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Medical certification and mental health

How the FAA can work to improve the process

It’s an open secret that pilots underreport mental health issues and often refuse to seek treatment.

Research supports this: A 2016 study concluded that hundreds of airline pilots could be managing depression symptoms perhaps without treatment for fear of impact to their career. A 2019 study, although not specifically addressing mental health, found that more than 60 percent of respondents admitted to delaying or avoiding medical care because of concerns for their pilot certificate.

A recent Department of Transportation report stated that the FAA has “comprehensive procedures to evaluate pilots’ psychological health.” Few would dispute that the FAA has an extremely thorough review process when it learns of potential mental health conditions. The report also found that pilots are reluctant to disclose mental health conditions, primarily because of “the stigma associated with mental health, potential impact on their careers, and fear of financial hardship.” Understandably so. Pilots who report mental health conditions or treatment are often required to obtain onerous and costly evaluations from the few FAA-approved psychiatrists and neuropsychologists. After obtaining these evaluations, the FAA may take many months to review.

All the while pilots are unable to exercise any medical certificate privileges, which usually means they cannot work or build flight time. Even after receiving a medical certificate, continued evaluation and reporting requirements are the norm. It provides little solace that pilots rarely receive a final denial with no hope of future medical certification when they are out of work (about 0.1 percent of applications are truly and finally denied).

While the FAA has made strides in its messaging and changes for certain mental health conditions (including situational depression, ADHD, and PTSD), the agency must do more if it hopes to dispel the fear pilots face when experiencing a mental health challenge. Substantive revisions to the FAA medical certification policies and procedures are required before any meaningful progress in combating mental health issues can be achieved. What can the FAA do to encourage pilots to seriously consider their mental health and to accurately report mental health conditions and treatment?

For one thing, the FAA could grant AMEs the discretion to issue temporary medical certificates when pilots report mental health conditions or treatment. Latest reports indicate the FAA has a nine-month backlog for internal review of any psychiatric case. Temporary medical certificates would allow pilots to continue working or building flight time while the FAA reviews the file.

For another, the FAA could amend its reporting requirements so that mental health evaluations, counseling, or use of an employee assistance program (EAP) are reportable only when resulting in a clinical diagnosis or treatment. As it stands now, all visits to a psychiatrist or psychologist within the past three years must be reported on the medical application even if the visit did not result in any formal diagnosis. Any counseling “related to a…psychiatric condition” must similarly be reported. On the other hand, use of an EAP is reportable only when “result[ing] in referral for psychiatric evaluation or treatment,” although FAA guidance on this point is inconsistent. This change would provide clarity and give pilots more tools to address their mental wellness. Pilots may be more likely to seek informal counseling (peer-to-peer, life coaching, and so on) and take advantage of EAPs to stop a mental condition from developing into an illness. Further, pilots concerned for their mental wellbeing would be more willing to seek help if only required to report visits resulting in clinical diagnosis or treatment.

The FAA could improve its communications with pilots by explaining, in layman’s terms, the reasons for its decisions. Currently, when the FAA denies a medical certificate or requests additional information, the FAA uses form letters which, at best, reference the underlying conditions at issue but fail to provide substantive explanation as to why the condition makes pilots unsafe to fly or why additional information is needed. Instead, pilots must request their medical certification file with “applicant notes” (which can take weeks) or track down an FAA employee to clarify the information. Providing clear reasoning in corresponding with pilots would do much to dispel the distrust many harbor against the FAA. Additionally, the FAA could assign individual case workers to a file, so pilots have a single point of contact.

Pilots concerned for their mental wellness should seek the care they need. Often, peer-to-peer or EAP resources may not require reporting and can prevent a situation from getting worse. Nevertheless, until the FAA makes meaningful changes to the medical certification process, pilots may hesitate to receive help and may hide a condition.

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photos of AOPA employee Ian Arendt

Ian Arendt

Ian Arendt is an in-house attorney with AOPA’s Legal Services Plan. He provides initial consultations to aircraft owners and pilots facing aviation related legal issues through the LSP. Ian is a private pilot and aircraft owner. The AOPA Legal Services plan is offered as part of AOPA’s Pilot Protection Services.

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