Subdural hematoma: physician obligated to inform FAA when patient is a pilot?

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I'm a regular poster here who recently (about 2 weeks ago) suffered an acute traumatic subdural hematoma, treated surgically. My condition is much improved but I still have a long way to go before I'm 100% again. I'm currently in inpatient rehab. Before anyone jumps in with accusations, I am OF COURSE self grounding indefinitely, until I'm healthy again and can obtain recertification from the FAA. I have no intention of hiding anything from the agency that I am required to reveal.

My question though is in regards to the rehab agency director's stated intention to inform the FAA of my medical condition, against my express wishes, because he happens to know that I am a private pilot (3rd class med cert only). He claims that the rehab agency's lawyers have counseled him to do just that (though he apparently made some initial anonymous inquiries to the FAA on his own). I am furious because I do not want to have to deal with this now, indeed want to leave the Sport Pilot option open. My understanding is that if OKC demands my certificate, that is effectively a denial or at least a revocation, and forecloses the Sport Pilot option. But even if I decide to pursue recertification, I have no desire at this time to engage in any kind of back and forth with OKC. I would like to work on my health first and worry about flying later.

So my questions are:

1. Is the rehab agency correct? Do they have an obligation to report to the FAA or is this, as I suspect, a blatant HIPAA violation?

2. If it is not a HIPAA violation, how can I best protect my future options?

3. If it is a HIPAA violation, what is my best option to protect myself against it? I am currently under their care, so hiring an attorney to represent myself against them doesn't sound like a very wise course of action, to say the least. :eek:
 
I don't think the FAA can demand your certificate after 30 days from issue. They can file an action against you but have no reason to if you've self-grounded. You haven't done anything wrong, you just got sick.

AOPA PPS member? I know who I'd call to help answer the questions, legal and medical.
 
Unregistered said:
I'm a regular poster here who recently (about 2 weeks ago) suffered an acute traumatic subdural hematoma, treated surgically. My condition is much improved but I still have a long way to go before I'm 100% again. I'm currently in inpatient rehab. Before anyone jumps in with accusations, I am OF COURSE self grounding indefinitely, until I'm healthy again and can obtain recertification from the FAA. I have no intention of hiding anything from the agency that I am required to reveal.

My question though is in regards to the rehab agency director's stated intention to inform the FAA of my medical condition, against my express wishes, because he happens to know that I am a private pilot (3rd class med cert only). He claims that the rehab agency's lawyers have counseled him to do just that (though he apparently made some initial anonymous inquiries to the FAA on his own). I am furious because I do not want to have to deal with this now, indeed want to leave the Sport Pilot option open. My understanding is that if OKC demands my certificate, that is effectively a denial or at least a revocation, and forecloses the Sport Pilot option. But even if I decide to pursue recertification, I have no desire at this time to engage in any kind of back and forth with OKC. I would like to work on my health first and worry about flying later.

So my questions are:

1. Is the rehab agency correct? Do they have an obligation to report to the FAA or is this, as I suspect, a blatant HIPAA violation?

2. If it is not a HIPAA violation, how can I best protect my future options?

3. If it is a HIPAA violation, what is my best option to protect myself against it? I am currently under their care, so hiring an attorney to represent myself against them doesn't sound like a very wise course of action, to say the least. :eek:
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Pffft, call Dr. Bruce and hire a lawyer. I would hand the director a letter saying that explicitly forbid him to disclose any medical information to any one other than consulting doctors and insurance, and that if he does disclose info you will sue him and his company. I wouldn't worry about care over this, it is highly unlikely your care would be affected at all, in fact, offending or upsetting them should be the last thing you should be concerned about, they should be worried about upsetting you.
 
tell them you understand that you are currently unfit to fly and will not fly until legally fit. And that if they notify the FAA of treatment and cause a loss of future privileges you will pursue legal action, poison their wells, raze their crops and salt the earth beneath them.
 
Unregistered said:
tell them you understand that you are currently unfit to fly and will not fly until legally fit. And that if they notify the FAA of treatment and cause a loss of future privileges you will pursue legal action, poison their wells, raze their crops and salt the earth beneath them.
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You forgot their firstborn. If you're going to do it, do it right. :)
 
PaulS said:
Pffft, call Dr. Bruce and hire a lawyer. I would hand the director a letter saying that explicitly forbid him to disclose any medical information to any one other than consulting doctors and insurance, and that if he does disclose info you will sue him and his company. I wouldn't worry about care over this, it is highly unlikely your care would be affected at all, in fact, offending or upsetting them should be the last thing you should be concerned about, they should be worried about upsetting you.
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This. Sort of. This is a violation of HIPPA as I understand it (only peripherally involved in this stuff). I would inform them that it is and that should stop their lawyers in their tracks. They have no obligation to inform anybody.

