The FAA yesterday delayed making stark changes to policies for aviation medical examiners (AMEs) that were set to take effect on January 1 and impact pilots seeking to get or renew an aeromedical certificate. But it will go ahead with rolling out its new, computerized color vision test requirements next month.

Previously, the FAA announced it would shift to issuing initial denials instead of deferrals for medical certificate applications that require additional information. Late on December 18, the FAA said it would postpone this process change until March 1 after receiving feedback from aviation stakeholders. This extra time will allow the agency to educate the pilot community and host a listening session in January with various aviation associations, the FAA noted.

According to the agency, the policy change is intended to expedite the medical certification process. Under the existing policy, deferred applicants have 30 to 90 days to submit additional medical records or evaluations in response to an information request letter. But the agency said there is no such timeline for denials and shifts the burden to file paperwork on pilots, ostensibly freeing up time at the FAA to work on other aeromedical applications.

Earlier this week, aviation groups issued a formal response letter urging the FAA to reconsider this policy change. In response to questions from AMEs, the FAA also held a special edition of AME Grand Rounds to clarify these policies and posted the recording to YouTube on December 16. 

Denials Over Deferrals

During the session, FAA deputy federal air surgeon Brett Wyrick underscored that AMEs are not expected to deny applicants. “It's not your job to deny anybody,” he told the AMEs in the audience. “Doctor Northrup and I and the rest of the FAA staff, we get paid to be the bad guys. But what we have asked you to do [in the past] is when you cannot issue—when you find something that is medically disqualifying or medically uncertain and needs further review—we ask you to defer.”

“What's different is that in the past, we would have said, ‘Hey, you're in the deferred status,’ and we would send a request for additional information: ‘This is what we need to see in order to make a determination on your application.’ What's going to happen now is they're going to go into denial status,” Wyrick explained. “We'll send them a denial form. And we'll also…indicate the items that we need for reconsideration.”

“Now, this is different,” he continued. “We used to send a letter, and we said, ‘We're unable to establish eligibility.’ What we're going to do now, we're going to say you're now on a denied status. This is a general denial.” This denial of a medical certificate would include a list of the required documentation for reconsideration, he explained.

Wyrick emphasized that AMEs need to “educate your pilots” about the importance of providing complete documentation during the evaluation and about the possibility of general denials from the FAA. With the new policy, it will be crucial for applicants to have proper documentation ready before their examination to avoid a denial.

An initial denial occurs when the FAA determines an applicant does not meet the medical standards, and the applicant may request reconsideration within 30 days by submitting the required documentation. If the FAA issues a final denial, the applicant can only appeal through the National Transportation Safety Board (NTSB). However, applicants who can demonstrate eligibility could have their cases reconsidered, even after a final denial. 

“We're relieving [applicants] of the burden of worrying about meeting deadlines when they try to come up with additional information,” Wyrick said. “There's no time constraint to submit it within a certain time, except for the fact that if they're applying for [a] Third Class [medical], you know that it's got to be done during the length of time that the certificate would be authorized.”

The burden of providing the necessary documents rests with the applicant “and it relieves the [FAA] and my staff of a lot of manpower that goes into keeping up with the status of all these documents that are in deferred status,” Wyrick said. “It gives us the ability to look at more people [and] process more applications, and hopefully speed up the process for everybody.”

For example, if a pilot is unable to schedule a necessary cardiology consultation within 90 days, “we're not going to hound them for extensions,” Wyrick said. “The burden is on the applicant to submit the necessary documents as soon as they are available.”

The changes on the surface align with Section 801 of the FAA Reauthorization Act of 2024, titled “reexamination of pilots or certificate holders,” which mandates timely notification of airman certificate reexaminations. However, it’s unclear whether the changes align with the goal of the bill as it was written: “The Administrator shall provide timely, written notification to an individual subject to a reexamination of an airman certificate issued under Chapter 447 of Title 49, United States Code.”

It is unclear what kind of paperwork those denial appeals might generate for the FAA, and some in the aviation community are questioning whether the FAA thought through potential consequences for individual aviators and for the industry when this policy goes into effect. Pilots who receive a denial must report this on future aeromedical applications and job applications, which could lead to delays in getting professional pilots back to work. Those who are issued denials may also lose eligibility for programs such as BasicMed, which has led to concerns about the impact on those seeking alternative flying privileges. 

In its December 13 response letter, AOPA and a coalition of airline and charter pilot unions urged federal air surgeon Dr. Susan Northrup to delay the policy change. The letter also expressed general positive support for promoting the submission of complete information when an applicant applies for an aeromedical certificate.

However, it expressed concern that this shift would “significantly increase unneeded confusion for applicants” and could have lasting consequences.

“These initial denials will also be reportable on future medical applications and other applications the industry uses, such as employment applications, which ask whether a pilot has had a previous medical denial,” the letter states. “The ramifications of an increase in airmen receiving and reporting medical denials on these applications and the need to educate hiring managers about this change are significant and will take considerable time.”

Computerized Color Vision Tests

Updates to the FAA’s color vision testing policies—which the NTSB has been recommending for decades—were also addressed during the AME Grand Rounds session.

“Screening will now require modernized equipment [and] one of three new computer-based tests,” said Judith Frazier, medical officer for the FAA Office of Aerospace Medicine’s aeromedical standards and policy branch.

Pilots with color vision restrictions must take one of the new digital tests. Meanwhile, pilots holding existing medical certificates without restrictions are not required to take another test unless they begin taking a medication or are diagnosed with a medical condition that could affect color vision, she explained. 

To address issues with precision approach path indicator (PAPI) lights and cockpit digital display perception, tests will screen for red and green color deficiency, as well as the less common yellow and blue color deficiencies.

There is an allowance for pilots to have less than normal scores. “Sufficient color vision sensitivity to be able to discriminate the colors that are required in these job sample tests were signal and airport lighting,” said Thomas Chidester, deputy director of the FAA’s Civil Aerospace Medical Institute. He showed the audience the testing software, along with prices.

The FAA has suggested that AMEs who do not wish to pay for the software and equipment necessary to conduct these tests could refer pilots to vision clinics or other AMEs who do have the software.