SI to Basic Med

[UTLonghorn_1979]

Apologies in advance for any redundancy, I am getting conflicting information from my HIMS AME about going BM after SI for SSRI initial deferral.

I've been on a SSRI since 2020, I'd like to get off of it as I'm also no longer drinking and I think the anxiety was exacerbated/caused by the alcohol consumption - been sober almost 9 months. I don't think I need to be on the SSRI anymore. Also, because of my communication to the prescribing Dr. for the SSRI, I had to go through a further alcohol HIMS process. I've been in the deferral process for over 2 years and it's back with the FAA under review.

My understanding is my SSRI use is considered recurrent so I need to be off of it for 2 years before reapplying for class 3 non-SI. My HIMS AME is saying 6 months. They also think that I can't apply for BM and that if I don't adhere to the SI FAA requirements that it will cause issues with my SI. Almost like I have to stay on the SSRI for ever, or sit it our 2 years.

Anyone have clarity on this? It's super confusing and not 100% adhering to the correct process just prolongs the issues. Specific questions:

1. Once issued SI for SSRI, can I immediately apply for BM and move to that from my SI class 3 and let the class 3 SI expire?
2. What do I need to do and when to transfer to BM and make sure I don't get back into the FAA medical process inadvertently?
3. Can I stop the SSRI while operating under BM and keep flying under BM?
4. Is the timing to reapply for unrestricted class 3 off of SSRI 6 months or 2 years?
5. Due to the alcohol HIMS portion, would I need to keep doing the random drug testing and AA logs? I intend to stay sober and keep going to AA regardless.
6. Can I continue to operate under BM until the new class 3 is processed/issued? I know this was a question with the new FAA denial vs. defer ruling.

I'd like my HIMS AME and they have been helpful through this initial process. I just didn't walk away with any clarity on next steps and after 2 years of already working through this process, I'm nervous about things getting screwed up with the FAA.

Thanks!

 

[flyingron]

You can let the "not valid for any class after mm/yy" medical you got expire and do basic med. Until it expires you need to comply with anything the FAA told you that you need lest they revoke the thing. Once you are no longer covered by an unexpired medical, you can operate solely by the basic med rules. If your doctor thinks you should d/c or change your meds, that's between you and him.

 

[UTLonghorn_1979]

You can let the "not valid for any class after mm/yy" medical you got expire and do basic med. Until it expires you need to comply with anything the FAA told you that you need lest they revoke the thing. Once you are no longer covered by an unexpired medical, you can operate solely by the basic med rules. If your doctor thinks you should d/c or change your meds, that's between you and him.

Thank you. Guess I'll wait until, hopefully, I get my SI, then start making plans for BM. I'm just nervous that the process of transitioning from SI to BM will be messed up by me or my HIMS AME due to not being familiar with that process.

 

[Jon Wilder]

STOP LISTENING TO THE AME'S ABOUT BASICMED!!!

None of them like it and all of them are going to tell you that you can't do it on a SI. Yes I know there are exceptions but 95% of them are going to tell you this. If you're not continually renewing the medical, they don't get paid. Thus they have financial incentive to tell you this crap.

This is the official FAA BasicMed site. Scroll down to "Medical Conditions Requiring One Special Issuance Before Operating On BasicMed".

https://www.faa.gov/licenses_certificates/airmen_certification/basic_med

I will also reference Domingo (once again) -

https://www.faa.gov/media/11051

Their window to withdraw a special issuance authorization closes once the underlying medical certificate expires. Period. @Brad Z has stated this on here several times as well.

 

[UTLonghorn_1979]

STOP LISTENING TO THE AME'S ABOUT BASICMED!!!

None of them like it and all of them are going to tell you that you can't do it on a SI. Yes I know there are exceptions but 95% of them are going to tell you this. If you're not continually renewing the medical, they don't get paid. Thus they have financial incentive to tell you this crap.

This is the official FAA BasicMed site. Scroll down to "Medical Conditions Requiring One Special Issuance Before Operating On BasicMed".

https://www.faa.gov/licenses_certificates/airmen_certification/basic_med

I will also reference Domingo (once again) -

https://www.faa.gov/media/11051

Their window to withdraw a special issuance authorization closes once the underlying medical certificate expires. Period. @Brad Z has stated this on here several times as well.

I appreciate the feedback. What’s the solution then? Who do you work with to make sure you comply with the rules of moving from under the eye of the FAA to not?

