Special Issuance Requirements - Utterly Confused

[Holdingshortforever]

I received a Special Issuance Class 3 Medical in July (after an incredibly long 2+ year wait and back and forth with the FAA) for "stress related anxiety and depression", and the authorization letter is very confusing. I have pasted relevant sections of the letter below for ease of review by the medically astute folks in this community.

I continue to do quite well, but I'm not sure what it is I need to do to keep this active and by when.

My questions are as follows:

(1) What exactly is the difference between the Authorization expiration date and the Certificate expiration date? I take the plain English to mean that the certificate expires on November 30, 2024 no matter how long the "authorization" lasts?
(2) Does the certificate expiration date of November 30, 2024 mean that I need to get a new physical from my AME and fill out a new MedXpress form before that date? If so, do I need to go to the original AME I saw, or can I go to a new one?
(3) Whom do I need to get the current detailed clinical progress note from? I know the letter says "treating physician" but I haven't seen my primary treating physician in years since I got off antianxiety medication a long time ago after doing incredibly well. Do I need to go back to that person just for this requirement? Or should I go to the HIMS psychiatrist who gave me a clean bill of health the first time when they asked for a current psychiatric evaluation? Or should I have my regular counselor provide the note? They will all most likely verify that I continue to do well, but I just need to know what documents to gather and from whom.
(4) Is there any other documentation the FAA will need to make sure I keep this active?

RELEVANT TEXT OF LETTER FOLLOWS:

• The enclosed CERTIFICATE :
o Is valid until November 30, 2024;
o Requires your signature;
o Supersedes any previously issued certificates

• This AUTHORIZATION:
o Shall be effective until it expires on November 30, 2028 or
withdrawn by the agency;
o Supersedes any previously issued Authorization;
o Must be presented to your AME at the time you undergo an airman
medical examination.

You have been granted this Authorization for Special Issuance following the
FAA ' s determination that you do not meet the medical standards prescribed i n
14 C.F.R. Part 67 under Section (s ) 67 . 107 (c ), 67 . 207 (c ), and 67 . 307(c) for an
unrestricted airman medical certification due to your established medical
history or clinical diagnosis of : stress related anxiety and depression. You
have the right to appeal this decision as prescribed in 49 USC 447 03 .
You must follow the Airman/AME Instructions set forth in this authorization
for continued certification under this authorization.

For continued certification under this authorization :
1. A physical examination (FAA Form 8500- 8 ) by a designated AME will be
required at the frequency prescribed under the provisions of 14 CFR § 61 . 23 .
Your next third-class application will be due in November 2027.

2. In November 2024, you are required to obtain the following :
• A current, detailed clinical progress note regarding your history of stress related anxiety and depression , generated from a clinic visit
with your treating physician in accordance with the enclosed guidelines.
• The clinical progress note must specifically include a discussion of any continued counseling, sleep and eating habits, general life stability.

Many thanks to all of the extremely knowledgeable pilots and docs on this forum for any insight you can share!

 

[Rcmutz]

The way that works for my OSA is the SI Authorization is good till the end date. The Class 3 certificate is only good for one year. The Class 3 exam still must happen every two years. For OSA they require my usage data for the year on the off year of the exam. Then like any other Class 3 medical exam on the second year, I see the AME with the same usage data. There should have been instructions with the SI on what you need to submit each year. BWTHDIK…. I did stay at a Holiday Inn Express, though.

 

[Half Fast]

It means you can (and probably should) switch to Basic Med and not have to worry about all this BS.

 

[Anthem]

Are you planning on doing anything beyond just pleasure GA flying ? If not and you won’t be getting in to larger turboprop type of planes (or pressurized) then stick with basic med.

 

[Half Fast]

Let's see if we can get @Brad Z to weigh in, but as I understand it, your medical certificate will expire in a month (sweet, huh?) so you will need another exam with your AME. The authorization, valid until 2028, will allow your AME to issue a fresh certificate BUT you will need to bring the clinical progress note for him to do so.

Hopefully Brad will correct that if I screwed it up. In any case, call your AME and discuss this with him.

