HIMS Special Issuance Timeline

J

Jon Wilder

Pre-takeoff checklist
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Greenville, SC
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Jwylde
Hi all.

Due to a couple of DUIs I got many years ago (one in 2003/BAC 0.12, another in 2008/BAC 0.13, being young dumb and stupid in my 20's), I'm being dragged through the HIMS process.

Prior to my initial AME physical appointment, March 3rd of 2020, I contacted CAMI/AMCD to find out what all I was going to need. They told me I would need to do an initial physical to start the deferment process. Bring with me a current copy of my driving record, a statement describing the offenses with BAC/my drinking habits at the time of the offense vs my drinking habits now, then mail it in along with the Med Xpress application to CAMI/AMCD.

The physical was done and all aforementioned documents were mailed off to CAMI/AMCD.

The first response, dated March 26th, 2020 -

"Due to your history of alcohol-related offenses, for further third-class medical certification consideration, you must provide the following for the Aerospace Medical Certification Division's review -"

Long and short - police narrative with BAC content, court records, and records associated with any care, treatment, or assessments/evaluations for alcohol abuse or related disorders.

I got what I could (had to get a letter from the arresting agencies stating they purge their records after 3 years, thus the reports were no longer available) and sent everything off to OK City.

The second response, dated January 5th, 2021 -

"For further consideration, please submit the following -

1. A current Substance Abuse Psychiatric Evaluation performed by a Human Intervention Motivation Study (HIMS) evaluator, in accordance with the psychiatric portion of the enclosed specifications."

Upon engaging with the HIMS Psychiatrist, he required that I complete 4 months of substance monitoring (10 panel w/ETG, 14 tests within a 12 month period) before he would even book the appointment. Upon his recommendation, I enrolled in the Test Day program with Choice Lab for this.

HIMS Psychiatrist advised me that even once I'd completed the 4 months of testing, to continue the testing until the FAA tells me to stop. Monitoring has been in place since February 2021 and has never been stopped. Thus, I now have clinical evidence of total abstinence going back to February 2021.

Upon completion of 4 months of testing (May 2021), the appointment was booked for July 19th, 2021. Substance abuse psych evaluation completed at the appointed date/time, and was submitted July 20th, 2021.

After several calls to regional, the FAA responded in a letter dated November 29th, 2021, with "For further consideration, please submit the following:"

They required that I am to engage with a HIMS AME for sponsorship and commencement of a monitoring program. Monitoring should consist at a minimum of:

Permanent abstinence from alcohol and from all mind or mood-altering substances is the expectation for the duration of your current and future airman medical certification eligibility;

Frequent, random, unannounced testing for alcohol consumption using standard medical testing methods (urine EtG/EtS, PEth testing, or a mobile alcohol monitoring system are preferred), at a frequency of no less than 14 tests in each 12 month period;

Standard peer support group activities (minimum twice a week);

Weekly INDIVIDUAL clinical aftercare/dependence counseling with a provider familiar treating substance use disorders;

HIMS AME face-to-face visits at 3 month intervals (half may be virtual);

Other requirements of the HIMS AME.

HIMS AME report following 3-4 months of monitoring.

I engaged with a HIMS AME on December 24th, 2021. Requests for my airman medical file were made for a copy to be sent to the HIMS AME. I also requested one for myself so that I could review the HIMS Psychiatrist report.

HIMS Psychiatrist's opinion summary stated -

"It is my opinion that the Airman is in good recovery.

I see no aeromedical matters of a psychiatric nature. However, it is my opinion that ongoing alcohol monitoring should be continued."

In his "Rationale for more concern", he stated -
"The airman has only 5 months of random negative testing thus far." (I had only been on the monitoring program for 5 months at this point)

I began attending AA immediately after engaging with the HIMS AME (actually went to my first meeting that night). I had a quarterly follow up with him on March 22nd, 2022. At this follow up, he stated to keep doing what I'm doing, and if everything still looks good at the next follow up, he'll submit his report.

2nd follow up was on June 24th, 2022. He then stated he would be submitting his report to the FAA.

Next follow up appointment scheduled for September 23rd, 2022.

My hope here is that the FAA responds with a Letter of Authorization for Special Issuance. Now that we're at this step, about how long does it take for the FAA to process from the time my AME submits the report to hearing back from the FAA? What is the likelihood that their next response will be a Special Issuance LOA?

Any help would be greatly appreciated.
 
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Please feel free to tell me it's none of my business, but is the weekly individual substance abuse counseling from now on or for a finite period of time?
 
Thanks all. Apparently there was a missing piece to the puzzle, and now I feel like I've wasted a month and a week.

Here is where we are at currently. Beware - long read.

I had my most recent HIMS follow up appointment with my HIMS AME on June 24th. At this appointment, he stated everything looks great and he will issue his report to the FAA.

My CFI informed me to let him know if I haven't heard from the FAA and it's been a month. I honestly thought that was kinda rushing it since the FAA seems to be about 2-4 months out in response time, but I digress.

