SI renewal turns into alcohol history inquiry

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FatherPilot

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Pilot for 13 years now; just came back from a 5 year break from flying. My 3rd class medical application was deferred in October 2021 due to previous treatment for depression and SSRI use. I complied with the FAA letter requesting all records and in March 2022 received a 6 month SI.

I began the renewal process, got in all my paperwork by September and waited for my next 6 month SI.

On Thanksgiving Day i got a new certified FAA letter, never a great feeling. They were requesting new information due to my history of alcohol abuse disorder. This took me completely by surprise, as I had not been treated for substance abuse only depression. FAA want how long i have been sober, treatment history, personal letter statement, and if applicable letters from a sponsor/priest or someone familiar with my recovery.

I checked with my Psychiatrist, nothing new had been recorded in recent meetings. The trigger must have been in our sessions almost 3 years ago where during my depression i was consuming alcohol every night, how alcohol is a depressant, how i should reduce alcohol consumption to feel better, etc. That was the worst evidence i could find of alcohol abuse in my history. It was not a major point of discussion in my treatment of depression going forward to this day.

I intend to comply with the FAA request as best I can. I was never admitted to any program or hospital for alcohol treatment, the only medical care i received was for depression from my psychiatrist. I have no sponsor or AA record. I have no one to write letters on my behalf describing my recovery. I can write a personal letter, though. I greatly reduced drinking during my therapy, further reduced it later, and went alcohol free 16 months ago and have been extremely happy with the results.

What can i expect to happen next from the FAA? Will i 100% be put on the HIMS train for life with testing and monitoring? I expect the worst, more records requests and waiting, and possible denial. Any advice i will take to heart.

Coda: i recognize now i should have let my SI quietly expire and go Badic Med. I should have gone Basic to begin with, as i had an expired 3rd class from 5 years ago before the depression incident. Sigh......
 
I would request your blue ribbon file from the FAA, “with applicant notes” and see what is really in there from your psychiatrist. My guess would be some form of monitoring (14 in 12 months urine tests). Something rung the “abuse bell” and it likely cannot be un-rung without evidence of “recovery”. I had a sort of similar situation (without knowing details) which took 2 and a half years to get released. A lot depends on your exact situation and full history. PM me if you want more details on mine. Alcohol and the FAA are not a good mix.
 
Half Fast said:
Once you get through these hoops and have your SI again, why not go to Basic Med? It’s a good way to avoid the FAA roulette wheel.
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That is the hope! I was out of the flying scene from 2016-2021 and did not know BasicMed existed when I applied for a new third class. Then I wrongly assumed after getting my first SI the renewals would be easy. Painful lessons.
 
RussS said:
I would request your blue ribbon file from the FAA, “with applicant notes” and see what is really in there from your psychiatrist. My guess would be some form of monitoring (14 in 12 months urine tests). Something rung the “abuse bell” and it likely cannot be un-rung without evidence of “recovery”. I had a sort of similar situation (without knowing details) which took 2 and a half years to get released. A lot depends on your exact situation and full history. PM me if you want more details on mine. Alcohol and the FAA are not a good mix.
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I will definitely do the FOIA request for my jacket to see what they have. I am also consulting AOPA legal services to help formulate the best package response to their new request, my best chance to minimize the requirements they might come back at me with.
 
FatherPilot said:
I checked with my Psychiatrist, nothing new had been recorded in recent meetings. The trigger must have been in our sessions almost 3 years ago where during my depression i was consuming alcohol every night, how alcohol is a depressant, how i should reduce alcohol consumption to feel better, etc.
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AOPA isn't going to be of any real help.

If you used insurance to pay for the psychiatrist they had to submit the claims through electronic billing. The insurance reimburses based on the ICD-10 codes that are transmitted in the electronic claim. Insurance will only pay for medically necessary procedures, which means the corresponding diagnosis code for the procedure must exist on the claim. If the psychiatrist sought reimbursement for treating your substance abuse/dependence (in addition to depression) they'd have to add the abuse/dependence ICD-10 to your chart to get paid. Once that code ends up on your chart you have been formally diagnosed with the condition.