Side note, how is that not some sort of malpractice if AMEs, if this is indeed the case, are knowingly giving you wrong advice, or negligently/unknowingly giving you wrong advice?

I’m not looking to open up a can of worms here (I have indeed turned over a new leaf), it’s just crazy that after 8 years it’s still not clear.

Thanks!

 

[midlifeflyer]

Side note, how is that not some sort of malpractice if AMEs, if this is indeed the case, are knowingly giving you wrong advice, or negligently/unknowingly giving you wrong advice?

The easiest answer is, AMEs are not your doctor. Their medical obligation is to the FAA, not to you.


(LOL "Probate Court" before edit is due to a keyboard macro combined with my poor typing skills)

 

[UTLonghorn_1979]

The easiest answer is, AMEs are not your doctor. Their medical obligation is to the FAA, not Probate Court you.

Interesting.

 

[TCABM]

Interesting.

AMEs designees are no different than Designated Pilot Examiners in that they serve the FAA, not the candidate. They are designated the agency’s authority to decision candidates against the applicable ‘rulebooks’.

What’s interesting about that?

 

[UTLonghorn_1979]

AMEs designees are no different than Designated Pilot Examiners in that they serve the FAA, not the candidate. They are designated the agency’s authority to decision candidates against the applicable ‘rulebooks’.

What’s interesting about that?

it’s interesting that your only option as a guide/advocate through the process, really isn’t either. I’m speaking of HIMS AMEs...

it’s interesting that the experience of many is that the AMEs aren’t familiar with said “rulebooks” or are intentionally midleading applicants.

I find this very interesting.

 

[TCABM]

it’s interesting that your only option as a guide/advocate through the process, really isn’t either. I’m speaking of HIMS AMEs...

it’s interesting that the experience of many is that the AMEs aren’t familiar with said “rulebooks” or are intentionally midleading applicants.

I find this very interesting.

Not sure what you mean by only option as a guide comment.

An applicant can engage a willing AME as a consultant. There are also other advocates that someone can engage as well as the ALE guide, dispositions, notes, and the underlying CFRs that are freely available.

The only real ‘gotchas’ are the an applicant isn’t aware of these things up front and doesn’t understand once an AME takes an application ‘live’ that genie can’t be put back in the bottle.

 

[UTLonghorn_1979]

Not sure what you mean by only option as a guide comment.

An applicant can engage a willing AME as a consultant. There are also other advocates that someone can engage as well as the ALE guide, dispositions, notes, and the underlying CFRs that are freely available.

The only real ‘gotchas’ are the an applicant isn’t aware of these things up front and doesn’t understand once an AME takes an application ‘live’ that genie can’t be put back in the bottle.

Everything I’m replying to is in the context of the HIMS process and SI, The HIMS AME is one’s ONLY guide for the process. I’m also responding to the below.

STOP LISTENING TO THE AME'S ABOUT BASICMED!!!

None of them like it and all of them are going to tell you that you can't do it on a SI. Yes I know there are exceptions but 95% of them are going to tell you this. If you're not continually renewing the medical, they don't get paid. Thus they have financial incentive to tell you this crap.

This is the official FAA BasicMed site. Scroll down to "Medical Conditions Requiring One Special Issuance Before Operating On BasicMed".

https://www.faa.gov/licenses_certificates/airmen_certification/basic_med

I will also reference Domingo (once again) -

https://www.faa.gov/media/11051

Their window to withdraw a special issuance authorization closes once the underlying medical certificate expires. Period. @Brad Z has stated this on here several times as well.

 

[midlifeflyer]

it’s interesting that your only option as a guide/advocate through the process, really isn’t either. I’m speaking of HIMS AMEs...

That's not really true. Your other guide/advocate option is hiring someone as a guide/advocate. Someone who does have an obligation to you. Bruce does that. Lou Fowler in Florida I think still does that. It's Wingman Med's business model.

it’s interesting that the experience of many is that the AMEs aren’t familiar with said “rulebooks” or are intentionally midleading applicants.

I find this very interesting.

Sometimes it's choice. I don't remember where I saw it, but there was a recent interview with one of the principals of Wingman Med. One of the things he talked about is situations in which the AME is able to issue rather than defer. Sometimes the AME defers in those situations simply to avoid the extra work. Sometimes it's simple appointment spacing. Sometimes lack of experience with a specific medical area. Not being paid for the extra work involved is yest another.

