Questions Regarding New Guidance.

Stegoo_86

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Stego_86
Hey All,

I had some general questions with SSRI use and the new guidelines. The new rules state that if you were deferred for being on an SSRI, but now have been off the meds for >2 years, you could see your AME, provide documentation, and possibly get your medical. In the past, you could stop taking the medication and be off of it for 60 days and then apply. Why does the new rule make this 2years? If it's a 1 off situation with no other diagnosis outside of GAD with no meds other than an approved SSRI, why could one just stop taking those meds for 60 days and then apply? I'm just trying to understand the logic here, is it because that airman was deferred?
 
it doesn’t do that. The only thing different is if you’ve been off >2 years, and If it’s NOT RECURRENT by diagnosis or by duration, and NOT MAJOR DEPRESSIVE DISORDER, the AME after review of all the supporting documents, can issue you.

To your question, if you are off for just 60 days, it gets deferred.
 
Hey, HIMS AME here. I'll try my best to unpack and unconfuse this policy, but keep in mind it's all VERY new and I'm still learning the intricacies myself.

Here is a BLOG POST I wrote about the policy when it first came out.

Here is a link to the disposition table for FAA Policy itself.

A few points to answer your questions:

* New policy was made specifically for airman that are CURRENTLY DEFERRED to give them a FAST TRACK to certification. But it can now be used for new exams.

* New policy allows for up to 2 different psychiatric diagnoses see list on links above.

* As stated above, the new policy does not apply to anyone with a previous or current diagnosis of MAJOR DEPRESSIVE DISORDER (MDD).

* Previous policy you are referring to is for anyone with a history of antidepressant use that did not meet criteria for 'situational depression' (single resolved episode AND treatment < 6 months). If an airman/applicant meets criteria for situational depression, the AME can issue a certificate on day of exam. Anyone that did not meet criteria for this pathway, had to be off meds x 60 days, still be deferred and was essentially going thru PATHWAY 1 of the Antidepressant protocol. This typically takes a long time to get certified and requires a lot of additional evals.

BLUF: If you're currently deferred and think you meet criteria for the FAST TRACK, schedule an exam with your AME or a solid HIMS AME and bring in all of your documentation/medical records with you. If your HIMS AME will go to bat for you they may be able to even call the FAA, upload all your docs and the decision tool worksheet and get you a verbal authorization. That's what I've been doing!

Good luck & Happy Flying
 
Hey, HIMS AME here. I'll try my best to unpack and unconfuse this policy, but keep in mind it's all VERY new and I'm still learning the intricacies myself.

Here is a BLOG POST I wrote about the policy when it first came out.

Here is a link to the disposition table for FAA Policy itself.

A few points to answer your questions:

* New policy was made specifically for airman that are CURRENTLY DEFERRED to give them a FAST TRACK to certification. But it can now be used for new exams.

* New policy allows for up to 2 different psychiatric diagnoses see list on links above.

* As stated above, the new policy does not apply to anyone with a previous or current diagnosis of MAJOR DEPRESSIVE DISORDER (MDD).

* Previous policy you are referring to is for anyone with a history of antidepressant use that did not meet criteria for 'situational depression' (single resolved episode AND treatment < 6 months). If an airman/applicant meets criteria for situational depression, the AME can issue a certificate on day of exam. Anyone that did not meet criteria for this pathway, had to be off meds x 60 days, still be deferred and was essentially going thru PATHWAY 1 of the Antidepressant protocol. This typically takes a long time to get certified and requires a lot of additional evals.

BLUF: If you're currently deferred and think you meet criteria for the FAST TRACK, schedule an exam with your AME or a solid HIMS AME and bring in all of your documentation/medical records with you. If your HIMS AME will go to bat for you they may be able to even call the FAA, upload all your docs and the decision tool worksheet and get you a verbal authorization. That's what I've been doing!

