This AME is about to Refuse to provide Special Issuance examinations

[WindOnHisNose]

I returned from a vacation only to find a fax from a pilot who has a Special Issuance for cardiovascular disease, specifically for having had coronary angioplasty, stenting and medication. He has had to jump through major hoops for over 15 years, has modified his lifestyle long ago after experiencing angina. He is a CFI and a very responsible person. Each and every year he has to undergo an exercise stress test (out of his own pocket, and these aren't cheap), a series of blood tests and submit them to OKC for renewal of his SI.

The verbage in the letter he received this time now has shifted responsibility for reviewing this bullshit testing from OKC looking it over and approving it to the AME, who has now been "blessed" with the honor of reviewing the results of the stress test, including the current status report (which must include a long list of blood testing, a discussion about physical activity recommendations, obesity determination, etc). The FAA, in its benevolence, has added "since review of your records and issuance of a new certificate are time-consuming, the AME will likely find it necessary to charge you a fee for these services. If you wish to avoid such a fee, you may, in the alternative, submit the specially required medical information in one mailing to the following address for review: Medical Appeals Section, AAM-313, Aerospace Medical Certification Division, Post Office Box 26200, Oklahoma City OK 73125-9867. This information should be obtained and sent in one mailing to the AMCD 90 days prior to the expiration of your medical certificate".

So, the Gods in OKC have found a way to send their workload off to the AME who is willing to deal with SI airmen, workload that is created in no small part because of the lengthy, cover-their-ass attitude, and in effect has shifted the responsibility for testing interpretation to the unsuspecting AME. Should I not pick up that an airman "develops 1 mm or greater ST segment depression at any time during stress testing", and authorize the SI, I will be liable for that.

I've had enough of this crap, and I can see why the number of AMEs is shrinking, why it is a major pain in the ass to provide care for airmen with SI!

In my medical practice I often see irrelevant testing having been ordered by another physician, it comes out abnormal and the patient wants to know what I think about the test results. I simply tell them that they need to go back to the physician who ordered the test and find out what they want to do with the results! With the internet and googling that is going on it is not uncommon for a physician, when approached by a patient who "read on the internet" that a specific test should be performed and the doc knuckles under and just orders the test to get the patient of his/her back. In the case of the pilot I am referring to at the beginning of this RANT and RAVE, the annual testing that is required by the FAA is an enormous waste of time and money for this poor pilot, and is now transferred from OKC to me!

I am mulling this over, am Mad As Hell that this pilot, and now his AME, who is gonna pay the price.

Randy

 

[WindOnHisNose]

It sounds like another positive step on the path to getting OKC out of my affairs and allowing me to choose my practitioner to manage my airman's medical. I'm a fan of smaller government.

I fail to see how this gets OKC out of a pilots affairs. OKC makes the edicts, the pilot pays.

 

[bob turner]

My students with those issues will not go to an AME who does not completely review every shred of documentation before sending it to OKC.

I agree - some of these SI requirements are expensive and invasive - one student reported a $26,000 test not covered by his insurance.

I have always been puzzled - I would rather be sharing the pattern with a truly sick pilot than sharing the freeway with the same guy. And I believe a .08 alcohol pilot is less dangerous to society than a .08 driver.

But I know nothing about medicine, so - opinion.

 

[aviationinfo]

Randy, I completely understand where you are coming from. There sure seems to be a disconnect at higher levels.

Having said that, I am sure I would find it a great comfort to have my AME review any package I am required to complete, even if he chooses not to have the final say over it and pass it up to the RFS. And I would happily pay for that service. It sounds like you're going to have to make judgement calls between when to defer to the RFS and when to act as the final review.

 

[WindOnHisNose]

Randy, I completely understand where you are coming from. There sure seems to be a disconnect at higher levels.

Having said that, I am sure I would find it a great comfort to have my AME review any package I am required to complete, even if he chooses not to have the final say over it and pass it up to the RFS. And I would happily pay for that service. It sounds like you're going to have to make judgement calls between when to defer to the RFS and when to act as the final review.

You know, the way it looks to me right now is that I really won't have a judgement to make as it applies to SI. The AME is expected to pass judgement on interpreting the testing results. OKC doesn't really suggest a good option for deferring SI to them...they directly state that this is the responsibility of the AME. Do I feel comfortable interpreting the test strips of an exercise stress test? Nope. Do I feel comfortable with the cardiologist who performed the test and read it out? Yes. Unfortunately, OKC won't accept that. They would rather have a gynecologist, in my case, take a stab at interpreting the test strip, and having me accept legal responsibility should a mishap occur for this pilot that could be blamed on a misread tracing.

