Recommended Practices: Medical Re-certification
The medical re-certification process begins almost immediately following discharge from treatment when the pilot normally meets with his/her IMS (Independent Medical Sponsor). The IMS is the single most important individual involved in medical re-certification. The IMS is the conduit for all information sent to FAA and the person who sponsors the pilot for the SI (Special Issuance) medical. Selection of the IMS is, therefore, a very important decision. In addition to examining factors related to selecting the IMS we’ll also review several related topics. These topics are the typical re-certification timeline, the P&P (Psychological and Psychiatric) evaluation, other possible methods of regaining FAA medical certification for some pilots, and coincident pilot licensing issues.
Selecting an IMS
The IMS (Independent Medical Sponsor) is an FAA AME (Aviation Medical Examiner) who has undergone specific, specialized training. Some pilots in need of an IMS may discover their regular AME is qualified as an IMS, but more likely participation in the HIMS program will require a pilot to select a new medical examiner. The decision of whom to select is a very important one. The IMS will be the pilot’s representative to FAA regarding their medical qualifications, and once selected, isn’t normally changed for the length of the pilot’s monitoring period. In addition to conducting the necessary physical exams, the IMS will review and compile all the records necessary for obtaining and maintaining a Special Issuance medical certificate. In many cases, the IMS will also conduct sobriety testing. Since the SI medical is only valid for 6 months, the pilot will also meet with the IMS regularly. In many cases, the IMS will meet monthly with the pilot prior to re- certification, quarterly through the first year, and semi-annually thereafter. Clearly the selection of this physician, so central to the HIMS process, is highly consequential to the pilot.
For many pilots the most important factors in selecting the IMS are location and cost. Pilots prefer an IMS who is geographically close to more easily accomplish the frequent required visits. Additionally, since sponsoring the pilot is such a time intensive endeavor, many sponsors require a considerable up-front payment. Sometimes this payment can result in a pilot feeling financially stressed, as many pilots have just recently completed and paid for their residential treatment. While location and cost are factors in making the selection of an IMS, they should not be the only factors one considers.
Some IMS’ are highly experienced in sponsoring HIMS pilots. These physicians typically have a good working relationship with other healthcare providers involved with the pilot, and with FAA. Such relationships can aid a pilot in getting the necessary testing and reports accomplished expeditiously and, therefore, the pilot may return to flying more quickly. The speed of the pilot’s return should be driven by clinical factors, of course, but administrative delays that aren’t clinically necessary can dramatically increase the cost of medical re-certification for both the pilot and the company. So, an efficient IMS with higher upfront costs may actually be less expensive in the long run. These statements are not meant to imply that a low or moderately experienced IMS cannot provide comparable service, but it is up to the pilot to ensure the IMS they select places a priority on getting them medically re-qualified.
It is also possible the pilot’s employer has previously vetted a number of IMS’ to determine which meet the needs of oversight and timeliness identified by the company. In these cases, the pilot may be required to select from a limited list of sponsoring physicians to comply with company requirements. A pilot should contact their company’s HIMS, Human Resources, or management representatives as necessary to determine their available options.
Many pilots are understandably concerned about how long it will take for them to complete the medical re-certification process. For many, their benefits will be limited and not flying means no regular paycheck. Many are also concerned about successfully completing the medical re-certification process as they’ve never been previously unqualified. And, of course, pilots are creatures of habit and routine and going through the HIMS process is a clear break with a routine most found comfortable and reassuring. So, “How long will this take?” is a common question for pilots entering the HIMS program.
The answer, unfortunately, is not always clear or simple. At almost every point in the HIMS process, a delay can be experienced either because it was determined to be clinically necessary or because of administrative issues. In many cases, the pilot causes the administrative delay, but other individuals can also create delays. Examples of such delays are: a pilot selects an assessor who is unfamiliar with FAA criteria resulting in an expired physical prior to receiving a diagnosis; a pilot fails to schedule an appointment with their IMS until well after discharge from residential treatment; psychiatric or psychological reports do not meet FAA standards; required reports to the IMS are delayed or missing; the package sent to FAA is delayed, incomplete, or disorganized; etc.
