describing the applicant's diagnosis, length and course of treatment, dosage of the antidepressant medication taken, and presence of any side effects from the antidepressant the applicant takes or has taken in the past;

  2. A written statement prepared by the applicant describing his or her history of antidepressant usage and mental health status;

  3. A report of the results of neurocognitive psychological tests with provision of the raw test data: including, but not limited to:  COGSCREEN AE, Trails A/B; Stroop Test; CCPT, PASSAT, Wisconsin Card Sorting Test;

  4. An evaluation and a written report from a HIMS-trained AME who has reviewed items 1., 2., and 3. above and who makes a recommendation for a special-issuance medical certificate; and

  5. Any additional information the Federal Air Surgeon may require to make a determination.