In any event, if Basic Med will give you sufficient privileges, you can just let the medical certificate expire and switch to Basic Med, as did I and about 70,000 other pilots. Once the medical certificate expires, it can no longer be revoked, but if you apply for a fresh one next month you do have some risk of falling into the OKC rabbit hole again.

Personally I won't play FAA medical roulette ever again. Basic Med from now on.

 

[Brad Z]

Let's see if we can get @Brad Z to weigh in, but as I understand it, your medical certificate will expire in a month (sweet, huh?) so you will need another exam with your AME. The authorization, valid until 2028, will allow your AME to issue a fresh certificate BUT you will need to bring the clinical progress note for him to do so.

Hopefully Brad will correct that if I screwed it up. In any case, call your AME and discuss this with him.

In any event, if Basic Med will give you sufficient privileges, you can just let the medical certificate expire and switch to Basic Med, as did I and about 70,000 other pilots. Once the medical certificate expires, it can no longer be revoked, but if you apply for a fresh one next month you do have some risk of falling into the OKC rabbit hole again.

Personally I won't play FAA medical roulette ever again. Basic Med from now on.

Sounds like the OP was under 40 at the time of the original exam. Thus the next exam with an AME is November 2027. (See note above: "A physical examination (FAA Form 8500- 8 ) by a designated AME will be required at the frequency prescribed under the provisions of 14 CFR § 61.23 . Your next third-class application will be due in November 2027.")

In the meantime, if the OP wishes to maintain the class 3 medical, he or she will need to comply with status update note in item #2 of the letter, or the certificate will not be re-issued for another additional year. Since this medical expires 11/30/2024, the OP needs to get a status update pronto.

As others have noted, BasicMed is an option at this point. The OP will need to be continued to be treated for the condition, but there will be no need to maintain an SI or provide the FAA with status reports. The OP can just let the current medical expire, send nothing else to AMCD, and instead follow the BasicMed process of completing the 8700-2, getting a BasicMed exam, and taking the online course.

 

[bbchien]

To Holdingshort forever: if you can fax the letter to me at ___ ___. ____, I’lll advise you specifically pro bono. Any FedXstation can do that for a few dollars (include you tel#). I agree the letters are getting tough for any non AME To figure out.
****

Many accurate comments here.

I think the only path ahead for the agency, with the budget they have is to ABANDON 3rd class. The have put allocated the resources to the revenue aviators, good or bad.

FAA is currently doing things that look right to them but are decimating the DPE AME and DME ranks. THEY can’t function without designees…but ever try recently to get a DPE? The 50 hour rule is killing them.

So is the ACS format for mechanics. Tried to find an A&P IA recently?

And AMES were given clerical duties…….And so a lotta guys are just gonna quit. And a lot have already.

Brad may not be part of the problem but his organization is on a ruinous path.

 

[Rcmutz]

Sounds like the OP was under 40 at the time of the original exam. Thus the next exam with an AME is November 2027. (See note above: "A physical examination (FAA Form 8500- 8 ) by a designated AME will be required at the frequency prescribed under the provisions of 14 CFR § 61.23 . Your next third-class application will be due in November 2027.")

In the meantime, if the OP wishes to maintain the class 3 medical, he or she will need to comply with status update note in item #2 of the letter, or the certificate will not be re-issued for another additional year. Since this medical expires 11/30/2024, the OP needs to get a status update pronto.

As others have noted, BasicMed is an option at this point. The OP will need to be continued to be treated for the condition, but there will be no need to maintain an SI or provide the FAA with status reports. The OP can just let the current medical expire, send nothing else to AMCD, and instead follow the BasicMed process of completing the 8700-2, getting a BasicMed exam, and taking the online course.

I have asked this before, but want to ask again because I don’t remember the answer.

If you are on a SI, and allow your Class 3 medical to expire going on to Basic Med, and THEN you SI expires say 2 years latter, if you wanted to go back to Class 3 for some reason, would you need to go back and submit all the same test reports etc as you did for the original SI? Remember, I said the SI has now expired.