You do have an obligation to inform the FAA at least for your next medical application though.

John
 
At first blush, I don't think the rehab guy is correct. You're doing things correctly with self grounding, not returning to flight until healthy, and then properly reporting to the AME on your next medical examination.

Even if the rehab guy reports you, my (very limited) understanding of the FAR's shows no actionable offense. So even if he reports, all he might get is a "thank you" and then they let the dog go back to sleep.

But the folks to consult with are Dr. Bruce and/or the AOPA Pilot Protection Services team. They will both know right away who has the correct standing on this and what is the proper action to take.
 
OP here.

My understanding is that they can at the very least send you a letter saying they have this information from a treating physician and that you are not qualified to hold a 3rd class certificate. Whether they actually request it back or not, I don't see why they couldn't. I'm pretty sure the time limit after issue is 60 days not 30, and refers to their reversing the AME's (or the FAS's) decision to issue you the cert. The can revoke your med cert for cause at any time (cf. the Bob Hoover case).

But anyway I really don't want to go down the rabbit hole of correspondence with OKC right now. I just want to get well, not deal with the FAA and the rehab agency's lawyers... though I may not have any choice as to the latter. :(

Stewartb said:
I don't think the FAA can demand your certificate after 30 days from issue. They can file an action against you but have no reason to if you've self-grounded. You haven't done anything wrong, you just got sick.

AOPA PPS member? I know who I'd call to help answer the questions, legal and medical.
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Yodice or Crump? Or even Bruce C.? Very definitely considering the latter. I've also posted this on the Red Board, though it hasn't gotten through a mod yet (presumably Bruce, who is often busy during the day).

Yes I'm an AOPA member and was at least once a PPS subscriber, but I don't recall whether I dropped that option or not.
 
You can opt into PPS on-line , pay the $99 with credit card, and call for help immediately after. I'm a long time AOPA critic but the PPS team is a large part of why I'm flying today. Money well spent for myself.

Best wishes for a full recovery, good health, and full flying privileges!
 
jsstevens said:
This. Sort of. This is a violation of HIPPA as I understand it (only peripherally involved in this stuff). I would inform them that it is and that should stop their lawyers in their tracks. They have no obligation to inform anybody.

You do have an obligation to inform the FAA at least for your next medical application though.

John
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I suspect they are confusing their obligation to the state with their obligation to the Feds. This state has mandated driver rehab for this kind of injury, which obviously has no teeth unless the physician informs the state. That confusion is going to be hard to disabuse. Proactive reporting to the state is the nose of the camel in the HIPAA tent, it's pretty easy to let the rest of the camel in. I already told the director that I was nearly certain his lawyers were wrong, at that I would get support for my position if need be.

Of course I have to inform the FAA, and before my next medical application if I want to fly. I'm under no illusions that I can self certify after this sort of injury.
 
I've had several years dealing with these types of people for elderly relatives and you need to be firm and make them understand that if they screw you up there will be consequences. They need to know you are serious. Really, they should not be telling anyone about your condition without your permission, except possibly your dmv. I hope you are feeling better and get through your illness.
 
Unregistered said:
tell them you understand that you are currently unfit to fly and will not fly until legally fit. And that if they notify the FAA of treatment and cause a loss of future privileges you will pursue legal action, poison their wells, raze their crops and salt the earth beneath them.
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Is there a reason why you posted as Unregistered? You are obviously not the OP.

As far as the OPs question goes, the doctor is not required to report your condition to the FAA but I have no clue about the HIPAA laws if the doctor goes ahead and does it voluntarily.
 
Before you were treated, you signed a bunch of forms. One of them was a very wide release authorization to release your info to - anyone they want. You signed it and now you need to revoke it before it gets out. Write it out in hand, and give it to the administrator, give it to the intake person, and make copies and give them to anyone that has seen you.

