Just by chance on May 25, Federal Air Surgeon Dr. Susan Northrup made one very small step to relax the criteria for minor depression. I would love to say it was in response to my column, but the FAA has never worked that fast, so this had to be in the works for several months.
The new policy states that if a pilot has had a single episode of depression in response to an event or stressor “that would cause the average person to become depressed,” it fully resolved within six months, and occurred more than five years ago, the AME can issue a medical certificate without further evaluation.
If the episode of depression occurred less than five years prior, the AME must also obtain clinical records that include a current detailed progress note to verify the diagnosis. The AME can issue the medical certificate, but the records must be forwarded to the FAA for “retention in the pilot’s file.” If treatment or symptoms in either case lasted more than six months, occurred more than one time, or did not have a specific triggering event or stressor, the pilot will need a special issuance and all the accoutrements of that exhaustive evaluation.
In my June column, I referred pilots to a survey, which I admit was small and non-scientific. However, the responses were so significant, they cannot be ignored. The first question was, “Have you ever used an antidepressant medication while flying that was not reported to the FAA?” Forty-nine percent said yes. That is a striking number that reflects a lot of pilots who are flying without informing the FAA about anti-depressant medication.
Question two was, “Have you suffered from depression or other mental health issues and not gotten help or medications due to the effect on your FAA pilot medical?” Sixty-three percent said yes! Even Northrup in her federal air surgeon bulletin acknowledged that pilots should not avoid care, highlighted by two suicides in young aviation students in 2021. I heartily agree with Dr. Northrup that pilots should seek care, whether it is mental health or physical health concerns that arise. One’s life is more important than our medical certificate.
The last question is a more poignant criticism of the FAA’s medical department. Question three was, “Do you think the FAA handles pilot mental health issues appropriately?”
Ninety-six percent of respondents said no.
This may be a hard pill to swallow, but the FAA’s psychiatric and psychological evaluation process is antiquated. Some of the process stems from a previous FAA chief psychiatrist who was, in my opinion, also just horrible. His legacy of antiquated evaluation has been a difficult sea to move. In addition, the Medical Department has a love affair with the CogScreen, a proprietary computer screening program that the FAA uses as a yes/no test regardless of other evaluations. The CogScreen may have utilization with alcoholic, drug abusing, and traumatic brain-injured pilots, but it has little to no value in depression. In fact, although there are CogScreen standards comparing possibly impaired pilots to non-impaired pilots, there is no evidence that it has prevented even one accident in the real world.
The bottom line is that the survey, even if only partially valid, shows there are many pilots flying on anti-depressants and many who should be on anti-depressants. That fact, plus the dearth of accidents that are attributable to mental issues, which I admit is hard to delineate, should give the FAA pause and re-evaluate its current processes and procedures for evaluating pilots with mental health issues.
The FAA’s reliance on a checklist of tests to be completed, FAA-approved psychologist and psychiatrist to be seen (which are few and far between and expensive), and then if a special issuance is granted, to make those hoops to jump through an annual event, certainly drives pilots to not report mental health problems.
Dr. Northrup is working hard to modernize the FAA medical processes, but it is like moving a bureaucratic iceberg. I hope she prevails.
As the new minor depression policy does, one easy solution would be to let AMEs participate more in the evaluation and medical issuance in pilots who have experienced mental issues. The CACI program (Conditions AMEs Can Issue) has certainly been successful streamlining the process for pilots’ physical issues without any change in medically related accidents. I think it would work for mental health issues as well.