FAA Current Detailed Clinical Progress Notes. Avoid Medical Certification Delay.

FAA Current Detailed Clinical Progress Notes. Avoid Medical Certification Delay.

With some very rare exceptions, the FAA should NEVER take more than six months to a year to review your medical certificate application. That might seem like a long time to some pilots. For others stuck in the quagmire of successive information requests from the FAA, it might seem laughably naïve.

To be clear, that statement applies to worst case scenarios. About 90% of pilots leave their AME appointment with a medical certificate already in their hands. Many with significant, but well controlled, medical conditions will wait less than three months for the FAA to make their decision.

My opening statement applies to pilots with multiple conditions or ones associated with significant aviation safety concerns. Recent heart attacks, previous strokes, heart valve replacements, insulin dependent diabetes, depression or anxiety treated with medication, other conditions of similar severity, or a combination of them all fall into that category. 

Even with those conditions, the FAA will generally provide a decision in less than six to 12 months. It will not always be the decision pilots want, but with a few exceptions, those who wait longer are waiting for another reason. 

What’s behind the horror stories?

You do not have to look far to find a story on the internet about a pilot who waited years for a medical certificate only to give up and stop trying. Often those stories include a frustrating statement to the effect that “I sent them everything they asked for and they kept asking for more.”

There is truth behind those stories, but there are also misconceptions. Most of the misconceptions have to do with this: the doctors at the FAA’s Aeromedical Certification Division (AMCD) never actually see pilots in person. Instead, they rely on the notes provided by your own doctors to decide if you are safe to fly an airplane. When those notes are incomplete or contradict each other, AMCD reviewers need more information to make a decision. Similarly, if one of those notes adds previously unknown and concerning, information, they will want more information on that as well. 

From the time you start your MedXPress application and especially when providing medical records about complex medical conditions, it is up to you to make sure that your application tells a complete and consistent story. One of the best tools to do that is a good current detailed clinical progress note from your physician(s). 

What is a Current Detailed Clinical Progress Note?

A clinical progress note is a note that every doctor should be trained to write. They might not immediately recognize what the FAA is asking for when you first discuss it with them. If the term “progress note” does not register, try asking for a “complete history and physical” or “SOAP note”. If that doesn’t work, RUN! Find another doctor! One who does not understand what those terms mean or is unwilling to provide a document that meets that standard can only delay your medical certificate application. 

For FAA purposes, the note must be signed by a board-certified physician. Many other highly skilled health care professionals provide excellent care. You might see a physician associate or nurse practitioner who knows more about your healthcare than any physician. It does not matter. For FAA purposes the note must come from a physician. 

The progress note should ideally exist as part of your medical record. It is different from an “After Visit Summary” or “Patient Summary” which you might also see in some online patient portals. Your doctor’s administrative staff should be able to help you locate it. 

Elements of a Good Note

A progress note is what doctors use to communicate with each other about your care. Formatting varies somewhat, but to meet the FAA’s standard, it must include the following information:

  • A history of the condition being treated
  • All current medications and doses
  • Whether or not you experience any medication side effects
  • Physical exam findings
  • Results of any tests performed to evaluate the condition
  • Your specific diagnosis includes something called an ICD-10 codes
  • A clear assessment regarding the status of your condition and how it affects you
  • A clear plan regarding how it is treated
  • A clear statement about how your doctor plans to follow up with you or monitor the condition

Letters from your doctor DO NOT replace progress notes. Ones that amplify information contained in your medical record can help to expedite your medical certification decision. However, your doctor’s detailed clinical progress note provides THE primary means that AMCD uses to evaluate your medical issues. Missing information, inaccuracies, or ambiguity will generate questions. 

Fine print and terminology

When it comes to FAA medical certification, the word “current” means within 90 days preceding your AME or any time after it. Several exceptions to that rule of thumb are clearly spelled out in the FAA’s Guide for Aviation Medical Examiners. Unless one of those exceptions applies to you, nothing prior to 90 days before your AME appointment will be considered in support of your medical certificate. 

The term “detailed” is more subjective. Its inclusion in the FAA’s guidance mostly serves to emphasize that they actually want your doctor to document their considered opinion in a way that shows they spent some effort thinking about your particular situation. As one example, an assessment for high blood pressure that says “HTN controlled with prescription medication” is not detailed. 

A detailed assessment should look more like this: “43-year-old male with essential hypertension and no other modifiable risk factors for cardiovascular disease. He takes 20mg of Lisinopril per day and his average blood pressure is 125/78. No concern for undiagnosed comorbid conditions or indication for work-up at this time. He should follow up annually for routine monitoring.”     

The difference should be obvious.  

Avoiding certification delays  

Progress notes that do not meet these standards slow things down. Visit summaries, notes by non-physicians, notes that lack sufficient detail, old notes, and letters provided instead of progress notes will all delay your application. 

You can probably identify most deficiencies on your own. If you want to take the guesswork out of your FAA medical certification and avoid any unnecessary delays, visit our website and schedule a free consultation to find out more.

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