The FAA’s new AME Assisted Special Issuance (AASI) PATH for Anxiety, Depression, and Related Conditions represents an important change for certain pilots and air traffic control specialists (ATCSs) who are taking antidepressant medication.

For years, airmen who received FAA authorization to continue flying or performing safety-sensitive duties while taking an approved antidepressant generally remained in a structured HIMS Special Issuance program. That process typically required recurring oversight by a HIMS Aviation Medical Examiner (HIMS AME), periodic psychiatric evaluations, and other documentation specified in the FAA Authorization letter.

Announced on July 29, 2026, the PATH process may reduce some of those recurring HIMS-specific requirements for eligible individuals. However, it is important to understand exactly who PATH applies to, how it differs from the traditional HIMS pathway, and why pilots and ATCSs should not assume they have automatically been moved into PATH.

Who the FAA AASI PATH Is Designed For

PATH is primarily relevant to pilots and ATCSs who are taking antidepressant medication and who have already been approved by the FAA under a Special Issuance or Special Consideration for anxiety, depression, or a related condition.

These individuals originally obtained FAA approval through the traditional antidepressant certification process with the assistance of a HIMS AME. If you are wondering whether you fall into that category, you probably do not. Pilots who have successfully navigated the HIMS program know. 

The key point is that PATH is a follow-up certification pathway, not an initial antidepressant approval pathway.

A pilot or ATCS who is already taking an FAA-conditionally acceptable antidepressant and has previously completed the FAA’s required psychiatric, HIMS, and neuropsychological evaluation process may eventually be eligible for PATH. But eligibility is not automatic.

The FAA must specifically authorize the individual to participate in the PATH program. Until that occurs, the individual must continue following the requirements contained in the existing Special Issuance or Special Consideration authorization [1], [2].

Traditional HIMS Requirements for Antidepressant Special Issuance

Historically, pilots and ATCSs taking antidepressant medication under FAA authorization have been followed under the FAA’s HIMS antidepressant recertification protocol.

Under this model, the HIMS AME plays a central role in ongoing FAA monitoring.

Depending on the terms of the individual Authorization, traditional HIMS follow-up may include:

• A face-to-face evaluation with a HIMS AME approximately every six months.
• A detailed HIMS AME summary submitted to the FAA.
• Periodic psychiatric evaluations or status reports.
• Documentation from the treating physician or prescribing clinician.
• Review of medication dosage, side effects, clinical stability, and functional performance.
• Chief pilot or employer reports in certain cases.
• Additional psychiatric, psychological, or neurocognitive testing when clinically indicated or specifically required by the FAA.

Because there was so much documentation required and the FAA was historically concerned about emergent medication side effects as well as recurrent symptoms, they relied on formally trained HIMS AME to facilitate the application process in addition to performing their role as a medical examiner [3].

For pilots and ATCSs who have demonstrated long-term stability, this process can become administratively burdensome even when there have been no meaningful clinical changes.

PATH is intended to provide a more streamlined monitoring pathway for selected individuals who have already demonstrated appropriate clinical stability.

How PATH Requirements Differ From Traditional HIMS Monitoring

The most important difference between the two pathways is who manages the continuing certification process and what documentation is routinely required.

Under the traditional antidepressant Special Issuance pathway, follow-up is centered around the HIMS AME.

Under PATH, the ongoing certification process may be handled through the AASI process, provided the FAA has specifically authorized it.

The PATH documentation requirements focus more heavily on current clinical stability and recent treating-clinician documentation rather than on repeated HIMS-specific evaluations.

Under current FAA PATH guidance, the airman generally must provide:

• The FAA Authorization letter specifically approving AASI PATH.
• A completed PATH Status Summary.
• Detailed Clinical Progress Notes from treating clinicians.
• At least annual documentation from the primary physician.
• Treating-clinician progress notes at least every six months, or more frequently when clinically indicated.
• A recent clinical progress note dated within 90 days of the AME examination.

The PATH Status Summary focuses on whether there has been any deterioration in areas that could affect aviation safety, including cognition, judgment, emotional stability, insight, behavior, or occupational and social functioning [1], [2].

In practical terms, this means PATH may allow an eligible pilot or ATCS to move away from a recurring HIMS-centered structure and toward a more traditional AASI follow-up process.

That does not mean the FAA is reducing its concern about antidepressant use. It means the FAA may allow selected, stable individuals to demonstrate continued eligibility using a different documentation framework.

PATH Does Not Eliminate HIMS for Initial Antidepressant Certification

PATH does not replace the HIMS process for a pilot or ATCS who is applying for FAA medical clearance for the first time after beginning antidepressant therapy.

A new applicant who intends to continue taking an FAA-conditionally acceptable antidepressant must still follow the FAA’s Decision Path II process. Decision Path II specifically requires involvement of a HIMS AME [4].

For initial antidepressant certification, the FAA typically requires a much more extensive evaluation package which typically includes: 

• Evaluation and coordination by a HIMS AME.
• A report from a board-certified psychiatrist.
• Neuropsychological evaluation.
• Treating-physician records.
• Medication history and documentation of clinical stability.
• Additional records or evaluations requested by the FAA.

The FAA requires the individual to demonstrate a period of stability on the same medication and dosage before the initial application package is submitted [4], [5].

Therefore, a pilot or ATCS who begins antidepressant treatment and then applies for FAA medical certification will not be eligible for PATH recertification until completing the traditional application process with a HIMS AME. 

Existing Antidepressant Special Issuance Holders Are Not Automatically Moved to PATH

Another critical point is that pilots and ATCSs currently taking antidepressants under an approved Special Issuance will not all automatically transfer into PATH.

The FAA must affirmatively authorize the change with a new authorization letter that specifically states that AASI PATH is approved [1].

If the current FAA Authorization still requires HIMS AME evaluations, psychiatric reports, or other HIMS documentation, those requirements remain in effect until the FAA issues new instructions.

Pilots and ATCSs should not assume the publication of the PATH protocol automatically changes their existing Special Issuance. The controlling document remains the individual FAA Authorization letter.

Why the PATH Change Matters

For new antidepressant applicants, the traditional HIMS-based approach remains the starting point and has not changed with the introduction of the AASI PATH protocol.

Even for those already approved, the FAA still retains control over eligibility. PATH is available only after the FAA specifically authorizes the individual to use it.

However, for pilots and ATCSs who are taking antidepressant medication and have already demonstrated long-term clinical stability, PATH may represent a meaningful reduction in the recurring administrative burden associated with traditional HIMS monitoring.

References

[1] Federal Aviation Administration, “AASI for Anxiety, Depression, and Related Conditions PATH,” Guide for Aviation Medical Examiners, Jul. 29, 2026.

[2] Federal Aviation Administration, “PATH Status Summary for Anxiety, Depression, and Related Conditions,” Jul. 29, 2026.

[3] Federal Aviation Administration, “HIMS AME Checklist – SSRI Recertification/Follow Up Clearance,” Dec. 28, 2022.

[4] Federal Aviation Administration, “SSRI Decision Path-II (HIMS AME – Initial Certification/Clearance),” Dec. 3, 2025.

[5] Federal Aviation Administration, “Airman Information – SSRI Initial Certification,” Dec. 3, 2025.

[6] Federal Aviation Administration, “Protocol for Antidepressants,” Guide for Aviation Medical Examiners, Apr. 24, 2024.

[7] Federal Aviation Administration, “Use of Antidepressant Medications,” Guide for Aviation Medical Examiners.