 

[Jon Wilder]

@Brad Z The "November 2027" is either a mistype by the OP or a misprint in the Authorization Letter. Special issuance medical certificates are time limited regardless of age/class, and usually for no longer than 12 months I believe. The enclosed certificate is valid until November 30th, 2024.

To the OP, you will need to submit all documentation requested by the Special Issuance Authorization Letter up to the last day of the Special Issuance Medical Certificate (November 30th, 2024). If you choose to remain certificated under Part 67, you will need to fill out a MedXpress form and undergo another physical with your HIMS AME to renew the certificate.

However, if you wish to do Basic Med, submit all documentation requested by the Special Issuance Authorization Letter up to the last day of the Special Issuance Medical Certificate (November 30th, 2024), but DO NOT fill out another MedXpress and undergo another physical. Submit the requested documentation and walk away from it. Then go through the BasicMed process.

You can actually get BasicMed done and active now if you want. That way once the medical certificate is dead, submit the documentation and be done with it. The Special Issuance Authorization Letter just becomes a piece of paper at that point.

As @Half Fast mentioned, if you apply for a fresh one next month, you do have some risk of falling into the OKC rabbit hole again. Go BasicMed and end the cycle of medical roulette.

 

[Brad Z]

I have asked this before, but want to ask again because I don’t remember the answer.

If you are on a SI, and allow your Class 3 medical to expire going on to Basic Med, and THEN you SI expires say 2 years latter, if you wanted to go back to Class 3 for some reason, would you need to go back and submit all the same test reports etc as you did for the original SI? Remember, I said the SI has now expired.

If the SI authorization has expired, it would be as though you started from scratch. That said, you know what they need from the last SI, so you should be able to walk into the AME’s office and be able to provide all of the information necessary to re-issue the SI.

 

[Brad Z]

@Brad Z The "November 2027" is either a mistype by the OP or a misprint in the Authorization Letter. Special issuance medical certificates are time limited regardless of age/class, and usually for no longer than 12 months I believe. The enclosed certificate is valid until November 30th, 2024.

To the OP, you will need to submit all documentation requested by the Special Issuance Authorization Letter up to the last day of the Special Issuance Medical Certificate (November 30th, 2024). If you choose to remain certificated under Part 67, you will need to fill out a MedXpress form and undergo another physical with your HIMS AME to renew the certificate.

However, if you wish to do Basic Med, submit all documentation requested by the Special Issuance Authorization Letter up to the last day of the Special Issuance Medical Certificate (November 30th, 2024), but DO NOT fill out another MedXpress and undergo another physical. Submit the requested documentation and walk away from it. Then go through the BasicMed process.

You can actually get BasicMed done and active now if you want. That way once the medical certificate is dead, submit the documentation and be done with it. The Special Issuance Authorization Letter just becomes a piece of paper at that point.

As @Half Fast mentioned, if you apply for a fresh one next month, you do have some risk of falling into the OKC rabbit hole again. Go BasicMed and end the cycle of medical roulette.

You are correct that medical certificates issued with an SI have a specific expiration date, however you don’t need to re-apply for a medical certificate and submit to an examination each time in order to extend the medical certificate. If you’re under age 40 at time of exam, your exam is still good for five years; you’ll just need to provide a status update each year during those subsequent years. After the fifth year, you’ll need to re-apply for a new examination in addition to providing a status update to comply with the SI.

 

[UTLonghorn_1979]

You are correct that medical certificates issued with an SI have a specific expiration date, however you don’t need to re-apply for a medical certificate and submit to an examination each time in order to extend the medical certificate. If you’re under age 40 at time of exam, your exam is still good for five years; you’ll just need to provide a status update each year during those subsequent years. After the fifth year, you’ll need to re-apply for a new examination in addition to providing a status update to comply with the SI.

Follow up question. I’m expecting, hoping for an SI in the next 8-12 months related to SSRI use for anxiety and alcohol substance use. I’m at the final stages for re-applying for SI through my HIMS AME. Assuming I get my SI, can I immediately move to basic? I want to look at getting off of the SSRI as I’m pretty sure much of the anxiety was related to job stress and the drinking was to cope with that.

