The decision to submit the recovering pilot’s case for FAA certification action is ultimately made by the medical sponsor. This sponsor is an AME (Aviation Medical Examiner) that has been through HIMS training and approved by the FAA to perform this duty. Often the medical director of the involved airline will perform this duty, other airlines rely on an independent AME.
The goal is to have the pilot in a stable recovery situation with treating professionals in agreement that he is ready for return to flight status. It is not beneficial to allow the case to proceed rapidly, often recovery will need the passage of time to be effective.
The time line chart below is helpful in understanding the various components of the FAA submission process.
It should be noted that the time for each step is an estimate. However, each step is an element that must be included in the package submitted to the FAA. We will consider them on an individual basis.
The FAA requires a formal 14CFR67 diagnosis with the multi-axial assessment documented. If the evaluation was done independently from the inpatient treatment facility, the complete history and rationale for diagnosis must be included.
If the pilot was admitted directly to the treatment facility, this will be the source of the initial evaluation as reviewed above. If not, the treatment facility will also conduct an evaluation to confirm the diagnosis. This will normally be part of a history and physical examination that will conclude with diagnosis and treatment recommendations.
During the treatment program, individual and group notes are made on each patient. The evaluating psychologist and psychiatrist as well as the FAA will want these records as part of the submission. Also needed are the results of any psychological testing and personality issues. WE MUST INSIST THAT THE TREATMENT CENTER PROVIDE THE FULL RECORD, BOILER PLATE STATEMENTS ARE NOT ACCEPTABLE.
A discharge summary will be prepared when the pilot leaves the facility. This summary must recommend needed continuing treatment in the pilot’s home area. This can range from intensive outpatient therapy (IOP), individual therapy, AA (always), aftercare group (always), and family counseling if needed. Many treatment centers take responsibility for identification of local continuing treatment resources. The best situation often occurs when the inpatient treatment facility is near the home of the pilot and continuing care can continue at the same facility.
Intensive Outpatient or Individual Therapy
This is often an extension of the inpatient program and must be continued until the pilot has made sufficient progress so that the weekly aftercare group is sufficient. Individual therapy may continue even after the pilot has returned to flight duties. In either case, after the pilot has progressed sufficiently to allow a recommendation for return to flight duties, a comprehensive summary is needed for FAA submission. This summary must give sufficient detail regarding treatment issues and progress made to allow the FAA to know where the pilot is in his recovery.
Aftercare and AA
The aftercare group is the cornerstone of sobriety after return to flight duties and will be mandated in the special issuance. The FAA submission must have a good summary of participation and progress. The group should be scheduled to meet weekly – the FAA expects the pilot to attend at least half to the meetings for the entire period of the special issuance. Failure to document the aftercare program in the FAA submission will result in delays in FAA certification.
AA, while not officially mandated by the FAA, is another cornerstone. The aftercare report should review the pilot’s AA attendance and document that the pilot has a permanent sponsor. No documentation is required directly from AA.
Peer and Company Sponsors
Both need to be identified, to be trained and to understand how the meetings are to take place. The pilot is responsible for insuring that the monthly meetings take place and that the sponsor understands where the monthly reports are to go. The AME will need to document that sponsors are in place in the AME summary.
Psychological and Psychiatric Examinations (P&P)
The FAA has designated pairs of psychologists and psychiatrists around the country. This examination should not be scheduled until all of the above steps are in place and all agree that the pilot is ready for return to flight duty. A full copy of the above records should be sent to them prior to the evaluation. This is a very demanding and perceptive testing procedure. The pilot should not have the P&P if there is evidence of any residual cognitive dysfunction due to chronic alcohol abuse. More time should elapse to allow recovery. If the pilot is not in solid recovery, he will very often be identified as needing more treatment/time before flight duties. This in turn may require repeating the testing several months later.
FAA Examination and Submission
This is the final review before the case is submitted. The AME has full discretion to give hold the process until the pilot is thought to be in good recovery. The FAA package will contain the following information:
• Diagnostic records (if separate from treatment)
• Full inpatient treatment records
• Summary from IOP or individual therapy
• Summary from aftercare group with schedule
• Full P&P report
• Deferred 8500-8 (FAA Examination)
• Summary from medical sponsor
The AME must carefully review all records to insure that there is not a mention of an overlooked issue (e.g. One note deep in the alcohol treatment records mentions a use of cocaine that has not been addressed). The summary from the medical sponsor must have enough detail for the FAA to determine that the AME does indeed “know” the pilot and can legitimately endorse his return to flight status. The pilot must be otherwise qualified on the 8500-8. The case should be sent to the Federal Air Surgeon’s office via a package with a signed receipt.
The special issuance letter is very specific in its requirements. The pilot is responsible for seeing that each provision of the letter is met. The AME is authorized at any time to revoke the medical certificate. Return to flight duty is a particularly vulnerable time for the recovering pilot. A return to the same atmosphere that supported the addictive behavior is a time for heightened awareness.