Also made a few recommendations, some of which overlap. Advance consult is an obvious one. Informing the AME ahead of time that you have an issue that may need more time is another. Offering to paying for the extra work is yet another.

Ultimately, an FAA medical exam is a checkride. Prepare for it the same way you prepare for a certificate or rating one. That was the Wingman discussion bottom line. It became mine 25 years ago when my AME informed me that a newly-reported condition was disqualifying. (I was fortunate; he did the extra work to issue rather than defer.)

In the HIMS situation, that can mean a lot of expense. But that may mean an initial discussion with the HIMS AME about how they see their role.

 

[UTLonghorn_1979]

That's not really true. Your other guide/advocate option is hiring someone as a guide/advocate. Someone who does have an obligation to you. Bruce does that. Lou Fowler in Florida I think still does that. It's Wingman Med's business model.


Sometimes it's choice. I don't remember where I saw it, but there was a recent interview with one of the principals of Wingman Med. One of the things he talked about is situations in which the AME is able to issue rather than defer. Sometimes the AME defers in those situations simply to avoid the extra work. Sometimes it's simple appointment spacing. Sometimes lack of experience with a specific medical area. Not being paid for the extra work involved is yest another.

Also made a few recommendations, some of which overlap. Advance consult is an obvious one. Informing the AME ahead of time that you have an issue that may need more time is another. Offering to paying for the extra work is yet another.

Ultimately, an FAA medical exam is a checkride. Prepare for it the same way you prepare for a certificate or rating one. That was the Wingman discussion bottom line. It became mine 25 years ago when my AME informed me that a newly-reported condition was disqualifying. (I was fortunate; he did the extra work to issue rather than defer.)

In the HIMS situation, that can mean a lot of expense. But that may mean an initial discussion with the HIMS AME about how they see their role.

I’ll definitely be looking for an actual advocate on my side once I get through the initial SI and transition to BM. And for sure if I choose to move back to class 3.

Thanks!

 

[Jon Wilder]

I appreciate the feedback. What’s the solution then? Who do you work with to make sure you comply with the rules of moving from under the eye of the FAA to not?

Side note, how is that not some sort of malpractice if AMEs, if this is indeed the case, are knowingly giving you wrong advice, or negligently/unknowingly giving you wrong advice?

I’m not looking to open up a can of worms here (I have indeed turned over a new leaf), it’s just crazy that after 8 years it’s still not clear.

Thanks!

The solution is to do your research.

It's not "malpractice" because the AME isn't treating you. He is examining you for the purpose of ascertaining whether or not you meet a legal/administrative medical standard.

Domingo has been posted and discussed in great depth and detail in this forum in many threads. Domingo is an official FAA legal interpretation issued from Lorelei Peter, Assistant Chief Counsel for Regulations. That interpretation confirmed that airmen have a responsibility to comply with the terms of a Special Issuance Authorization only for as long as the underlying Special Issuance Medical Certificate is valid. Once it has expired, and the airman is not actively seeking to renew the medical certificate, the airman's responsibility to comply with the terms of the Special Issuance Authorization is no longer.

"Authorizations often have a longer duration than the associated special issuance medical certificate. These longer durations are for internal FAA administrative purposes and aid the Office Aerospace Medicine with the processing of special issuance medical certificates under§ 67.401. The Authorization's longer duration period conveys no independent medical privilege as evidenced by the requirement for an airman to demonstrate that he remains qualified for a new special issuance medical certificate when the current special issuance medical certificate expires. As such, an airman's responsibility to comply with the terms of an unexpired Authorization - including a term that requires regular submission of medical information - terminates when the associated special issuance medical certificate expires. Because there is no reasonable basis for requiring an airman in
those circumstances to provide medical information that is not needed for determining medical certification under§ 67.401,3 the FAA would not have a basis to withdraw the Authorization.

The above interpretation is consistent with the purpose of BasicMed, to allow an airman who can meet alternate requirements to fly without holding a medical certificate."

"Because alternate avenues are provided to collect information, it does not appear that Congress, who mandated BasicMed, wanted an airman to be beholden to continued requests for information related to a prior Authorization after the most recent special issuance medical certificate has expired and the airman is not in the process of seeking a renewed special issuance medical certification."

You can read Domingo for yourself at https://www.faa.gov/media/11051