I went though the deal years ago, and now when I get that stack of papers I write in hand on every one of them "you do NOT have permission to release any medical information to anyone at any time without express written consent of the patient." I learned the hard way, but now I write it every time, on every document. If you think I'm BSing, look at my posting history and you will know how serious I am about this stuff.
 
docmirror said:
Before you were treated, you signed a bunch of forms. One of them was a very wide release authorization to release your info to - anyone they want. You signed it and now you need to revoke it before it gets out. Write it out in hand, and give it to the administrator, give it to the intake person, and make copies and give them to anyone that has seen you.
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Actually I doubt seriously that I had a chance to sign much of anything. I remember driving myself to the local ER with a very bad headache, getting worse by the minute. I remember telling them that I thought I was having a cerebral hemorrhage. I'm told that I decompensated very rapidly after reaching the ER and was lifted by ambulance to a hospital with better trauma services.

But even so, are you seriously saying that hospitals routinely force patients to sign away their HIPAA rights as a condition of treatment? I always understood that HIPAA paperwork to be you acknowledging the limits of HIPAA - which certainly exist and are broad. For example, if the NTSB or the FAA were investigating an accident and wished to subpoena my medical records, the caregiver would have to comply, and it's certainly to their legal advantage to have the patient acknowledge in writing that they're aware that HIPAA protects them against all requirements to disclose. I don't think they can make you give them permission to disclose beyond what HIPAA requires though, and I'd be truly astounded if hospitals tried that tack - I can't even think of a reason why they would want to.

But I could be wrong, or I could be misreading what you are saying.
 
docmirror said:
Before you were treated, you signed a bunch of forms. One of them was a very wide release authorization to release your info to - anyone they want. You signed it and now you need to revoke it before it gets out. Write it out in hand, and give it to the administrator, give it to the intake person, and make copies and give them to anyone that has seen you.

I went though the deal years ago, and now when I get that stack of papers I write in hand on every one of them "you do NOT have permission to release any medical information to anyone at any time without express written consent of the patient." I learned the hard way, but now I write it every time, on every document. If you think I'm BSing, look at my posting history and you will know how serious I am about this stuff.
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Agreed. In fact, I'd have a rubber stamp made up just to save time.

I also concur with the advice to call Dr. Bruce (for advice) and a lawyer (for teeth). A few well-worded nastygrams and a rendition of the riot act usually solves these sorts of problems.

Rich
 
Unregistered said:
Actually I doubt seriously that I had a chance to sign much of anything. I remember driving myself to the local ER with a very bad headache, getting worse by the minute. I remember telling them that I thought I was having a cerebral hemorrhage. I'm told that I decompensated very rapidly after reaching the ER and was lifted by ambulance to a hospital with better trauma services.

But even so, are you seriously saying that hospitals routinely force patients to sign away their HIPAA rights as a condition of treatment? I always understood that HIPAA paperwork to be you acknowledging the limits of HIPAA - which certainly exist and are broad. For example, if the NTSB or the FAA were investigating an accident and wished to subpoena my medical records, the caregiver would have to comply, and it's certainly to their legal advantage to have the patient acknowledge in writing that they're aware that HIPAA protects them against all requirements to disclose. I don't think they can make you give them permission to disclose beyond what HIPAA requires though, and I'd be truly astounded if hospitals tried that tack - I can't even think of a reason why they would want to.

But I could be wrong, or I could be misreading what you are saying.
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Sounds serious, and I'll say straight up - I am not a lawyer, so don't ask me about the legaleze on the HIPPA form. But - when I read it, what it reads like to me is this; 'we know about HIPPA, and we know that it's for your benefit but we are going to give your info to anyone we want for any reason we want, and your signature says its ok.' I'm glad you didn't sign it in advance, but wondering if you signed it after the fact? Usually the admin will send a person to your room with a stack of papers and a pen, and she's very nice, and has your signature on that release form.

I recall seeing exemptions in a HIPPA form for no less than marketing purposes, drug interaction studies, training MDs and nurses, and statistical capture of info. Now, after I write my comment on their form about "NO ONE, NO TIME, NO INFO they usually hem and haw for a bit, maybe call a supervisor, etc but I've never been kicked out of the place. In fact, I think I'd like them to kick me out after refusing to authorize the violation of my HIPPA privacy. Sounds like a good lawsuit.