Good luck & Happy Flying
..and as long as you can show authoritively what the true diagnosis is (NOT major depressive disorder), it works.....
 
Thanks!

Unfortunately, I'm a bit more of a dope than I initially indicated. There is a bit of a time factor involved here as we are in the middle of buying a Baron. If it's going to be a year or so I would cancel the deal and eat the deposit, but if it's only a matter of months I would continue with buying the plane and have us fly with instructors while we wait. So any info here is GREATLY appreciated which brings me to 2 follow on questions:


1) Roughly how long does the process take in a worst case scenario?
2) What if she goes off the med totally; can she re-apply after x days without listing the past prescription?
 
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Thanks!

Unfortunately, I'm a bit more of a dope than I initially indicated. There is a bit of a time factor involved here as we are in the middle of buying a Baron. If it's going to be a year or so I would cancel the deal and eat the deposit, but if it's only a matter of months I would continue with buying the plane and have us fly with instructors while we wait. So any info here is GREATLY appreciated which brings me to 2 follow on questions:


1) Roughly how long does the process take in a worst case scenario?
2) What if she goes off the med totally; can she re-apply after x days without listing the past prescription?
Worst case- 18 months.
Decision path 1 (discontiuaition ) will not be available to her with a history of being on it for >5 years, or if there have been periods of off meds, then back on ("recurrence"). Recurrent disease untreated and unmonitored is 100% denied as it WILL recur, un-monitored in the future (as it will already have done so by history).

Now in 26 years of doing this I have ONE and only one exception. the HIMS psychiatrist after looking at my 48 y.o who had been on it for 9 years then off 3 years (from his PCP) recognized an "overly helpful" PCP and wrote "I find no evidnece that this man ever had anything. FAA barfed on it but an 20 months issued the tighest SI (highest mainentance/surveillance) requrimeents SI I had ever seen.
 
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Thanks!

Unfortunately, I'm a bit more of a dope than I initially indicated. There is a bit of a time factor involved here as we are in the middle of buying a Baron. If it's going to be a year or so I would cancel the deal and eat the deposit, but if it's only a matter of months I would continue with buying the plane and have us fly with instructors while we wait. So any info here is GREATLY appreciated which brings me to 2 follow on questions:


1) Roughly how long does the process take in a worst case scenario?
2) What if she goes off the med totally; can she re-apply after x days without listing the past prescription?
I'm a little confused about the described case. This is an airman/applicant current on an antidepressant or has history of use?

This has been my experience over the last year:

For a simple Pathway 2 antidepressant case it will be about 6 months for decision on special issuance once a full package is received by the FAS office in DC.

For a more complex case that is requiring a full psychiatric consultation/review at the FAS office in DC, this will take approx 1 year after receipt of a complete package.

***And again this can be longer if there is back/forth with FAA requesting more docs/evals etc...
 
Worst case- 18 months.
Decision path 1 (discontiuaition ) will not be available to her with a history of being on it for >5 years, or if there have been periods of off meds, then back on ("recurrence"). Recurrent disease untreated and unmonitored is 100% denied as it WILL recur, un-monitored in the future (as it will already have done so by history).

Now in 26 years of doing this I have ONE and only one exception. the HIMS psychiatrist after looking at my 48 y.o who had been on it for 9 years then off 3 years (from his PCP) recognized an "overly helpful" PCP and wrote "I find no evidnece that this man ever had anything. FAA barfed on it but an 20 months issued the tighest SI (highest mainentance/surveillance) requrimeents SI I had ever seen.
Bruce, regarding your comment "Decision path 1 (discontiuaition ) will not be available to her with a history of being on it for >5 years, or if there have been periods of off meds, then back on ("recurrence")" is this explicitly stated anywhere or just been your experience as a HIMS AME over many years? I agree that the EBM does show its like a 90% recurrence rate for depression in patients meeting these criteria so agree with the general sentiment...I've just never seen this written in FAA policy.

Thanks for your thoughts on this.
 
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