Of course there's also the less complex possibilities that the psychiatrist determined you had alcohol use disorder and noted your chart as such, or that someone at the FAA read the notes and became concerned.

Either way, at this point you're committed. You have an open medical application that will either be issued, denied, or withdrawn. Anything but an issued medical and BasicMed isn't an option until you do get issued. The fact that they stated substance abuse rather than dependence is a good thing. Once you are diagnosed dependent you are dependent for life. Dependence is the path that leads to HIMS in some form for life and extended monitoring.

Here's what I'd do:
1. Get a copy of your completed medical record (including ICD-10s) from the Psychiatrist so you know exactly what the FAA has. Look for diagnosis codes F10.10-19 or F10.20-29 or F10.90-99
2. As others have stated, request your complete medical record from the FAA. You're not going to get this back in time to respond to their request letter, but at least you'll be looking at what they're looking at.
3. Consider paying a HIMS AME to do a consultative review of the medical records from your provider(s). Dr. Chien or Dr. Fowler would be excellent choices. Do what they tell you to do.
4. Be very careful about how you word any personal statement you send to the FAA. Be factual, honest, and direct. A misstatement can convert the FAA abuse assertion to a dependence assertion.
5. Unless the FAA specifically states they must receive medical records directly from a provider, NEVER let someone send your medical records directly to the FAA. Obtain them from the provider, make copies, review for accuracy, and then send them.
 
ThatOtherGuy said:
AOPA isn't going to be of any real help.

If you used insurance to pay for the psychiatrist they had to submit the claims through electronic billing. The insurance reimburses based on the ICD-10 codes that are transmitted in the electronic claim. Insurance will only pay for medically necessary procedures, which means the corresponding diagnosis code for the procedure must exist on the claim. If the psychiatrist sought reimbursement for treating your substance abuse/dependence (in addition to depression) they'd have to add the abuse/dependence ICD-10 to your chart to get paid. Once that code ends up on your chart you have been formally diagnosed with the condition.

Of course there's also the less complex possibilities that the psychiatrist determined you had alcohol use disorder and noted your chart as such, or that someone at the FAA read the notes and became concerned.

Either way, at this point you're committed. You have an open medical application that will either be issued, denied, or withdrawn. Anything but an issued medical and BasicMed isn't an option until you do get issued. The fact that they stated substance abuse rather than dependence is a good thing. Once you are diagnosed dependent you are dependent for life. Dependence is the path that leads to HIMS in some form for life and extended monitoring.

Here's what I'd do:
1. Get a copy of your completed medical record (including ICD-10s) from the Psychiatrist so you know exactly what the FAA has. Look for diagnosis codes F10.10-19 or F10.20-29 or F10.90-99
2. As others have stated, request your complete medical record from the FAA. You're not going to get this back in time to respond to their request letter, but at least you'll be looking at what they're looking at.
3. Consider paying a HIMS AME to do a consultative review of the medical records from your provider(s). Dr. Chien or Dr. Fowler would be excellent choices. Do what they tell you to do.
4. Be very careful about how you word any personal statement you send to the FAA. Be factual, honest, and direct. A misstatement can convert the FAA abuse assertion to a dependence assertion.
5. Unless the FAA specifically states they must receive medical records directly from a provider, NEVER let someone send your medical records directly to the FAA. Obtain them from the provider, make copies, review for accuracy, and then send them.
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This is great info. I checked my FAA letter, they state my history of Alcohol Use Disorder is the concern. That term is also used on my Psych's appointment notes, never dependence. The next paragraph of FAA letter is an FYI..."part 67 requires evidence of recovery for applicants with established history or clinical diagnosis of substance dependence...etc"

I don't know if this indicates they have categorized me as such, or an explanation that they are trying to determine if this is the case since I had a period of abuse.