When HIPPA was passed, it was very patient favorable. Then, the hospital lobby got involved and the form became unreadable by normal humans, which is why I went to the lengths to write out a clear, unabiguous statement and scratch through all of their 'authorized releases' part. But - that's just me.
 
docmirror said:
Sounds serious, and I'll say straight up - I am not a lawyer, so don't ask me about the legaleze on the HIPPA form. But - when I read it, what it reads like to me is this; 'we know about HIPPA, and we know that it's for your benefit but we are going to give your info to anyone we want for any reason we want, and your signature says its ok.' I'm glad you didn't sign it in advance, but wondering if you signed it after the fact? Usually the admin will send a person to your room with a stack of papers and a pen, and she's very nice, and has your signature on that release form.
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Of course, I can't be 100% certain I didn't sign something during the hazy time between my emergency craniotomy and the time I returned to full consciousness. I just have a hard time believing it's possible to sign away your HIPAA rights - the ones we still actually have - by filling out hospital paperwork. If HIPAA forbids them from discussing your medical details except in certain prescribed situations, how can that scam be legal?

Not saying you're wrong, but if it's true then I'm pretty naive about HIPAA because it just doesn't pass my smell test.

Oh, I also talked to Mike Yodice of AOPA PPS today (turns out I do have PPS). He doesn't know the answer to either of my questions: do the rehab people have any obligation to discuss my condition with the feds? and is it a violation of HIPAA for them to do so? He basically pointed me to a list of "panel attorneys" who participate with PPS but who have specialties all over the map. He gave me no guidance at all as to how to find an attorney with HIPAA expertise, other than to ask one of them for a reference.

I have already sent further questions to Mr. Yodice and hope to perhaps have better guidance by this time tomorrow.

I recall seeing exemptions in a HIPPA form for no less than marketing purposes, drug interaction studies, training MDs and nurses, and statistical capture of info.
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I've seen those exemptions too but always assumed they were actual HIPAA exceptions, and were all limited to statistical or anonymous use of data. That stuff I don't care about. Blabbing my medical condition to a federal agency because I happen to be a private pilot is on a whole different level as far as I'm concerned.
 
docmirror said:
https://www.floridahospital.com/sites/default/files/nppp_092313english_clean_copy.pdf

Looks about like what most places do. Everything, everywhere, to anyone, anytime, for any reason. According to them, you can't stop them either.
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Yes, I've seen similar HIPAA "consent" forms at many institutions. It's not clear to me how much actual patient consent is involved since I'm pretty sure most of the relevant exceptions are already spelled out in HIPAA: disclosure "as required by law", to prevent a serious health or safety risk, and in response to a lawful summons or subpoena from LE. The rest of it, disclosure to insurance companies, for marketing and fundraising etc., for research, might require consent, but I still say, so what? Unless you don't want an insurance record for some reason, why not allow that anyway? Personally, I couldn't begin to afford my current care without insurance. And the rest of it is mostly "your" medical info, but anonymized, with your personal identifying info removed.

Doc Bruce replied to my Red Board inquiry. The gist was that they're on thin ice but that HIPAA has no real teeth to hold them to the fire. My best bet would be a warning letter from my attorney impressing on them that I have not consented to the disclosure. There are some details that he recommended to add that aren't clear to me, so I've asked him for clarification.
 
Bottom line on HIPPA - they will notify agencies when required to by law...they are required to - think mental illness and domestic abuse. There is nothing in federal law nor in FAA regulations that I am aware of which requires doctors to notify the FAA for your condition. Your doctor is violating HIPPA and potentially causing you legal harm for it.

Side note - unless you receive a denial of your medical, you are still authorized to make a determination of your own fitness to fly sport. Even if you are not fit at this time, you determine when you become fit in the future.
 
jsstevens said:
This. Sort of. This is a violation of HIPPA as I understand it (only peripherally involved in this stuff). I would inform them that it is and that should stop their lawyers in their tracks. They have no obligation to inform anybody.

You do have an obligation to inform the FAA at least for your next medical application though.

John
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The laws don't apply to government.

I'd give them that letter.

Contact Bruce.

Contact AVIATION lawyer.


Get better
 
Unregistered said:
but I still say, so what? Unless you don't want an insurance record for some reason, why not allow that anyway?
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If you are the OP, you started this thread concerned about exactly this problem. Now you say 'so what?' Well fine, I tried to provide some semi-relevant info about the deal and you brush me off. As far as I'm concerned now I hope they do notify the FAA. Cya.
 
I asked my lawyer daughter about Hippa and a physician reporting medical info to the FAA. She said it would need a lawyer doing some research to figure out whether it's legal or not. At any rate it isn't an easy question to answer even for an attorney. For what that's worth.
 