I might re-apply for class 3 after 2 years off of the meds, as that’s my understanding of when I can do so without a deferral for the SSRI use. I have no plans for flying other than GA fun/work travel over the next few years. Eventually I’d like to volunteer for CareFlight and dog rescue types of organizations, with ultimate goal of looking at doing aerial firefighting. But that’s at least 10 years away.

I am over 40 years old.

Thanks!

 

[Brad Z]

Follow up question. I’m expecting, hoping for an SI in the next 8-12 months related to SSRI use for anxiety and alcohol substance use. I’m at the final stages for re-applying for SI through my HIMS AME. Assuming I get my SI, can I immediately move to basic? I want to look at getting off of the SSRI as I’m pretty sure much of the anxiety was related to job stress and the drinking was to cope with that.

I might re-apply for class 3 after 2 years off of the meds, as that’s my understanding of when I can do so without a deferral for the SSRI use. I have no plans for flying other than GA fun/work travel over the next few years. Eventually I’d like to volunteer for CareFlight and dog rescue types of organizations, with ultimate goal of looking at doing aerial firefighting. But that’s at least 10 years away.

I am over 40 years old.

Thanks!

You can transition to BasicMed once your medical certificate expires. Until then, you’d need to comply with the requirements of the SI. Note that a medical certificate issued under an SI is typically limited to a year or less.

 

[Half Fast]

I think the only path ahead for the agency, with the budget they have is to ABANDON 3rd class. The have put allocated the resources to the revenue aviators, good or bad.

I agree with the idea, but executing it isn’t so simple. If OKC eliminates the 3rd class, then pilots will have to get a 2nd class before going to Basic Med. The only way to make it work would be to change the law to eliminate the need for a medical as a prerequisite for Basic.

IOW, it’s gonna take an act of Congress....

An alternative approach might be to let any physician grant a 3rd, just as they can do for Basic, unless one of the 3 conditions requiring an SI is present in which case they must see an AME. Prior to 1960 or so, any doc could issue a medical for PPLs, so we’d basically be returning to that.

....but his organization is on a ruinous path.

Amen, brother. Amen.

 

[Holdingshortforever]

Many thanks to all of you for your detailed and thoughtful replies! And also to Dr. Chien for the very kind offer! I have faxed you the letter.

I was under 40 at the time I got my physical with the AME, which explains the differing dates.

As far as what to do next, I'm still torn. There's a lot of good advice in these replies. If the process to renew the SI is actually straightforward in my case, I don't see any reason not to keep a Class 3. But if I want to do BasicMed, it seems like I will still need to get the FAA the information it wants so they don't revoke the certificate before I get the BasicMed process done. And that means I still need to figure out which providers to ask and what documents to ask of them.

Also, I am a student pilot trying to get my PPL and I'm unsure if the FAA will give me any trouble for trying to solo and eventually pass a check ride without a Class 3 of some kind. (I know 14 CFR § 61.23(a)(3)(i) and 14 CFR § 61.89(d) seem to authorize doing a full PPL process under Basic Med, but I'm not sure if the bean counters at the FAA readily know that. Judging by how the FAA and my AME handled my medical file, I don't have a ton of confidence.)

Are there any reasons to *not* do BasicMed? I am thinking about becoming a CFI at some point and eventually fly internationally, which I know require having a medical certificate. Would switching to BasicMed hurt me down the road if I have those aspirations and want to upgrade to a Class 2 when I'm ready?

Thank you all!

 

[bbchien]

There are no reasons to NOT do a basic med, either in addition or as an alternative to your 3rd class. See your private email.

I would caution however that the condition for which the SI was issued is a DISASTER to get back into/onto, if you dont maintain it, and woudl not "throw" this hard won authorization without seriouly considering the maybe eventual need to "get back into system" (larger aircraft, travel to Canada, etc).

