The FAA’s Office of Aerospace Medicine (AAM 300) is effectively broken down into four interworking groups[1]:

• Headquarters in Washington, DC
• Civil Aerospace Medical Institute (CAMI) in Oklahoma City
• Ten Regional Flight Surgeon Offices
  • Alaskan
  • Central
  • Eastern
  • Great Lakes
  • New England
  • Northwest Mountain
  • Southern
  • Southwest
  • Western Pacific
  • International, Military and Federal
• Drug abatement program

Each of these offices has a certain focus, but each also has areas of overlap and/or interaction with others. When it comes to medical certification of pilots, the bulk seems to fall on the Aerospace Medical Certification Division (AMCD) within CAMI and the Regional Flight Surgeon offices. And important thing to understand is that FAA medical certification looks at you a bit different than your treating physician. They are looking at you from a risk mitigation perspective. In other words, what are the chances that you will have a sudden or insidious incapacitating event in the next 6, 12, 24 or 60 months, depending on age and class of medical? I am sorry to say, but no, your past 6000 hours of accident free flight does not really help you after a heart attack, stroke or other significant medical issue. It is the medical evidence of successful treatment and functional capacity for the next set of desired hours is what matters. 

Regional Flight Surgeon offices are also responsible for AME selection and oversight as well as managing the air traffic controller medical certification[1]. In our experience dealing with Regional Flight Surgeons and some of their staff, there can be some pretty significant differences in how the regions handle things. Some are heavily involved with airman medical certification while others are less involved. Some Regional Flight Surgeons will help with over the phone approval of cases that have excellent documentation while others will never provide an over the phone approval no matter how good the paperwork looks. Some regions have a blanket internal policy that they will not allow any AME offices at or near an airport, regardless of how legitimate of a medical office it is. Some regions will allow an office at or near an airport so long as it meets the guidelines of the Designee Management Policy. 

In our experience AMCD seems to handle the majority of airman medical certification cases. 

Process and Timelines

When you go to an exam with an AME, they are supposed to submit it to the FAA within fourteen days. This is a metric that AMEs will be reviewed on. Consistent poor performance in this metric can even result in loss of designation as an AME. This fourteen days is critical to understand because it does place the AME in a bit of a bind if you have a CACI eligible condition, but failed to prepare in advance of your exam. They could issue your medical if you had the right paperwork, but you are unlikely to get a detailed clinical progress note within that timeline. 

The FAA, meanwhile, is under no mandatory timeline to review your exam because it is a safety system and they are dealing with a volume problem. We have been told that exam numbers have been increasing at about 10% per year, but physician staff has not been growing at the same rate.

It is commonly thought that the FAA has 60 days to review and make a disposition on your case. The reality is that the FAA has 60 days to overturn your AME’s decision. If your AME issued your medical, but the FAA has significant concerns, they can revoke your medical within that 60 day timeline. After that 60 day limit, the FAA has to give you a chance to reply before they can revoke your medical. When the FAA does ask for more information it comes in the form of a letter and typically only grants you 60 days to respond. 

Some cases, such as use of antidepressants medication and alcohol and/or drug recovery, automatically get reviewed at the Federal Air Surgeon level. 

Denials, Reconsideration and Appeals

Denial letters can sometimes be difficult to comprehend. In speaking with some FAA physicians, any CFR disqualifying condition you have will be listed in the denial letter even if you satisfactorily met special issuance requirements for that particular condition. They may be denying you for a non-CFR condition that wasn’t addressed well, but the CFR ones are likely to be the ones cited in the denial letter. 

Typically a denial letter will mention the ability to request reconsideration. Sometimes they will even state in the letter that if you provide a certain evaluation from a physician, they will reconsider. The value in the request for reconsideration is that the FAA will generally send you a list of detailed requirements before they will reconsider your case. This is the way you can find out exactly where your submission was deficient and can help with a roadmap to success. 

The definition of an appeal can vary depending on whom you talk to. In our opinion a request for reconsideration after supplying amplifying new information is not a true appeal as are your being given the chance to submit new data for review. An appeal, in our opinion, is asking the FAA to re-review previously provided documentation in an attempt to reverse their own decision. Typically this would be done at the Federal Air Surgeon office level and in our experience it tends to be a waste of time. 

Sometimes a potential client will ask us to help with an appeal. We tell them that we don’t help with formal appeals to the Federal Air Surgeon office. The reason is that nearly every time we review the files, the FAA has made the correct decision based on the information they were provided. The issue almost always lies in not having provided the high quality documentation that shows the individual met certification standards, not that the FAA made an incorrect decision. In the rare instance where the FAA did make an error, we can highlight those for immediate correction and still no formal appeal is required. We have yet to have a physician at AMCD refuse to assist in a situation like this. 

Understanding the process can go a long way to understanding how to better prepare for your medical certification

[1] F. S. Briefing, “Who’s Who in the Office of Aerospace Medicine,” Cleared for Takeoff. Accessed: May 12, 2024. [Online]. Available: https://medium.com/faa/whos-who-in-the-office-of-aerospace-medicine-6adf770441ed.