Understanding the FAA’s Mental Health Guidelines
Old vs New
The FAA published its new mental health guidelines in June 2024. These represented perhaps the most significant changes in mental health policy guidelines in years. On the other hand, it wasn’t as though the FAA had been completely stagnant in updating policies regarding mental health. In recent years, both the PTSD Decision Tool and the Situational Depression Tool have been introduced to allow an AME to issue a medical to those who met specific criteria for those conditions.
Groups of Deferrals
However, diagnoses such as depression and anxiety were still a mandatory deferral. General acceptance for seeking help and treatment for mental health conditions has increased in recent history. Many people are caught in the following group of deferrals without much distinction. For example, recurrent major depression, on and off medication, and relatively mild depression. Combined with the overall increase in the number of applicants for medical certificates but no actual increase in staff for the FAA medical review times, wait times for review began to increase.
With their new guidelines, the FAA essentially made some more distinctions within “anxiety, depression, and related conditions” so that a deferral for mandatory FAA review is no longer required for less concerning cases. Yet many will likely get deferred anyway due to a lack of preparation.
Evolution, not Revolution
By providing more distinction and guidance for AMEs, the FAA allows those who will get issued their medical bills to have their decisions made by the AME. The potential to save six months or more greatly benefits pilots. For those looking for their first medical certificate, that barrier may have been enough to give up on flying.
This is no different than what the FAA has been doing with the CACI protocols for several years – those who are the lowest risk and can prove it with the proper paperwork can be issued their medical certificate at their exam. The FAA is now using the same underlying technique for the less concerning mental health conditions. The more significant mental health conditions like major depression, bipolar, psychosis, and personality disorder, among others, will still have to be deferred for further review by the FAA.
Documentation is still Key.
What we have been experiencing in terms of consultations, online forums, and social media platforms is that many people will be disappointed at their FAA medical certification exam with their AME. Most people think they will leave their FAA medical certification exam with a medical certificate in hand if they meet the new criteria.
Per the FAA’s Guide for Aviation Medical Examiners: “The AME should gather information regarding the diagnosis, severity, treatment, symptoms, and address ALL of the questions on the Anxiety, Depression, and Related conditions Decision Tool for the AME.”
Supporting Documentation
Most people seem to be under the impression that this will be a one-on-one discussion with the AME. The FAA intends for this to be a full review of the supporting historical documentation, so this review can now be done by the AME vs the FAA.
Many pilots did not bring supporting documentation to their exams when these cases were mandatory deferrals. Their exam would be deferred to the FAA for further review, regardless of whether they have documentation. For instance,
1. Most people would not have provided the information the FAA would need to decide
2. The FAA would come back and ask for significant records to show a level of review of that supporting information.
3. This would let the FAA make the medical certification decision for the applicant.
The AME must look at the same information, which must be available for exam review.
Recommendations
If you have a history of a mental health issue that falls into these new guidelines, you still need to prepare for your upcoming exam like a check ride. In July 2024, AME Grand Rounds discussed these new guidelines. One of the FAA psychiatrists explicitly stated that the AME could only issue a medical after a review of supporting documentation. Many AMEs do not like reviewing documentation as part of the exam process. And the more documents you bring, the less likely your AME will be to spend time looking through everything.
AME Appointments
Remember that you generally pay an AME for a 15-20 minute appointment to determine if you meet the guidelines. Do not complicate the appointment for the AME. Otherwise, you may walk out of the exam with your medical certificate. If you bring dozens of pages that cover a few years of treatment, you may find yourself deferred anyway.
Wingman Med recommends treating this like any other historical condition reported for the first time. Bringing a current detailed clinical progress note summarizing your history makes it much easier for an AME to review. Ideally, this would be done by your treating clinician. Or someone of even higher qualifications who can do the primary document review and summarization. They can then provide a more concise and professional report that is much easier for the AME to read and evaluate at the exam. Along with choosing the right AME, proper documentation is critical to your FAA medical certification success.
#FAA mental health standards
