Imagine this scenario. You’re working with a company like Wingman Med, and you’re told that a prior surgery, diagnosis, or treatment from years ago now requires documentation for FAA medical certification. Maybe you haven’t even had your FAA exam yet and are trying to be proactive. Or maybe you already sat for your AME exam and later received a letter from the FAA Office of Aerospace Medicine requesting additional medical records.

There’s just one problem. The records are 10, 15, or even 20 years old, and no matter how many calls you make, you can’t seem to get them.

This situation is more common than pilots realize—and handled incorrectly, it can lead to significant certification delays or even denials. The good news is that missing records do not present an impossible obstacle to overcome. But the FAA will not simply take your word for it. How you respond matters.

Why the FAA Cares About Old Medical Records

The FAA’s medical certification process is not based on personal assurances, verbal explanations, or what “seems reasonable.” The FAA does not evaluate you—they evaluate your paperwork.

As we’ve emphasized before, high-quality medical documentation is the foundation of a successful FAA medical outcome. Current, detailed clinical progress notes are critical to FAA decision-making.

The FAA is trying to answer a simple question: Is there any unresolved risk to aviation safety? And for many conditions like brain surgery and cancer, the FAA requests historical medical records to help answer that question.

If the records are missing, the FAA still needs that question answered one way or another.

The Core Problem: Records That No Longer Exist

Medical record retention is governed by state law, not FAA policy. In many states, physicians and hospitals are only required to retain records for 7–10 years, sometimes less for inactive patients.

That means if your surgery, hospitalization, or treatment occurred decades ago, the records may legitimately no longer exist.

From the FAA’s perspective, however, “the records no longer exist” is not a conclusion—it’s a claim that must be supported with evidence.

This leads to the real question pilots need to ask.

What Can You Do When FAA-Requested Medical Records Cannot Be Obtained?

The goal is to prove that you made legitimate, documented attempts to obtain them.

The FAA needs to see that:

1. You tried
2. You followed proper channels
3. The records are truly unavailable

Without that proof, you are unlikely to be able to move forward with your medical certification.

Step 1: Submit Formal Medical Record Requests

If you haven’t already, submit a formal written request for your records to:

• The physician’s office
• The hospital or surgical center
• The medical records department

Do this in writing, not just by phone. Keep copies of everything.

If the facility responds verbally that records are unavailable, that response is not enough.

Step 2: Get a Written Statement Explaining Why Records Are Unavailable

If a medical practice or hospital tells you that:

• Records are older than required retention periods
• Records were destroyed per state law
• Records are no longer retrievable

You must ask for a formal written response stating this explicitly.

This document should include:

• The name of the facility
• The date of your request
• The reason the records cannot be provided
• A reference to applicable state retention laws if possible

This written confirmation becomes part of your FAA submission and highlights that you are not attempting to hide anything from your previous health.

Step 3: When a Practice or Hospital Is Out of Business

If the physician or hospital no longer exists, the burden is still on you to show that fact.

In these cases, you should attempt to obtain:

• State business dissolution records
• Licensing board confirmations
• Hospital closure notices
• Archived public records showing the date of closure

Many states allow online searches for dissolved businesses or closed medical facilities. This documentation demonstrates that the lack of records is not due to noncompliance—it’s due to nonexistence.

Step 4: Submit a Clear Paper Trail to the FAA

Your FAA response should include:

• Copies of all record requests
• Written denials or explanations from facilities
• Proof of business dissolution or closure where applicable
• A concise cover letter explaining the situation

This is not the time for emotional explanations or frustration. The FAA is looking for objective evidence, not intent or effort alone.

Why You Can’t Just “Explain It” to the FAA

Pilots often ask: “Can’t I just explain that it was a long time ago and I’m fine now?”

No.

In FAA medical certification, you only speak through your records. If records are missing, you cannot simply ask the FAA to trust your memory or your good intentions.

When historical records are unavailable, the FAA often responds by requesting additional evaluations to fill the information gap. These may fall outside standard FAA protocol and can include:

• Specialist evaluations
• Diagnostic testing
• Detailed narrative summaries
• Current functional assessments

This is not punishment, it’s risk management. The FAA still needs evidence to replace what’s missing.

The Bottom Line

If the FAA requests historical medical records that cannot be obtained:

• Missing records are not fatal to your case
• But silence, delay, or unsupported claims can be

You must demonstrate legitimate, documented attempts to obtain the records and provide proof when they no longer exist. When documentation gaps remain, expect that additional evaluations may be required to satisfy the FAA’s concerns.

Handled correctly, these cases can move forward. Handled casually, they can stall indefinitely.

This is where experienced guidance matters – because in FAA medical certification, what you submit matters far more than what you say.