Stewartb said:
I asked my lawyer daughter about Hippa and a physician reporting medical info to the FAA. She said it would need a lawyer doing some research to figure out whether it's legal or not. At any rate it isn't an easy question to answer even for an attorney. For what that's worth.
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If she is not a specialist in this type of law, its no surprise to me that she would need to do some research. I think law is like medicine. Practitioners have specialties. I learned that doctors might know a lot about their own specialty, but knowing about someone else's specialty, not so much. That's why you usually have a team of specialists if you have a complicated medical case.
 
NSS. Aviation lawyers probably won't be versed on Hippa. That was kinda the point.
 
docmirror said:
If you are the OP, you started this thread concerned about exactly this problem. Now you say 'so what?' Well fine, I tried to provide some semi-relevant info about the deal and you brush me off. As far as I'm concerned now I hope they do notify the FAA. Cya.
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Sorry you feel I'm brushing you off. It's not my intention, I just don't understand the philosophy of don't allow them to disclose ANYTHING. The world we live in today, unless you are independently wealthy, I don't think for most people it's possible to receive health care services under those terms. If they can't submit a dx code to insurance, you are stuck with the whole bill. If they can't discuss your case among each other or with a specialist of their choosing, you're not going to receive the best care available.

And no, I'm not concerned about "exactly this problem", I'm talking about a disclosure that's way outside anything mentioned in any HIPAA consent form I've ever seen, including the Florida hospital one you linked to. Seriously, I challenge you to find the clause in that document that requires (or even allows) them to share my medical info with the feds, absent a subpoena or notice that they are investigating me in connection with wrongdoing or a public safety matter (like an aircraft incident or an airspace violation or other ATC "thing").

Like Dr. Bruce said, they're apparently on very thin ice. The question is, if they choose to plunge into the water, what can I do about it? :(
 
Unregistered said:
Sorry you feel I'm brushing you off. It's not my intention, I just don't understand the philosophy of don't allow them to disclose ANYTHING. The world we live in today, unless you are independently wealthy, I don't think for most people it's possible to receive health care services under those terms. If they can't submit a dx code to insurance, you are stuck with the whole bill. If they can't discuss your case among each other or with a specialist of their choosing, you're not going to receive the best care available.

And no, I'm not concerned about "exactly this problem", I'm talking about a disclosure that's way outside anything mentioned in any HIPAA consent form I've ever seen, including the Florida hospital one you linked to. Seriously, I challenge you to find the clause in that document that requires (or even allows) them to share my medical info with the feds, absent a subpoena or notice that they are investigating me in connection with wrongdoing or a public safety matter (like an aircraft incident or an airspace violation or other ATC "thing").

Like Dr. Bruce said, they're apparently on very thin ice. The question is, if they choose to plunge into the water, what can I do about it? :(
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I will say that I agree with your philosophy here and I also agree that what we are talking about is outside the example from Florida. If the FAA came to the doctor first, that might be another matter. I don't know where the doctor or the lawyers get the idea that this disclosure is required unless they're using it as a CYA move. How does any doctor know their patient it a pilot unless the patient reveals it?
 
Unregistered said:
[snip]
Like Dr. Bruce said, they're apparently on very thin ice. The question is, if they choose to plunge into the water, what can I do about it? :(
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Make sure they get cold & wet! (And have a lawyer warn them the ice is thin and you'll be there to make sure they get cold and wet!)
 
Nope. Lawyers tend not to discuss what they don't know about. No surprise here. I was thinking about the OP's comments about the response from Mr. Yodice. My kid's suspicion is that government may be excluded from the restrictions in Hippa.

The FAA probably has no keen interest in the information. If the OP intends to report and follow aeromedical rules for continued flight privileges he might have better things to worry about right now. I'd want to ask an attorney for an opinion but if research was going to run up a sizable invoice I might feel differently. It's an interesting question. I hope he shares the answer if he chooses to pursue it.
 
Everskyward said:
I will say that I agree with your philosophy here and I also agree that what we are talking about is outside the example from Florida. If the FAA came to the doctor first, that might be another matter. I don't know where the doctor or the lawyers get the idea that this disclosure is required unless they're using it as a CYA move. How does any doctor know their patient it a pilot unless the patient reveals it?
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That's my understanding too.

As I said earlier, I think they are basing this on state statutes that require them to report the injury to the DMV - yet another specific exception carved out of HIPAA under the "as required by state and local law" clause, I'm pretty certain.

There is no state or local law requiring them to talk to the FAA about my case, I'm fairly confident too, but not quite to the level of certainty. There is certainly no federal law requiring them to and I've never heard of local law requiring interaction with federal authorities, but IANAL.
 