I will work on those diagnosis forms from my Psych (which I paid 100% out of pocket I am sure).

Thank you for the straight shooting info!
 
FatherPilot said:
This is great info. I checked my FAA letter, they state my history of Alcohol Use Disorder is the concern. That term is also used on my Psych's appointment notes, never dependence. The next paragraph of FAA letter is an FYI..."part 67 requires evidence of recovery for applicants with established history or clinical diagnosis of substance dependence...etc"

I don't know if this indicates they have categorized me as such, or an explanation that they are trying to determine if this is the case since I had a period of abuse.

I will work on those diagnosis forms from my Psych (which I paid 100% out of pocket I am sure).

Thank you for the straight shooting info!
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Glad I can help.

Additional bit of advice. Remember that your psychiatrist and the FAA are speaking different language when they use the terms "alcohol dependence", "alcohol abuse", and "substance use disorder". The standards used for diagnosing mental health issues by everyone but the FAA is the DSM-V. The predecessor to the DSM-V was the DSM-IV. It included diagnoses for "alcohol abuse" and "alcohol dependence". The DSM-V uses the term "Alcohol Use Disorder" with an additional modifier of "mild", "moderate", or "severe". Your psychiatrist is most likely charting using language and criteria seen in DSM-V.

The FAA uses criteria defined in the FARs for substance issues. Airmen with substance issues will either be classified into "substance abuse" or "substance dependence". The definitions and criteria are laid out in 14 CFR 67.307(a)(4) and 14 CFR 67.307(b).

It's important to keep this in mind because the FAR criteria for abuse or dependence are much more strict than the DSM-V criteria used by the general medical community. When reading FAA communications or personal medical records remember the context of the writer. The implication is that the FAA doesn't care about your DSM-V diagnosis. They care about your FAR diagnosis. For example, you can be diagnosed as "Alcohol Use Disorder - Mild" (DSM-V) and still meet the criteria for FAR "alcohol dependence".

Good luck!
 
If the Letter sez "abuse disorder" there was enough in the for the agency to tell you that.

Now the question is:
Are you now abstinent-
if so can you substantiate that?

Asking your local psychiatrist for commentary isn't going to do a whole lot of good as he plainly does not understand part 67.

You're going to need to get to a HIMS AME, start a private random test program, then slow roll the responses, buy the time you get to 4 months provably sober, get to the HIMS psychiatrist after 4 months sober and it'll fit (just from what you wrote) into abuse. You'll be given an SI for two years of abstinence and then it'll be over.

Sigh.
 
Of course, it's not the first time the FAA misread something. I had them misinterpret a statement of "no signs of xxx" to mean that I did have xxx and spent two years fighting it before they finally sent me a letter essentially saying, "OK, you don't have xxx. But if you ever do get xxx stop flying and let us know." Of course, I'm no more likely to get xxx than the next person.
 
flyingron said:
Of course, it's not the first time the FAA misread something. I had them misinterpret a statement of "no signs of xxx" to mean that I did have xxx and spent two years fighting it before they finally sent me a letter essentially saying, "OK, you don't have xxx. But if you ever do get xxx stop flying and let us know." Of course, I'm no more likely to get xxx than the next person.
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There was a letter in an AME journal in which a Duke University medical professor took the FAA to task because it forced an individual to prove they did not have a disease based solely on the existence of a genetic marker. The response to the letter was a bunch of self justification which came down to, "what do you expect us to do when an applicant is truthful?"
 
UPDATE: I got my SI medical for anxiety/depression SSRI renewed, let it time out and am now on Basic Med.

I hired an aviation attorney. They helped me write my personal statement which I feel was key in receiving a favorable outcome. For my situation, they only required a CogScreen AE from a HIMS psychiatrist, in addition to a surprise drug/alcohol test within 48 hours of receipt of certified letter. Clean test, passed Cog, received SI within 60 days of submission.

