The Government Accountability Office (GAO) praised the way the FAA monitors Aviation Medical Examiners (AMEs) and proposed expanding that system to monitor its other designee programs.
But how would the FAA pay for it? The GAO suggested that the agency charge designees application and renewal fees. And that's where AOPA draws the line.
"Ultimately, pilots would incur the cost of these recommended fees. Pilot examiners and inspectors would increase their prices to account for the added cost," said Andy Cebula, AOPA senior vice president of Government and Technical Affairs. "Pilots already pay for their portion of these aviation services through fuel tax. And Congress just passed spending legislation that once again prohibits new user fees, legislation that AOPA lobbied for."
Overall, the GAO report released last week praised the FAA's use of designees for pilot and aircraft certification. Some 90 percent of certification activities are performed by these private individuals, allowing the FAA to concentrate scarce resources on the most safety-critical functions.
But the GAO faulted the agency for its oversight of designees, with the exception of medical examiners. While the watchdog agency didn't find any systemic safety failings with the designee system, it wants the FAA to improve its management control.
As the model, the GAO cited the FAA Office of Aerospace Medicine's database, which is used to monitor the performance of AMEs and to supply FAA flight surgeons with data that include the number of medical certificates issued by each AME, the number of errors in each certificate, and the amount of time it takes to transmit medical information.
However, it could cost up to $50 million to extend this model to the FAA's flight standards and aircraft certification services. So to prevent cutting funds to other FAA programs, such as safety programs, the agency would need to come up with the money some other way.
The GAO suggested charging an application and renewal fee to designated pilot examiners, designated engineering representatives, and other designees who perform certification services on behalf of the FAA. That would help recover the cost of processing those applications. But those fees undoubtedly would be passed on to consumers.
AOPA believes there are other ways to improve the current monitoring system and expand it to additional FAA services without forcing pilots to bear the brunt of the cost.
For example, even the program for monitoring AMEs could be fine-tuned by utilizing AOPA's TurboMedical application — an online interactive medical application that identifies potential problems based on the answers selected. (Now pilots can complete AOPA's TurboMedical online, but they must transfer the information onto the FAA Form 8500-8 in the AME's office.)
If the FAA switched from its current paper form to the electronic TurboMedical application, it could minimize the amount of paperwork, reduce the number of errors and deferrals, and speed the application processing time. This not only could free some of the FAA's resources to be used toward the implementation of the monitoring program in other areas, but it also could decrease the amount of time it takes pilots to receive their medical if it is deferred.
The GAO reasoned that the FAA could impose application and renewal charges on commercial designees because the Federal Drug Administration charges pharmaceutical companies an application fee to cover the cost of reviewing new drugs, and the U.S. Customs and Border Protection agency charges a fee to brokers who help move merchandise through Customs.
Commercial designees charge the public a fee, but they do not send a portion of that to the FAA. FAA inspectors and engineers provide the same services to the public for free as part of their government employment.
The 2005 FAA appropriations bill prevents the FAA from charging any new user fees, so if the FAA were to charge fees to designees, it would need a change in the law — a move that AOPA would fight.
November 22, 2004