I am more interested in the statement by the doctor that the facility lawyers say that disclosure to the FAA is mandatory without a request from the FAA or law enforcement. I am almost sure that is not true.

But I agree that the FAA probably has little interest in the OP's current condition as long as he or she is not trying to exercise the privileges of their medical certificate.

Good luck to the OP, and let me say that I am really surprised they are even thinking about this only two weeks out from the event.
 
Stewartb said:
Nope. Lawyers tend not to discuss what they don't know about. No surprise here. I was thinking about the OP's comments about the response from Mr. Yodice. My kid's suspicion is that government may be excluded from the restrictions in Hippa.
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All of the HIPAA consent forms I've seen explicitly exclude them, so I suspect your kid's suspicion is spot on. But as far as I'm aware, they (the gov't) have to initiate the inquiry. Excluding the government from HIPAA restrictions doesn't give a third party carte blanche to talk to them just because they want to or think the law requires them to. I'm pretty sure the law DOES require them to talk to the DMV, but am looking for support for the position that there is no such requirement to talk to the FAA. As you (or someone) said, the only reason they even know I'm a pilot is because I openly shared that information.
The FAA probably has no keen interest in the information. If the OP intends to report and follow aeromedical rules for continued flight privileges he might have better things to worry about right now. I'd want to ask an attorney for an opinion but if research was going to run up a sizable invoice I might feel differently. It's an interesting question. I hope he shares the answer if he chooses to pursue it.
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I'm thinking the same thing, especially since Mr. Yodice indicated that answering this question is NOT covered under pps. But whatever I find out, I will share the answer here if I can.

The FAA may have no keen interest in the information, but I sure don't want to get embroiled in correspondence with them now, and I'd prefer not to have to proactively mail my medical in for cancellation, which seems to be my only other protection against having my medical rescinded.
 
On a less-confrontational note, possibly an entry in your log book stating something to the effect of "Self-grounding until fully recovered from subdural hematoma" might not be a bad idea. You can write whatever you like in your log book (as long as it's true), and it would establish that you had no intention of violating 61.53.

This actually is what I did during the several months between my gallstone diagnosis and recovery from the surgery, for pretty much the same reasons as you're concerned about. Early in the interview with the first surgeon I'd been referred to, I'd asked about the recovery time as concerned flying and other activities. When I later decided to use another surgeon, the first surgeon got all offended and made what sounded like a veiled threat to call the FAA to tell them I was unfit to fly.

I already knew that, of course, and was flying under the SP rule in any case, so it didn't really bother me. The last gall bladder attack had been hellish enough that flying was the last thing I had any intention of doing until the situation was corrected. But I decided to cover my ass with a log book entry that I was self-grounding, anyway. I figured it was a simple way to document my abiding by 61.53.

Two weeks after the surgery, when the surgeon who did the procedure pronounced me fully-healed, I made another entry that I was un-grounding myself after discussing it with my physician. And that, as they say, was that.

Rich
 
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Everskyward said:
I am more interested in the statement by the doctor that the facility lawyers say that disclosure to the FAA is mandatory without a request from the FAA or law enforcement. I am almost sure that is not true.
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So am I. The rehab agency director agreed just a few minutes ago to ask their lawyers to call me and give me a chance to ask them what statute they believe requires them to disclose to the FAA. If they can't point to a specific statute, then that pretty well confirms that it's CYA combined with knowledge that HIPAA has no teeth, as Dr. Bruce seemed to imply on the RB. :(
 
Unregistered said:
So am I. The rehab agency director agreed just a few minutes ago to ask their lawyers to call me and give me a chance to ask them what statute they believe requires them to disclose to the FAA. If they can't point to a specific statute, then that pretty well confirms that it's CYA combined with knowledge that HIPAA has no teeth, as Dr. Bruce seemed to imply on the RB. :(
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My thinking is that, if it is true, it would have come up before and this is the first I have heard of it.
 
I could understand a little the facility doc motives if the OP was part of a 121 carrier and the doc thought the OP might put a quantity of passengers in danger. But that is not the case.

Dr. Bruce suggested to the OP
Dr. Bruce Chien said:
You could pre-empt all actions by simply sending in your certificate for cancellation, without comment, certified mail.
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OP if you do this, send photo copies of the mailing and the proof of receipt to that doc along with directions to a nearby body of water and jumping instructions.

I agree with all that the facility doc is way too zealous on the "Doc must report to FAA" point under discussion.
 
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