After a month, I did as requested and informed my CFI (in light of everything, I'm VERY glad that I did). He spoke with a former AME friend of his, who referred him to a specific FAA agent, mentioning that she "might" be of help.

Upon contacting the agent, I said to her that at my recent HIMS follow up appointment, my AME stated that everything looks great and that he would send his report to the FAA. She informed me that they have not received anything since they sent me my last "For further consideration" letter requiring me to engage with the HIMS AME. Then...she proceeded to give me a "Let me explain how this works" speech, to which I said "Please do because I'm very new to this process and would like whatever straight answers you can give me."

So...she mentioned that due to my age (I was 40 at the time of my original application in February of 2020), the Med Xpress application that I have been working from has now expired. I informed her that I was aware of that and had thought that we were waiting on the FAA to grant an LOA for Special Issuance before we could do a new medical application and physical. To which she stated "Even if the HIMS AME had sent us anything, it would not have been the LOA you would receive, but you would have received another "For further consideration" letter because "Oh, by the way, your last Med Xpress application has expired due to age. Please submit another."

So I was under the impression that we do the first medical, which gets deferred. Then they request court records, then they request psych eval, then they request engagement with HIMS AME for sponsorship and monitoring, AME sends report, then they grant an LOA for special issuance, at which time I would then do a new medical application/physical and get a SI issued. Thus this whole time, I had thought my AME had sent his report in and we were waiting for that LOA. Turns out this is NOT the case.

She informed me to go online, fill out a new Med Xpress application, then schedule an appointment for a new/updated 3rd class physical with my HIMS AME. It's going to get deferred again, but now we take and send in my new medical, along with all of my monitoring, the HIMS AME's report, and will probably resend all of the same documents I sent on the last application to avoid any possible "Well that documentation got lost" scenario...all as one neat package. She also informed me that since the FAA is now expecting all of this to come through, and we're submitting a new medical application this time with everything they've asked for, as long as the FAA likes what they see, they should grant the special issuance and send your medical certificate along with the letter of authorization for special issuance. She also said that because they're waiting for it, it really shouldn't take any longer than 90 days once it has all been received.

So...I've submitted my Med Xpress application, noted my confirmation number, and scheduled my appointment for August 18th. With any luck, I should be sitting on a SI medical come November sometime.
 
once the FAA get your complete HIMS file, the HIMS AME's ck list, his narrative report and the completed medexpress application, it may take up to 6 months.
 
And that is why my approach is to do EVERYTHING ahead of the first application. That said I do have one “dual diagnosis” 3rd class that I have proactively re-examined to keep it live…..
 
bbchien said:
And that is why my approach is to do EVERYTHING ahead of the first application. That said I do have one “dual diagnosis” 3rd class that I have proactively re-examined to keep it live…..
Click to expand...

As I knew my 1st application would be deferred, I contacted AMCD to find out what I needed. They told me they couldn't tell me that until I started the application process and they received all of my paperwork from the AME.

I was completely unaware of anything HIMS until they requested the psych evaluation by a HIMS psychiatrist upon review of my court records.The request for the psych evaluation came almost a year after I began the process. COVID slowed a lot of things down as the courts were closed and I couldn't get my court records for some time.

There is a lot I wish I'd known prior to beginning this process that would've sped the whole thing up. Unfortunately this has been a learn as I go journey.
 
And that is why you engage someone "in the know" prior to your first application. Why would one ever go before a "board of inquiry" unprepared?
 
I've been with my HIMS AME now for 9 months (engaged with him December 24th), and was being monitored by a HIMS psychiatrist prior to engaging with the HIMS AME. Substance testing began on February 9th, 2021 through Choice Lab Inc. Release authorization was transferred to my HIMS AME with no gaps in monitoring. All results clean. Thus I now have 19 months provable abstinence from alcohol and all mind/mood altering substances. Began my AA attendance also on December 24th and have been in attendance twice a week from the start. I've also been on top of my quarterly AME follow up visits.

I did my physical on August 18th. Application and HIMS packet was transmitted on August 22nd. As of September 26th, my medical is now "In Review".

With any luck, I'll have a medical in hand within 60 calendar days. From there I can begin the solo phase of my flight training.
 
No amount of airplaning is worth this amount of government red tape. You ever tried boating?
 
Do you know what the total cost was for all of this treatment? Did you ever receive you special issuance medical certificate?
 
ttumat said:
Do you know what the total cost was for all of this treatment? Did you ever receive you special issuance medical certificate?
Click to expand...
In my specific case, once all was said and done, I was in about $10K-$11K. I received my HIMS SI medical certificate in July of 2023. It has since timed out and I am now flying on BasicMed.

Let me give you some advice I wish I had known before I started the process.

