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.

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Robert Sancetta

The medical aspects and ramifications of sleep apnea cannot be overstated. In 2018, I wrote a two-part series on this important subject. Please refer to those for a more detailed discussion of the physiologic impacts of sleep apnea, the more common treatment modalities, and why treating it is essential for the long-term health of a significant portion of the general population.
This piece today is primarily intended to give an update on the FAA medical certification protocols for sleep apnea. I am pleased to state that the process has recently been greatly simplified.
This does not imply that adequate analysis, treatment, and compliance with treatment are of lesser importance. Quite the contrary: ongoing research and statistical analyses of sleep apnea only point to an increasingly apparent need to adequately diagnose and treat it.
Note that this discussion applies primarily to the most common type of sleep apnea, which is obstructive sleep apnea. The less common central sleep apnea presents other risks that are beyond the scope of this blog.
Briefly, untreated sleep apnea can lead to fatigue; daytime drowsiness; cardiac issues, including concerning arrhythmias (irregular heartbeats such as atrial fibrillation); stroke; high blood pressure; increased risk for diabetes; psychiatric problems; cognitive decline; and an increased risk of erectile dysfunction.
Once the pilot is evaluated by the FAA, a special issuance authorization will usually be granted. This will require, after the initial evaluation phase, annual submissions to maintain FAA medical privileges.
But the process has been simplified!
Before getting into the nuts and bolts, I want to remind pilots that sleep apnea remains the only special issuance condition that permits an AME to issue a medical certificate at the time of the first report of the condition. All other special issuance conditions require the pilot to wait for FAA review and approval. Please remember that subsequent issuances for many special issuance considerations are discretionary to the AME, but that initial issuance usually requires FAA preapproval.
But we found a way to get around that requirement during the initial beta-testing of the protocols with the staff physicians at the Federal Air Surgeon’s office. If the AME is satisfied that the initial diagnostic and treatment documentation is favorable, a routine unrestricted medical certificate is issued. Then, the requisite data is sent to the FAA, which then turns around and grants the coveted special issuance authorization. Hence, the pilot does not have to endure the waiting game for the first approval.
The diagnostic evaluations and treatment requirements remain the same as they were when I first discussed sleep apnea. What, then, is the simplification that I am referring to?
In the past, the usual documentation goat rope mandated that a large volume of paperwork be submitted to the FAA. As is all too common with that process, pages get lost or mis-scanned, and sometimes a nastygram is sent to the pilot instead of the definitive authorization.
Once that frustration gets sorted out, almost all pilots reporting sleep apnea receive their authorization. Follow-up annual submissions required less documentation, but letters from the treating physician, a separate compliance form for the pilot themselves to fill out, and a full year of compliance documentation remained a bit unwieldy.
Given a favorable track record of certifying pilots with sleep apnea, a simplified data submission protocol has been approved. While all the usual diagnostic evaluations and treatment modalities remain important (whether the patient is a pilot or not), the only data that must be submitted to the FAA is, drumroll, a one-page form.
On that simple form, the physician indicates that the evaluation and treatment are favorable. A few numerical entries are required, but only for the high points of diagnostic and treatment parameters. A physician certification that the pilot is compliant is required.
Also on the form, the pilot indicates that the treatment is effective for them and that they are compliant with it. And then the physician notes that unacceptable or excessive quantities of sleep medications are not being prescribed.
Bring that one page to the AME, and they can issue an unrestricted medical certificate at the time of the exam.
It is always best to discuss the situation with your AME beforehand, however, to avoid any unexpected landmines at the time of the FAA examination.
The more common treatment modalities are acceptable. These include the continuous positive airway pressure (CPAP) system, which remains the best choice for moderate to severe sleep apnea. Oral appliances (basically fancy mouth guards) are useful for a subset of people with milder forms of sleep apnea.
There are several newer interesting modalities receiving a lot of advertising dollars, but before launching into one of those, please check with your AME to make sure that the FAA will find that particular solution acceptable.
Bottom line: If you, your spouse, or your medical providers think that you might have sleep apnea, get it evaluated; if you are diagnosed with sleep apnea, get it treated—your long-term health may depend on it. (Most people treated for sleep apnea will report improved sleep, less fatigue, and that they feel better than they have in a long time.) And inform your AME proactively.
FAA medical certification is now much more user-friendly than in the past for the diagnosis of sleep apnea.

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