It is an entirely different story for non-SI issues, such as the CACI I mentioned in the thread on "Guide for Medical Examiners".

Randy

 

[WindOnHisNose]

In my experience with AMEs and my own SIs my AME reviews all the SI reports and records before submitting to the RFS so this policy isn't changing his role much. My cardiologist wouldn't send my file to the AME if it wasn't going to pass muster and my AME wouldn't send it up, either. The potential SNAFU is at the RFS office (like when the RFS is away on business or vacation) and the file is forwarded to another region or to OKC. If that happens all progress comes to a grinding halt. So in my experience OKC is the greatest potential problem in the process. Eliminating their participation makes good sense. My AME is a qualified physician so he should be able to read my specialist's summaries as well as anyone in OKC but with less red tape and fewer delays. To me that's a win.

stewartb, it is a beautiful world in which you live, and good for you. I can't tell you how many times the AME has dropped the ball for members of this website, and done so in a big way. You have found an AME, and a cardiologist, who understand the system. You are fortunate. Many are not so fortunate.

When you say that your cardiologist wouldn't send your file to your AME if it wasn't going to pass muster, what would he/she do? Retest you? Great, and what if you again don't pass muster? Your AME is now duty bound to provide some kind of answer to OKC (there is, of course, a time limit on when the SI would lapse) for reissue of your SI. What will that answer be? If the answer is "He doesn't pass muster" OKC will issue a denial letter and demand that you send your medical certificate to them. There is a point in the FAA system at which you can no longer let your SI lapse without receiving the denial letter...and most of us don't want a denial because it takes LSA out of the picture.

The option of sending the file to OKC to the Medical Appeals Section sounds like a lovely exercise in patience. If I were a pilot in that situation I sure as heck would not want to follow that path.

My experience while on the faculties at Yale and at Mayo Clinic is that it is pretty easy for those at the top to establish requirements/procedures, but it is not so easy for those who are lower in the food chain whose workload is further burdened by what comes down from above. In the case of OKC there are many examples of overkill, in terms of requiring hoops for pilots to jump through. It is my feeling that the bureaucrats upstairs found a way to unburden themselves (work-wise and risk management-wise) by shifting the burden (created by their oft ill-conceived protocols) to those at the lowest level of the food chain, the AME.

 

[Gordon Misch]

I can see pros and cons to this.

Downside is increased burden placed on the AME by the "cubicle rats" in OKC, together with the expectation that the AME is competent in specialty fields. I see this increased burden WAY too much in my teaching profession. Requirements are piled upon requirements, few of which enhance my value to students. The problem is that the cubicle rats aren't in a position to evaluate the effects of their requirements in a balanced way. But they can feel good about requirements that they INTEND to be beneficial to students. The consequence is a depressed effort to benefit ratio.

On the upside, the pilot can visit the AME without directly applying for the SI, to get an opinion. In that process, the AME can consult with the specialist. All of this can happen outside the view of FAA. Certainly it takes more time, and a $100 third-class exam isn't in the cards. However I think the likelihood of ultimately obtaining the medical cert might be enhanced, though with a higher bill from the AME.

I agree with Randy about bureaucratic burdens being imposed from above, especially where those who are creating the burdens do not have to carry them. I also agree with Stewart, that this procedure perhaps gives pilots greater flexibility in managing their certification, though with a greater AME bill.

Randy, re lapse of the SI and demands for medical cert relinquishment, how does one with an SI let all of the medical stuff lapse, in order to fly light sport?

 

[WindOnHisNose]

Gordon, thanks for your note.

I am not at all sure that Stewart's point suggesting greater pilot flexibility is the outcome of this change. I see this as purely a shift in who takes responsibility for renewing the SI, and who does the work for going through the documents required by the SI, and who is liable should a bad outcome follow the "renewal" of the SI by the AME.

I find it a bit ironic that as an AME we are watched to see if we defer appropriately to OKC or RFS, and the implication has been that if we don't defer at a certain rate we may be letting too many pilots get through the system that should be deferred (false negatives). Now we are discouraged from deferring, in essence, and this leads one to question why this sudden change of heart by OKC. We were very happy when the CACIs came out (http://www.supercub.org/forum/showt...elaxed-Your-AME-Unleashed&highlight=unleashed), giving AMEs greater lattitude in issuing a medical certificate for conditions that previously were SIs. The conditions were clearly defined and the protocols were simple to follow and were a good guide for the pilot to follow as he did his pre-examination preflight. This is now different, it is diverse.