It was a hard decision to give up on my hard fought 3rd class, but I decided any flying was better than no flying if OKC ever looked at me sideways again. I had a dream of becoming a CFI in my semi retirement, but shelved that in favor of Basic Med freedom.

I spent two solid years under OKC certified letters, spent $2500 on CogScreen, $1000 on an attorney plus a couple hundred on 6 month psych visits. I understand it is their game, their rules, largely due to public pressure and paranoia about flying safety. I am so grateful to survive OKC and for the existence of Basic Med.

Never apply for a medical without certainty of the outcome. MedExpress is the equivalent of signing up for Stephen King's The Long Walk...once it starts, either finish or die. I will forever be in fear of little green labels in my mailbox!
 
You can indeed become and act as a CFI under Basic Med. Get your IR and Commercial done first of course. Both BTW also only need Basic Med as well - although you can’t act as or get paid as a commercial under Basic - but you can still get the rating.
 
Even without a medical, you can still be a CFI in gliders, or in airplanes as long as your student can act as PIC.
 
Lindberg said:
Even without a medical, you can still be a CFI in gliders, or in airplanes as long as your student can act as PIC.
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Good news everyone - you can become a CFI under Basic Med and act just like a CFI who has a 3rd class.

You can teach student pilots who don’t have to act as PIC.
 
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FatherPilot summed up a very important lesson well: "Never apply for a medical without certainty of the outcome." Most medical issues can be overcome with the right documentation, but it's much more efficient to have the documentation ready BEFORE your AME exam. Getting deferred and waited to the FAA to ask for more information drags out the process significantly.

If you check "yes" to anything on MedXPress, make sure you know what the implications will be and get medical records to mitigate the consequences BEFORE your AME exam.
 
Or better yet - as Father Pilot pointed out in 1st post - take the extra time to determine if you can go Basic Med from the start and just avoid the SI complications.
 
WDD said:
Good news everyone - you can become a CFI under Basic Med and act just like a CFI who has a 3rd class.
Click to expand...

Well, not completely "just like", but pretty close for most light GA purposes, and most typical "CFI retirement gig" uses.

Most typical light GA instructional scenarios are not an issue. However, if you as the CFI need to act as PIC, then the aircraft has to meet the Basic Med requirements. So if you're doing a flight review for someone who is out of FR currency, then the plane has to meet the requirements. Or if they're not IFR current (or even not IFR rated) and they want to get some actual instrument time, then again the plane needs to meet the Basic Med requirements. And a few other similar scenarios.

Some of the larger light GA twins are more than 6000 pounds max gross.
Similarly, any plane with 7 or more seats doesn't meet Basic Med.

So, probably not too limiting for the OP, but something to be aware of when the owner of a Cessna 340 with the Ram IV STC asks for a flight review and it's been 25 months since their last one. Or the plane is a PA-32 with the 7th seat option, even if not installed, without the "revert to a 6-seater" STC.
 
FatherPilot said:
UPDATE: I got my SI medical for anxiety/depression SSRI renewed, let it time out and am now on Basic Med.

I hired an aviation attorney. They helped me write my personal statement which I feel was key in receiving a favorable outcome. For my situation, they only required a CogScreen AE from a HIMS psychiatrist, in addition to a surprise drug/alcohol test within 48 hours of receipt of certified letter. Clean test, passed Cog, received SI within 60 days of submission.

It was a hard decision to give up on my hard fought 3rd class, but I decided any flying was better than no flying if OKC ever looked at me sideways again. I had a dream of becoming a CFI in my semi retirement, but shelved that in favor of Basic Med freedom.

I spent two solid years under OKC certified letters, spent $2500 on CogScreen, $1000 on an attorney plus a couple hundred on 6 month psych visits. I understand it is their game, their rules, largely due to public pressure and paranoia about flying safety. I am so grateful to survive OKC and for the existence of Basic Med.

