AINsight: Waiting for an FAA Letter?

 - April 14, 2023, 9:05 AM

Pilots awaiting FAA letters regarding medical condition reviews need to have some significant patience these days. This is not always an easy task, as in many such cases the FAA letter must be received before an AME can issue that pilot a new medical certificate. I have spent more than 30 years as an AME hoping this waiting game situation would improve, and sadly I am still knocking my head against the wall in frustration.

Before I get into some of the nitty-gritty of why there are seemingly undue delays in receiving FAA letters, I do want to give credit where credit is due. When an AME can get in contact with the FAA to discuss the urgency of a pilot receiving a review and subsequent authorization letter, they are “all ears” to help out. FAA staff members and physicians are actually eager to help out when they can.

In fact, they enjoy nothing more than assisting in getting a pilot approved, whenever it is aeromedically safe to do so. I sense genuine satisfaction when the FAA is able to help out on a case that has some compelling urgency to it.

As wonderful as this is, however, getting help with a specific urgent individual case is not by any means a fix for the ongoing systemic problem at the FAA with extensive delays in reviews and the issuance of disposition letters.

As I have also explained in prior blogs, AMEs can not make the aeromedical staff members their personal assistants to help expedite all of their cases. Remember, for each case we “expedite” (this term being used quite loosely in FAA-speak these days) that means that some other pilot, one who is equally anxious to receive their authorization letter or medical certificate, waits that much longer. Therefore, AMEs must pick and choose which cases are compelling enough to beg for some timely assistance from the FAA.

There are also certain types of medical cases that can never be expedited. A typical example would be the case of a pilot who had coronary artery disease diagnosed and treated, such as with stent placement or bypass surgery.

For first- and second-class applicants, the initial review of this type of case must go through the “Federal Air Surgeon Cardiology Consultation Panel,” which meets only about every other month for a day or so. Regardless of when submitted to the FAA, applicable cases will wait until the next panel review, and there are no good options to bypass that wait.

Further, the panel can only get through a limited number of cases in just a few days. There have been circumstances, therefore, when a pilot must wait an additional two months for review, as the panel never got to their case in the prior panel meeting.

These situations are infrequent, but they do happen. Obviously, they are disappointing, but unfortunately, they are occasionally unavoidable.

The pilot can at least take some solace in the fact that subsequent reviews (typically annually) do not require waiting for a cardiology panel meeting and can be approved by one of several FAA staff physicians. In fact, the recertification of a subset of reasonably straightforward cardiology cases can now often be done “on the spot” by the AME. Thus, no waiting period is involved, as long as the follow-up medical data meets the parameters prescribed in that pilot’s authorization letter.

A significant aspect of what continues to slow down the review process is the archaic logistical process of getting medical documentation to where it can actually be reviewed by a staff physician.

To this day, for the majority of FAA case reviews, we are still bound by the process of sending paper copies of medical data to the Aerospace Medical Certification Division (AMCD) in Oklahoma City. The submission packet can range from just a few pieces of paper to sometimes many hundreds—and, on occasion, even more than that.

Delivery time and logistics are the first hurdle. Once arriving at the AMCD, the data must get logged into the system at the mail room, which is also a tedious human-reliant process.

Once logged in, the documents then go to the scanning room. Eventually, the documents are scanned, with the process sometimes taking extensive amounts of time to do so.

Then, once scanned into the system, the records packet is released to a non-physician—but often highly qualified and experienced—“legal instruments examiner” (analyst) to make an initial assessment as to whether all of the required documentation for that particular case is indeed included. Once the analyst is satisfied, the case then gets entered into the physician’s queue for final review.

It is not uncommon for staff members and FAA physicians to tell me that they have many hundreds of cases awaiting review in their individual queues.

As you can imagine, simply getting the documentation to where someone can actually begin the review process is a very time-consuming process. It often takes days to even weeks for the hard-paper copies to get scanned into the system before any analysis begins.

And, to be honest, the remainder of the review process can take quite some time, too. Once approved, it can then take several additional weeks for a new authorization letter to be signed and mailed to the pilot.

When the FAA, perhaps through a prior authorization letter that required the new documentation, states to send in the data 30 to 60 days prior to the expiration of the medical certificate, you can easily imagine that the medical certificate might likely expire before a new authorization letter is received. That the FAA doesn’t state a more realistic and longer advance submission period for new medical data is something that I have argued, obviously to no avail whatsoever, for most of my years as an AME.

A simple hint here is that the FAA doesn’t mind if the data is received a tad early. While they often also state that the current status report and testing can be done “no earlier than 90 days prior” to the upcoming medical exam, I recommend to the pilot that they try to arrange the required testing and evaluations almost to that date, and then we strive to submit the data to the FAA almost immediately thereafter. The pilot’s treating physician also must agree to the urgency of getting the required testing done on a timely basis. 

This logistically complicated procedure buys nearly an extra month of review time. Even still, both pilot and AME sweat out the dreaded waiting game.

For a pilot to go through this tap dance every year, and for AMEs who work hard to be advocates for their pilots, this is an ongoing stressor that is not enjoyable. For AMEs like me, wherein much of my practice is for “special issuance” cases, I also anxiously await the pilot’s approval letter and rearrange my schedule as necessary both to assist with the initial data submission and then to fit that pilot in for their exam—once that exam can be done, given an authorization letter being finally approved and received.

The opinions expressed in this column are those of the author and not necessarily endorsed by AIN Media Group.