Given the complexity of the HIMS re-certification process, there are multiple opportunities for delay. The best guard against such delays is a proactive pilot who is active in, and monitors the progress of, their own case. In many cases, company HIMS representatives or other HIMS pilots may be able to provide some advice or assistance to a pilot seeking medical re-certification. But, ultimately, it is the responsibility of every pilot to monitor his or her own re-certification. Some pilots who have performed this function well have been re-certified in considerably less than 6 months. For other pilots, medical re-certification has taken a significantly longer time. From our experience, a proactive pilot will “typically” be re-certified in approximately 6 months. This “typical” timeline is depicted below.
The “P&P” (Psychological and Psychiatric) evaluation is an important aspect of the medical certification process, and one that is often looked to with some trepidation by pilots. The purpose of the evaluations is to establish the pilot is developing healthy recovery oriented thinking patterns, that there is no underlying psychosis or neurosis that was masked by excessive alcohol or drug use, and that there are no lingering cognitive deficiencies that may have been related to the alcohol or drug use. For most pilots whose drug of choice has been alcohol, and who have been identified at a relatively early stage in the disease process, the probability of cognitive damage is small. For others, who may be in the latter years of their flying career after many decades of drinking, cognitive deficiencies may be present. Fortunately, for many of these pilots, cognitive problems usually improve over time of their own accord once the alcohol or drug use is terminated. In some cases, cognitive rehabilitation exercises may also aid in improving test results.
FAA requires the P&P evaluations occur no sooner than 30 days following release from residential treatment. This requirement ensures the pilot has at least 60 days sober and the brain is no longer under direct influence of the alcohol or drugs. But, in some cases, such as the “late” stage pilots described above, a longer period of sobriety may prove beneficial before undertaking the examination. If the P&P does not go well, it generally requires a 6 month wait before it can be re-accomplished. So, the choice of when to have the P&P should be based on the clinical factors of the case as well as the economic ones.
Originally, the HIMS program was designed to be a resource for the re-certification of professional pilots. At the time, the perceived need was greater for that group since their livelihood was dependent upon flying, and it was considered essential to have the support and oversight of peers and supervisors to allow for an expedited return to the cockpit. Pilots who didn’t meet the criteria for inclusion in HIMS were required to establish their medical qualification through other means. For pilots with an abuse diagnosis, these means often included some form of treatment and a minimum 2-year period of demonstrated sobriety. However, these pilot cases were managed on an individual basis, so there was some variability in the requirements that were imposed. In many cases, pilots in this group benefited from working with HIMS qualified AME’s. After successful completion of this non-HIMS rehabilitation program, the pilot would be granted a normal medical license. A future alcohol or drug incident would then result in revocation of the medical and a need to re-certify under the provisions of a Special Issuance.
The non-HIMS program described above is still in use today, but there have also been other programs developed. Some pilots who have come to FAA’s attention for alcohol misuse have been granted a medical, but have also been placed under monitoring by an HIMS qualified AME. Some non-professional pilots have been placed in programs that have some of the elements of a HIMS program, but lack other elements. Due to the varying nature of these programs, these programs are not considered to be part of HIMS. These programs are, however, opportunities for medical re-certification for some pilots diagnosed with chemical dependency illness.
There are multiple branches within FAA, and under some circumstances pilots undergoing medical re-certification are also subject to actions taken by non-medical branches of FAA. Specifically, certain violations will result in either a suspension or revocation of a pilot’s flight ratings licenses (including written test results; flight hours accumulated are not affected). These violations include such things as a failure to report a DUI, falsification of the medical application, or a positive DOT drug or alcohol test. Whatever the circumstances, it is best to consider these licensing actions and the medical re-certification process as separate entities.
It is possible to complete the medical re-certification process while still under a suspension or revocation order of the flying licenses. Of course, without the appropriate licenses, the pilot is still prohibited from operating a commercial aircraft. So, it is important to remember the interrelationship of these documents and to plan for it during medical re-certification. Since the written licensing requirements may be accomplished some time in advance of the practical test, a pilot who’s planned properly may be able to receive a medical re-certification and take the practical flight tests in a matter of weeks. Poor planning in this regard can result in an end to disability benefits since the pilot is medically re-certified, while the pilot lacks the flying licenses to return to work.