BEFORE YOU SUBMIT ANYTHING TO AN AME OR THE FAA -

Get established with a HIMS AME. DO NOT DO A MEDICAL APPLICATION AT THIS POINT!!! Set up a monitoring program with Choice Lab Inc or Soberlink. If going with Choice Lab Inc, tell them you want the FAA protocol 10-panel with EtG, and a testing frequency of not less than 28 tests per 12 month period. Authorize Choice Lab Inc to email test results to your HIMS AME.

Highly recommend you also get involved with and start working an AA program. Get a sponsor, do 90 meetings in 90 days, then attendance at a minimum of twice weekly thereafter.

You are going to do this for a period of not less than 24 months BEFORE you ever apply for a medical certificate.

AFTER TWO YEARS AND BEFORE YOU APPLY FOR YOUR MEDICAL CERTIFICATE -

Keep doing everything you are doing. Contact Ramos Law and retain attorney Joe LoRusso. He is going to give you a bunch of documentation to submit with your medical application.

DO NOT TRY TO DO THIS ON YOUR OWN!!!

I would also recommend setting up a consult with Joe LoRusso at Ramos Law before you do anything. He specializes in getting pilots out of the HIMS program.
 
Jon Wilder said:
BEFORE YOU SUBMIT ANYTHING TO AN AME OR THE FAA -

Get established with a HIMS AME. DO NOT DO A MEDICAL APPLICATION AT THIS POINT!!! Set up a monitoring program with Choice Lab Inc or Soberlink. If going with Choice Lab Inc, tell them you want the FAA protocol 10-panel with EtG, and a testing frequency of not less than 28 tests per 12 month period. Authorize Choice Lab Inc to email test results to your HIMS AME.

Highly recommend you also get involved with and start working an AA program. Get a sponsor, do 90 meetings in 90 days, then attendance at a minimum of twice weekly thereafter.

You are going to do this for a period of not less than 24 months BEFORE you ever apply for a medical certificate.

AFTER TWO YEARS AND BEFORE YOU APPLY FOR YOUR MEDICAL CERTIFICATE -
Click to expand...
^^^^ THIS ^^^^^

Sage advice. While 28 in 12 months for urine drug screens will certainly be sufficient the FAA will request 14 in 12 for most in the program. Dr. Chien may correct me if I have misspoken. Doing all the Jon suggested will put you in a position to get your SI quicker than waiting for the denial after having done none of the above. I would add that a consultation with a HIMS psychiatrist would be helpful if you can find one and they will give you an appointment without an FAA denial and SI path letter requesting such. I was lucky enough to have that done before I ever saw a HIMS AME but after I went at it on my own and received a deferral from an AME. If I had to do it over again I would have engaged a HIMS AME first and had followed the pathway outlined by Jon. All in all I had an 18mo process from receiving my denial letter until the third class special issue. I did have long term sobriety (12+ yrs documented by sponsors) and completion of a Tx program prior to that. I also had character witness letters from a couple of ATP's and others. WHen I saw the HIMS AME he responded that he has never seen anyone that came to him with all their ducks in a row and he recommended issue in his letter to the FAA after the first appt. Of course it was not approved until after 4 months of urine screens since that was the only missing piece of the puzzle.
 
robin ardoin said:
^^^^ THIS ^^^^^

Sage advice. While 28 in 12 months for urine drug screens will certainly be sufficient the FAA will request 14 in 12 for most in the program. Dr. Chien may correct me if I have misspoken. Doing all the Jon suggested will put you in a position to get your SI quicker than waiting for the denial after having done none of the above. I would add that a consultation with a HIMS psychiatrist would be helpful if you can find one and they will give you an appointment without an FAA denial and SI path letter requesting such. I was lucky enough to have that done before I ever saw a HIMS AME but after I went at it on my own and received a deferral from an AME. If I had to do it over again I would have engaged a HIMS AME first and had followed the pathway outlined by Jon. All in all I had an 18mo process from receiving my denial letter until the third class special issue. I did have long term sobriety (12+ yrs documented by sponsors) and completion of a Tx program prior to that. I also had character witness letters from a couple of ATP's and others. WHen I saw the HIMS AME he responded that he has never seen anyone that came to him with all their ducks in a row and he recommended issue in his letter to the FAA after the first appt. Of course it was not approved until after 4 months of urine screens since that was the only missing piece of the puzzle.
Click to expand...
28 in 12 was suggested by Joe LoRusso. He explained that while the FAA requirement is 14 in 12, apparently when the airman has taken it upon themselves to establish their own monitoring program, the FAA has actually argued "Well you can plan around that". Doing 28 in 12, since EtG goes back 2 weeks, there's no way they can possibly argue it.
 
insofar as abstinence is concerned, ETG does not go back 2 weeks. The same goes for peth.

Joe, like the faa, does not seem to understand how this works.

It’s a shell game seemingly designed to placebo the public into thinking the faa has mitigated a safety issue….

“Hush little baby, don’t say a word.. never mind the noise you heard. It’s just the beast under your bed, in your closet, IN YOUR HEAD”

It’s a self fulfilling prophecy really. You really need to hire a lawyer like Joe to placebo the faa.
 
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