Never apply for a medical without certainty of the outcome. MedExpress is the equivalent of signing up for Stephen King's The Long Walk...once it starts, either finish or die. I will forever be in fear of little green labels in my mailbox!
Click to expand...
I always ask: Do you want the FAA to be the first to read EVERY word in your file.
Moral: Alway have someone knowledgable READ every word of your file. I find SAMSHA "heavy drinking" in amazing places even in PCP records.
Let the buyer beware, they read EVERY WORD.
 
bbchien said:
I always ask: Do you want the FAA to be the first to read EVERY word in your file.
Moral: Alway have someone knowledgable READ every word of your file. I find SAMSHA "heavy drinking" in amazing places even in PCP records.
Let the buyer beware, they read EVERY WORD.
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They read every word yet there memos are loaded with major mistakes.
 
WDD said:
Or better yet - as Father Pilot pointed out in 1st post - take the extra time to determine if you can go Basic Med from the start and just avoid the SI complications.
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You have to have held a Class medical certificate at some point to go Basic Med. You can NOT do it from the start.

You can fly Sport Pilot without ever having a medical.
 
bbchien said:
I always ask: Do you want the FAA to be the first to read EVERY word in your file.
Moral: Alway have someone knowledgable READ every word of your file. I find SAMSHA "heavy drinking" in amazing places even in PCP records.
Let the buyer beware, they read EVERY WORD.
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This is a classic example of using ICD10 codes inappropriately. As I've stated before on this forum, we use ICD10 codes to justify billing, justify certain tests, meds, labs etc. Its a broken system, especially since there isn't always an ICD10 code that matches what the diagnosis is and we have to shoehorn into something similar. In addition, 10s to hundreds of ICD10 codes get thrown into a chart during a hospital admission, many are inaccurate or in error, but if the treating physician doesn't have the time or care to delete the inaccurate ones, they just get inactivated but stay in medical record forever. Once the FAA starts linking up their database to big hospital EMR systems like Cerner, Epic, etc just wait for all of these issues to happen to everyone. My advice- go Basic Med now and never look back unless you absolutely need a medical for a career. And if you do, stay as far away from traditional physicians and hospitals as possible. Pay cash for any medical care, and insist that the physician not submit to insurance, or even better find one that still uses old school paper charts. And I am speaking as a licensed physician and pilot.
 
bbchien said:
I always ask: Do you want the FAA to be the first to read EVERY word in your file.
Moral: Alway have someone knowledgable READ every word of your file. I find SAMSHA "heavy drinking" in amazing places even in PCP records.
Let the buyer beware, they read EVERY WORD.
Click to expand...
THIS exactly. On intake appointment, scribbled down the page after all the depression and anxiety verbiage was "ETOH Abuse" off to the side. That was missed by me, and apparently by OKC on their approval of my first SI. They saw it 6 months later when I (stupidly) renewed the medical...starting an extra year long slog to getting approved. Fun times!
 
Tokirbymd said:
My advice- go Basic Med now and never look back unless you absolutely need a medical for a career.
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Having a commercial certificate was nice while it lasted, even with the headaches involved in entering the FAA medical treadmill, but now for me it's just not worth the risk of falling into another one of their pitfalls. I wonder how many other pilots with commercial certificates have elected to revert to private pilot privileges. Does anyone know if that data exists?