 

[Rcmutz]

Dr. Chen makes a valid point. My SI is for OSA. Only thing required is a sleep study or perhaps a Wakefulness Maintenance Test. Both of which are a PITA. Coming off a Class 3 onto Basic Med requires me to weigh the odds of my personal physician or his group deciding they don’t want to do the BM down the line due to liability concerns, forcing me to find another Dr, or go back to the Class 3. They do do the truck driver medical exams. Decisions decision.

 

[Brad Z]

Many thanks to all of you for your detailed and thoughtful replies! And also to Dr. Chien for the very kind offer! I have faxed you the letter.

I was under 40 at the time I got my physical with the AME, which explains the differing dates.

As far as what to do next, I'm still torn. There's a lot of good advice in these replies. If the process to renew the SI is actually straightforward in my case, I don't see any reason not to keep a Class 3. But if I want to do BasicMed, it seems like I will still need to get the FAA the information it wants so they don't revoke the certificate before I get the BasicMed process done. And that means I still need to figure out which providers to ask and what documents to ask of them.

Also, I am a student pilot trying to get my PPL and I'm unsure if the FAA will give me any trouble for trying to solo and eventually pass a check ride without a Class 3 of some kind. (I know 14 CFR § 61.23(a)(3)(i) and 14 CFR § 61.89(d) seem to authorize doing a full PPL process under Basic Med, but I'm not sure if the bean counters at the FAA readily know that. Judging by how the FAA and my AME handled my medical file, I don't have a ton of confidence.)

Are there any reasons to *not* do BasicMed? I am thinking about becoming a CFI at some point and eventually fly internationally, which I know require having a medical certificate. Would switching to BasicMed hurt me down the road if I have those aspirations and want to upgrade to a Class 2 when I'm ready?

Thank you all!

There is no issue doing your initial training with BasicMed. It's less common since you need a one-time medical and most students still have a valid medical when it comes time to take the practical test. But the regs are clear and DPEs should be quite familiar with it. Heck, the DPE may be a BasicMed pilot too.

Whether you need BasicMed is completely up to you. As others have noted, there's pros and cons either way. The big reason not to do it is if you have immediate plans to go commercial and fly for compensation or hire (flight instruction for compensation *can* be done under BasicMed).

 

[bbchien]

We have conversed and I think the OP "has got it".

 

[Half Fast]

Also, I am a student pilot trying to get my PPL and I'm unsure if the FAA will give me any trouble for trying to solo and eventually pass a check ride without a Class 3 of some kind. (I know 14 CFR § 61.23(a)(3)(i) and 14 CFR § 61.89(d) seem to authorize doing a full PPL process under Basic Med, but I'm not sure if the bean counters at the FAA readily know that. Judging by how the FAA and my AME handled my medical file, I don't have a ton of confidence.)

I did my PPL checkride using Basic Med without a problem. My class 3 certificate was only good for 9 months when I received it. Between instructor scheduling, my own schedule, and DPE availability, it was about 10 months before I took my checkride and by then I was on Basic.

It's not as unusual as you may think. Many people start training, then have to drop out for a few years. When they start again, the class 3 might be expired, but they can pick up Basic Med quickly and finish their training.

 

[Brad Z]

To Holdingshort forever: if you can fax the letter to me at ___ ___. ____, I’lll advise you specifically pro bono. Any FedXstation can do that for a few dollars (include you tel#). I agree the letters are getting tough for any non AME To figure out.
****

Many accurate comments here.

I think the only path ahead for the agency, with the budget they have is to ABANDON 3rd class. The have put allocated the resources to the revenue aviators, good or bad.

FAA is currently doing things that look right to them but are decimating the DPE AME and DME ranks. THEY can’t function without designees…but ever try recently to get a DPE? The 50 hour rule is killing them.

So is the ACS format for mechanics. Tried to find an A&P IA recently?

And AMES were given clerical duties…….And so a lotta guys are just gonna quit. And a lot have already.

Brad may not be part of the problem but his organization is on a ruinous path.

