The Deferral Process

There are three possible outcomes to every FAA medical exam. You can be issued or denied your medical certificate or your exam may be deferred to the FAA for further review. Whenever you do not meet the criteria to be issued a medical certificate at the exam, your case is usually deferred to the FAA for further review and disposition. Applicants are rarely denied by the AME. The FAA prefers that the AME just defer the case and let them confirm the situation. 

Once an exam is deferred there will typically be an initial look by an FAA medical case reviewer around a month or two after the exam is submitted by the AME. They are looking to see if supporting documentation is present or not, but they are not reading all of the supporting documents in detail nor are they making a final disposition of your case. If you do not have any supporting documentation, the FAA will send you a letter in the mail asking for more information related to the issues disclosed on your MedXPress application. 

Getting a Letter from the FAA

The letter you get from the FAA will most often highlight the medical condition of concern. This should not be much of a surprise to you given that you filled out MedXPress and hopefully your AME explained why your exam was being deferred. The letter will have very specific requirements and it will also have certain timelines associated with the request. 

We previously wrote about the Horror Story of delay when stuck in what seems to be a never ending back and forth cycle with the FAA. The FAA sends a letter, you respond. They send another letter and you respond again. Many times the issue has to do with the documentation itself. The FAA asked for information related to X and what you submitted either doesn’t meet the criteria or also introduced Y, a new condition that the FAA was not previously aware of. But there is a specific type of letter that we call the Gatekeeper. 

What is a Gatekeeper?

Sometimes a pilot has multiple medical issues that all need to have documentation to support their application. Some things, like musculoskeletal complaints and basic vision testing, can readily be evaluated by the AME during the exam. But many medical conditions can only be properly evaluated with lab testing, specific examination techniques and perhaps radiographic studies such as MRIs or CT scans. If all of your medical issues that need further review are on the lower end of concern, they will all be addressed in the letter from the FAA. 

But say you had multiple issues and one of them is a recent head injury with a brain bleed. Depending on the level of injury you may have a mandatory five year wait from the time of injury until you can get a medical certificate. It doesn’t matter what the status of your other medical issues are if you have a mandatory five year wait for the head injury. In a situation like this, the letter from the FAA may only ask for information pertinent to the head injury and initially ignore all of the other conditions of lesser concern. This is what we refer to as the Gatekeeper letter. 

The Gatekeeper letter does not seem to be a policy, but we have definitely observed this phenomenon. If you can’t get past the Gatekeeper, then you aren’t getting a medical certificate regardless of how your other medical conditions are doing. To us it seems as though the FAA medical division is using the Gatekeeper letter as a form of efficiency. Perhaps they don’t want to review dozens of pages of medical records for several different conditions when most of them won’t even matter from a certification standpoint. 

In this example the FAA letter only asks you about the head injury. They want all of the medical records from the event, a detailed clinical progress note from your neurologist, and the results of any interval testing and evaluations. You dutifully gather up all of this information and submit it to the FAA on time. Six or eight months go by while your case is in review, but the FAA determines that you did not have a significant brain bleed based on your medical documentation. Perhaps you misinterpreted what your physicians initially told you. 

Another Letter, but not Approved

Because you made it past the Gatekeeper you now have a legitimate shot at getting your medical certificate. The FAA sends you a new letter telling you so. But this letter also wants to know about those other medical conditions that they didn’t ask about before. The better part of a year has gone by when you get this new letter telling you that you have passed the traumatic brain injury situation and now they want to know about conditions B, C and D. And they give you the customary 60 days to get the requested medical information to them. 

This is a frustrating situation because you would have really liked to know they wanted this information back when they asked for the head injury information. From a bureaucratic efficiency standpoint it makes sense. From a pilot standpoint it is just more delay. However, like the delay we discuss in the Horror Story, it is a delay from lack of preparation. Had you known what issues would require supplemental medical information before your AME exam, you could have had it all prepared in advance. Had you known what category your head injury fell into with certainty, you may not have used the wrong terminology resulting in a Gatekeeper letter in the first place. 

Treating the FAA medical examination as a check ride like any other certificate can help you avoid unnecessary delays in your medical certification. Using the FAA’s Guide for Aviation Medical Examiners is one of the best ways to begin that preparation – it is like the ACS for medical certification.