Dr. Robert Sancetta is a former DC-10 captain with 11,000 flight hours. He has worked as a Senior AME since 1993 and is appointed as AME Consultant to the FAA Federal Air Surgeon.

AIN Contributor

Robert Sancetta

A pilot’s response to receiving a letter from the FAA’s Aerospace Medicine Certification Division (AMCD) can be wide-ranging. If the pilot had been anxiously waiting for a letter from the FAA in response to a medical application previously submitted, the initial joy of it finally arriving is also fraught with trepidation upon opening it—will it be an approval or a denial?
If an FAA letter was entirely unexpected, a pilot’s initial reaction will always be that of dread. What horrors are contained within?
The purpose of this discussion is to help pilots read between the proverbial lines. There is typically a moderate degree of confusion when reading an FAA letter. They are full of government legalese, referring to all sorts of FARs and Code of Federal Regulations (CFRs). That is confusing enough.
After that, there are often threatening-sounding bold-faced warnings and other considerations that do nothing to allay a pilot’s fears. There are many times when a pilot is unsure if they are formally grounded and whether anything needs to be done immediately to defuse the situation.
In my usual overly-optimistic AME fashion, I am pleased to report that the majority of FAA letters to pilots do not ground the pilot. I do not dismiss how stressful it can be for pilots to receive FAA letters, but usually, they present a situation that is not insurmountable.
FAA letters often simply acknowledge a previously reported medical condition, perhaps are a simple ongoing approval notification, sometimes do ask for additional data (the quintessential “nastygram”), frequently are formal special issuance authorizations (SIA), and unfortunately, on rare occasion, there is the disappointing medical denial.
To continue appearing somewhat optimistic, with proper evaluations and documentation, many denials can eventually be turned into approvals. There are some medical conditions that will be permanently disqualifying, of course, but mercifully, those occurrences are infrequent.
The letters can be confusing at times, even to an AME who has read many of them daily for many years. It is no wonder, then, that a pilot receiving an unanticipated FAA letter would, at first glance, be uncertain as to the true meaning. Once again, the first question is often, “Am I grounded or not?”
This circumstance may not be a simple “sit in the living room, call the AME (or the employer’s privately-contracted aeromedical consultant), relax, and have a cup of coffee while awaiting a response.”
An example of the time-critical stress a situation like this can cause is when a pilot is on an overseas trip, a zillion time zones away, interrupting their rest period to frantically try to get in touch with me. After the pilot had already left the country, their spouse or partner informed them of a certified letter from the FAA.
As noted above, it contained all sorts of warnings and concerning statements that made it difficult to determine if the pilot had been denied. The pilot, of course, needs to know if they are grounded or if they can continue their trip.
I am very sympathetic to this predicament and, if at all possible, try to navigate the pilot through the gist of the letter in as timely a manner as is possible. Calling in sick on an international trip is an enormous inconvenience to a corporate flight or airline operation, and therefore, it is essential that the intent of the FAA letter is fully understood before making a final decision regarding the flight status of that pilot.
FAA letters routinely contain many of the following elements: references to FARs or CFRs, statements with respect to why these potentially adversely impact the pilot, “suggestions” for how to rectify a challenging medical situation in the FAA’s administrative judgment, and what might need to be completed periodically thereafter in an ongoing manner moving forward. There are several other potential elements, but these are a few of the basics.
You will notice that I put the “suggestions” in quotes. If the FAA asks for additional testing or documentation, in point of fact, these are not suggestions. They are mandatory.
Even if a pilot’s treating physician does not feel that the testing is medically necessary, it is not optional from the FAA’s standpoint. There are times—not all that frequently, fortunately—when a pilot may have to pay out of pocket for an expensive evaluation, since the treating physician was unable to justify it to the pilot’s medical insurance provider.
Very important inclusions in FAA letters are whether a pilot’s medical certificate has or has not been denied, whether a previous SIA has been rescinded—which is, in essence, also a denial—and/or how much time the pilot is being given to provide the required additional documentation. These important considerations are not always self-evident on an initial reading of the letter.
To be fair, sometimes an FAA letter will state, “You are not denied at this time.” However, I would prefer that the FAA make the denied/not-denied interpretation a bit more obvious and understandable for pilots in all disposition letters that are not frank approvals—perhaps in the same bold font that has already scared the heck out of the pilot in the warnings section.
Pilots are not expected to be familiar with all governmental medical legalese. As I have noted, even experienced AMEs are sometimes uncertain about the fate of that pilot. FAA medical letters sometimes contain confusing errors, requiring the AME to contact the FAA for a more clearly worded amended letter.
I also wish that the FAA was clearer about whether the AME can or cannot issue the subsequent medical certificate. In the case of some authorization letters, the AME should be able to issue the next medical certificate.
Some authorizations, however, require that the pilot’s data be submitted well in advance of the next scheduled FAA examination. Whether the AME can issue or not is often left a bit nebulous, and even a savvy AME sometimes must read between the lines. And, at times, the AME has to contact the FAA for clarification. The process can be burdensome and time-consuming, but it is imperative that pilots and their AMEs get it right.
Even when a pilot is approved, FAA letters will always contain general warnings and a reference to FAR 61.53 (prohibition on operations during medical deficiency). The essence of these inclusions is that if a previously reported medical condition either recurs or worsens, the pilot should not fly until things can be sorted out.
General warnings from FAR 61.53 also note that should a pilot have any new condition or be taking a medication that might be concerning from an aeromedical standpoint, they should stand down until appropriate medical care and documentation acceptable to the FAA is obtained, reviewed by the AMCD, and authorized in, you guessed it, an FAA medical disposition letter.
The opinions expressed in this column are those of the author and are not necessarily endorsed by AIN Media Group.

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