Normally, yes.
At some point, you were given a letter that sent you to HIMS. Did that letter identify you as having alcohol abuse? If so, there might be more to this. Letting your medical/SI expire may generate a letter to you stating that as someone with a known abuse problem, you are unqualified to fly (regardless of the medical program).
I think asking is a good step. I'd ask about going to sport pilot, which is a driver's license medical. If you can do that, you can fly under basicmed too.
I'm just trying to be cautious here. Like I said, I have a vague memory of having read that somewhere, but I can't find it.
Substance
dependence and substance
abuse are distinct well defined disqualifying conditions referenced in CFR part 67. The terms are not interchangeable. Substance dependence is a lifelong diagnosis. Substance abuse is not a lifelong diagnosis, although someone who doesn't get the hint has a high likelihood of graduating to dependence.
The only manner in which BasicMed addresses substance
abuse is indirectly through the self certifying and prohibition against flying with a disqualifying condition clauses. Abuse is not specifically called out, but if the airman is abusing substances as defined by 14 CFR 67.307 they have a disqualifying condition and shouldn't be flying under any class medical or BasicMed. If evidence could be produced to prove the abuse and that the airman operated, the FAA could make a case for some type of enforcement action against the airman's medical certificate and/or airman certificates.
BasicMed
does specifically call out s
ubstance dependence within the last 2 years as disqualifying in 14 CFR 68.9(a)(1)(iv). The problem is when does the 2 year clock start if dependence is a lifelong diagnosis? I'm not aware of any clear current guidance on this. The waters get muddy because most medical professionals believe that simple abstinence from a substance is not the same as recovery. The most simple interpretation is you put down the bottle for 2 years and you're good, but there's not a lot of case law on this.
An airman that obtains a 1 time special issuance for substance dependence and allows their medical to lapse is eligible to fly under BasicMed. The expiration of their special issuance letter has no impact on their BasicMed eligibility. Substance dependent airmen must continue to abstain from mood altering substances. If the airman relapses, they now have a disqualifying condition again.
If the airman develops any of the other disqualifying conditions listed in 14 CFR 68.9 they must obtain additional SIs for those conditions. The gotcha is that to obtain the SI for the new condition they must prove they're entirely medically qualified. That means their substance dependence diagnosis will be evaluated and they'll have to establish that they've remained abstinent and their recovery is still stable since their last evaluation.
I've heard talk of "Don't go flying if you've got a disqualifying condition" letters as a result of DUIs reported or located through the NDR check tied to BasicMed. I don't have first hand experience with this, but it seems totally probable. They can also request additional info per 14 CFR 68.11 and could determine an airman ineligible for BasicMed as a result of the information provided. Ultimately "the administrator" has the final say and could send you a letter/take action for any reason that was determined to be in the public interest or the safety of air transportation.