Coalition Asks FAA to Stay New Medical Certification Policy that Favors Denial Over Deferral

The new policy would shift the practice of deferring medical certificate applications deemed incomplete to denying those applications pending reconsideration.

"The FAA’s use of denials, in lieu of the currently used deferral, as a routine part of the medical application process will significantly increase unneeded confusion for applicants and introduce unintended consequences for those under initial denial," the groups wrote. "These initial denials will also be reportable on future medical applications and other applications the industry uses, such as employment applications, which ask whether a pilot has had a previous medical denial. The ramifications of an increase in airmen receiving and reporting medical denials on these applications and the need to educate hiring managers about this change are significant and will take considerable time."

Applicants denied a medical certificate are unable to serve as a pilot or controller during the reconsideration process, and ineligible to fly as a sport pilot with a driver's license or under BasicMed. BasicMed has significantly reduced the volume of medical certificate applications that would otherwise have been filed.

"We support your office’s desire to promote the submission of complete information at the time of initial medical application," the coalition of pilot advocacy groups and unions wrote in the December 13 letter. "In addition to reducing application time, it dramatically reduces the administrative burden on your staff and allows them to focus on evaluating submitted data."

AOPA medical certification specialists routinely advise members with complicated medical situations. Pilots can also consult their AME, in advance of an exam, for advice on what documentation the FAA may require in their particular circumstances.

The signatories noted that modernization of the medical certification system, including implementation of Aeromedical Working Group recommendations required by Congress in the 2024 FAA Reauthorization stand to address the concerns that drove the policy change.

"…these changes and your authorization to bring on more AMEs, staff physicians, and medical certification specialists will go a long way to helping the FAA and the pilots the agency serves. We are very willing to help bring these improvements to reality."