Other than those flying excluded aircraft, is there really any good reason for a private pilot to continue applying for a class 3 medical anymore?
 
dbahn said:
Other than those flying excluded aircraft, is there really any good reason for a private pilot to continue applying for a class 3 medical anymore?
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I notice you have colored in provinces on your signature map. So, yes.
 
dbahn said:
Other than those flying excluded aircraft, is there really any good reason for a private pilot to continue applying for a class 3 medical anymore?
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-Not allowed to fly in to canada
-plenty of HP/Complex planes - especially pressurized that insurance now requires a class 1,2,3 medical

and obviously if you move up to anything beyond 6K (like twins) - but that falls under excluded aircraft.

catmandu said:
I notice you have colored in provinces on your signature map. So, yes.
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Haha thats funny. So yeah - those places above that you have flown to already.. . .
how do you get one of those nice colored maps with places flown anyhow ?
 
catmandu said:
I notice you have colored in provinces on your signature map. So, yes.
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Yes, that’s a downside currently but may change soon. But flying in Canada has also changed significantly in the past five or ten years and is not nearly as attractive as it was in the more distant past. I have fond memories . . .
 
Anthem said:
.....
-plenty of HP/Complex planes - especially pressurized that insurance now requires a class 1,2,3 medical

and obviously if you move up to anything beyond 6K (like twins) - but that falls under excluded aircraft.
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I'm sure there might be some cases where it's true, but the idea of HP/Complex planes or twins not accepting BasicMed is not true IME.

FWIW, I just insured a Seneca under BasicMed. None of the quotes had a problem with it.
 
jbarrass said:
I'm sure there might be some cases where it's true, but the idea of HP/Complex planes or twins not accepting BasicMed is not true IME.

FWIW, I just insured a Seneca under BasicMed. None of the quotes had a problem with it.
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I dont believe the seneca is high performance. Nor is it pressurized.
But there was just a threat a few weeks back here of people who are being told they need to have a medical cert for insurance to bind. Basic Med would NOT be acceptable. So like I said - for things like piper m600/500/350/meridian type planes, for Cessna 210's and especially P210's - that requirement is coming down and coming down fast. I can quote you my insurance clause as well.

As for bigger twins (cessna 340/414/421/navajo/king airs - those are mostly excluded as BM doesnt cover those. But those are mandatory as well.
Also you are limited to < 18k altitude with BM, which severely limits any pressurized capable plane.

and here you go - the previous discussion on insurnace requiring medical certs. Im not alone, as its definitely happeneing.
pilotsofamerica.com

Warning: Insurance renewal and medical type

I got a quote to renew my insurance that gave me a choice of two carriers. I could stay with my current insurer (AIG) or go with a new carrier. They were within $20 of each other and the coverage was similar. I've never had a claim so I haven't had any interactions that would lead me to pick...
pilotsofamerica.com pilotsofamerica.com
 
Seneca is certainly HP and complex, but not pressurized.

Believe what you will. BasicMed works well for me and 80,000 other pilots.
 
jbarrass said:
Seneca is certainly HP and complex, but not pressurized.

Believe what you will. BasicMed works well for me and 80,000 other pilots.
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FAA definition of high performance since 1987

“an airplane with an engine of more than 200 horsepower”

So completely depends on which model Seneca. Some are and some aren’t.

And not sure what your issue is - I have basic med. I also have a class 3. Im just telling you there are planes that are within basic med category planes that insurance companies will not accept. Others are reporting the same. If you don’t want to believe that - then believe what you will. Smh.
 
dbahn said:
Yes, that’s a downside currently but may change soon. But flying in Canada has also changed significantly in the past five or ten years and is not nearly as attractive as it was in the more distant past. I have fond memories . . .
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What has changed? My first flight to Canada was over 15 years ago and most recently last month. I haven't noticed significant changes.
 
MRC01 said:
What has changed? My first flight to Canada was over 15 years ago and most recently last month. I haven't noticed significant changes.
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Security has tightened, but much of that happened since the 911 attack. (Many of my crossings were before that.) But fuel availability can be an issue at smaller airports and prices are high. My most recent trips through Canada were 2017 and 2018 and customs, fuel, and lodging were all considerably more challenging and less "forgiving" than previously. A friend that flew from Vermont to Alaska last month vowed that he would never do that again . . .
 
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