Designee management is outside of my wheelhouse, but I'm pretty familiar with the issues. The lack of DPEs is a downstream effect of lack of FAA inspectors, who are coming from the same cohort of pilots that the airlines had been, up until recently, throwing tons of money at. To make matters worse, inspectors were leaving the FAA to go back to the cockpit. I don't blame them, they were overworked. As a result, there weren't enough inspectors to manage the existing, let alone the additional needed designees. I expect that the decline in airline pilot hiring and an eventual slowing of flight training will even things out. Inspectors are getting hired and trained.

Regarding medicals, I personally don't think the idea of sunsetting the 3rd class medical is not as far fetched as it was 10 years ago. The big stumbling block would be a pretty big difference from established ICAO medical standards. Ultimately I think the success of BasicMed from a safety perspective will have the greatest effect on moving in that direction. Other countries are looking to see how it will play out...so far, so good but the initial data is from a relatively short period of time with a relatively short time frame from last FAA medical. As we get farther and farther into BasicMed, we'll have a much better sense of risk from a data perspective. There's reason to be optimistic.

 

[Half Fast]

Regarding medicals, I personally don't think the idea of sunsetting the 3rd class medical is as far fetched as it was 10 years ago.

I hope you’re right, but I don’t see how it will help unless we also eliminate the Basic Med prerequisite to have held a medical. Or are you saying we just drop the medical requirement for PPLs altogether, like for SP?

 

[Jon Wilder]

Many thanks to all of you for your detailed and thoughtful replies! And also to Dr. Chien for the very kind offer! I have faxed you the letter.

I was under 40 at the time I got my physical with the AME, which explains the differing dates.

As far as what to do next, I'm still torn. There's a lot of good advice in these replies. If the process to renew the SI is actually straightforward in my case, I don't see any reason not to keep a Class 3. But if I want to do BasicMed, it seems like I will still need to get the FAA the information it wants so they don't revoke the certificate before I get the BasicMed process done. And that means I still need to figure out which providers to ask and what documents to ask of them.

Also, I am a student pilot trying to get my PPL and I'm unsure if the FAA will give me any trouble for trying to solo and eventually pass a check ride without a Class 3 of some kind. (I know 14 CFR § 61.23(a)(3)(i) and 14 CFR § 61.89(d) seem to authorize doing a full PPL process under Basic Med, but I'm not sure if the bean counters at the FAA readily know that. Judging by how the FAA and my AME handled my medical file, I don't have a ton of confidence.)

Are there any reasons to *not* do BasicMed? I am thinking about becoming a CFI at some point and eventually fly internationally, which I know require having a medical certificate. Would switching to BasicMed hurt me down the road if I have those aspirations and want to upgrade to a Class 2 when I'm ready?

Thank you all!

You only need to get the requested information up to the "Not valid for any class after" date on the medical certificate. Once you've submitted that, you're done. Make sure you revoke in writing any and all prior authorizations for your AME to share your protected health information with the FAA as well. Then walk away from the medical certificate.

You can wait until your medical is timed out before going BasicMed if you wish.

No issues doing solo or checkride as a student pilot. That's exactly how I did mine.

You can CFI on BasicMed. However, flying commercial and/or internationally will require a medical certificate.

 

[Brad Z]

I hope you’re right, but I don’t see how it will help unless we also eliminate the Basic Med prerequisite to have held a medical. Or are you saying we just drop the medical requirement for PPLs altogether, like for SP?

Good question. When MOSAIC eventually comes along, we'll basically have three medial eligibility standards significantly overlapping the majority of light GA operations. What that will eventually morph into is anyone's guess.

 

[bbchien]

You only need to get the requested information up to the "Not valid for any class after" date on the medical certificate. Once you've submitted that, you're done. Make sure you revoke in writing any and all prior authorizations for your AME to share your protected health information with the FAA as well. Then walk away from the medical certificate.

You can wait until your medical is timed out before going BasicMed if you wish.

No issues doing solo or checkride as a student pilot. That's exactly how I did mine.

You can CFI on BasicMed. However, flying commercial and/or internationally will require a medical certificate.

and Jon, add to that the doctor's office. CAMI continues to interpret extraneous imofrmation recieved from helpful Hanna, after the last valid medical as "reapplication" and you know what happens after that....(just had that happen yet again).