FAA Postpones Medical Certificate Policy Change

Following a letter signed by EAA and 13 other aviation associations and unions, as well as a separate letter from House Transportation and Infrastructure Committee Chairman Sam Graves, the FAA has postponed the implementation of a policy that would significantly alter the application process for the issuance of medical certificates from January 1 to March 1. As previously reported, the FAA Office of Aerospace Medicine had proposed to issue initial denials to any incomplete application requiring an FAA decision. Denial letters would include instructions for submitting the necessary information to continue the application. Currently these applications are deferred by the FAA pending the submission of required information within a specified time window.

EAA and numerous other aviation groups have concerns about the policy, which the FAA initially said was prompted by Section 801 of the FAA Reauthorization Act of 2024. In the statement to industry following the letter provided Wednesday, December 18, the FAA said, “The decision to implement this change was not associated with the FAA Reauthorization Act of 2024, but the need to provide immediate answers to airmen regarding the medical certification process.” In other communications, the FAA further stated that the policy would “streamline” applications by reducing the volume of back-and-forth communication between the FAA and applicants, as is typical of deferrals.

EAA and the other signatories of the letter contend that this proposal introduces too many unintended consequences to be acceptable to the aviation community. This is true even if the end result of the revised process should not result in any change to the final outcomes of cases.

The policy would dramatically increase the number of denials issued following initial application, increasing the stress of the application process and potentially the confusion of what conditions and medication do and do not result in a “denial.”

Of additional concern to EAA and other general aviation groups, BasicMed is not an option to airmen whose most recent medical certificate was denied, suspended, or revoked.* Deferred medicals are none of these, meaning that an airman under deferral can continue to fly under BasicMed rules while their application is in process (provided they meet all other regulatory requirements, including 14 CFR 61.53 on self-certification). An initial denial would end that eligibility, though it would be restored with a favorable decision after all documentation is submitted and reviewed. This could be relevant in the case of an airman who requires a 2nd Class or higher medical certificate, who could continue flying recreationally under BasicMed while their application is in process.

EAA appreciates the willingness of the FAA to respond to community concerns by postponing the implementation of this policy. We look forward to further dialog with the FAA in the new year as we further advocate for our members on this topic.

Regardless of this policy, it is best practice to submit all relevant information for an FAA decision on any condition or medication at the time of application. This will potentially cut weeks or months off the time between your application and an FAA decision. If you have any concerns about your eligibility for a medical certificate or additional information required by the FAA, talk to your AME prior to your appointment. EAA members can also call us at 800-564-6322 or email govt@eaa.org.

*A previous report on this issue also included Sport Pilots in this statement. EAA is reviewing 14 CFR 61.23(c)(2)(ii), which uses different language for Sport Pilots than 61.23(c)(3)(iv) for BasicMed, making this statement’s applicability to Sport Pilots potentially inaccurate. EAA is investigating further.

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