Shifting responsibility, shifting work, shifting liability...

Randy

 

[mvivion]

Shifting responsibility, shifting work, shifting liability...

Randy

I suspect this is precisely what this is all about. And, that was my concern with the (heavily amended) PBR 2 language that came out of the House committee recently. It put all the burden on a doctor, not a specialist, not even an AME, to determine that a pilot is safe to fly. As with so many other FAA policies, this just shifts the responsibility and the liability to the AME.

We've lost a lot of good A & P technicians to other jobs because they could make more money and be subject to far less liability earning their living elsewhere. It seems to me that Randy is correct in that this shift of liability could well have the same effect on AMEs. As it is, doctors all carry substantial malpractice insurance. I'm sure their insurance carrier would be delighted to know that they could now be the subject of litigation involving a few hundred lost souls from an Airbus 380 accident......

MTV

 

[WindOnHisNose]

I suspect this is precisely what this is all about. And, that was my concern with the (heavily amended) PBR 2 language that came out of the House committee recently. It put all the burden on a doctor, not a specialist, not even an AME, to determine that a pilot is safe to fly. As with so many other FAA policies, this just shifts the responsibility and the liability to the AME.

We've lost a lot of good A & P technicians to other jobs because they could make more money and be subject to far less liability earning their living elsewhere. It seems to me that Randy is correct in that this shift of liability could well have the same effect on AMEs. As it is, doctors all carry substantial malpractice insurance. I'm sure their insurance carrier would be delighted to know that they could now be the subject of litigation involving a few hundred lost souls from an Airbus 380 accident......

MTV

Exactly, Mike. Frankly, I have limited my AME activity to 2nd an 3rd class certificates precisely for that reason.

Randy

 

[WindOnHisNose]

Can anyone refer me to an FAA statement about a change to the SI process? If there's a change to the process I'd like to learn about it so I can best deal with it. The only thing I can find that's related to this topic is the AASI program and that's not new although applying it to a cardiac SI may be.

Stewart, I also cannot find a statement about the change. I do know that I helped a fellow just a month ago with a similar diagnosis and SI and the verbage in the letter which was sent to him and to me has changed. It is my guess that this change just sort of was slid in so as not to draw major attention. I put a call into our RFS office this morning to discuss this and haven't heard back. I'll report back here when I hear back.

 

[OLDCROWE]

Any chance this is just a desk clearing exercise in OKC rather than a new policy?

 

[WindOnHisNose]

Any chance this is just a desk clearing exercise in OKC rather than a new policy?

Could be, but I doubt it. Someone put some thought into the letter sent to this airman.

Randy

 

[OLDCROWE]

Could be, but I doubt it. Someone put some thought into the letter sent to this airman.

Randy

If the airman is comfortable, and only if, he could redact his name and the ame's name and provide it to AOPA.

 

[n40ff]

You know, the way it looks to me right now is that I really won't have a judgement to make as it applies to SI. The AME is expected to pass judgement on interpreting the testing results. OKC doesn't really suggest a good option for deferring SI to them...they directly state that this is the responsibility of the AME. Do I feel comfortable interpreting the test strips of an exercise stress test? Nope. Do I feel comfortable with the cardiologist who performed the test and read it out? Yes. Unfortunately, OKC won't accept that. They would rather have a gynecologist, in my case, take a stab at interpreting the test strip, and having me accept legal responsibility should a mishap occur for this pilot that could be blamed on a misread tracing.

It is an entirely different story for non-SI issues, such as the CACI I mentioned in the thread on "Guide for Medical Examiners".

Randy

Unfortunately, OKC won't accept that


That's the rub! The FAA and the bloody lawyers only have leverage on the AME, not the specialist who is really qualified. So it's only the AME who can assume the risk.....

Anyone who thinks this is positive simply has his head in the sand. It's another nail in the coffin. Mechanics, CFI's and now AME are and/or will get out of aviation. The airman will be left with fewer and fewer options. Less people to support him and his airplane, the cost in both time and $ will only go up.

This is not positive and if you happen to have an AME who thinks it is, I suspect he either can't read or has his head stuck somewhere too?

It would be interesting to know exactly what this will do to the AME's insurance premium?

Jack

 

[bob turner]

Lots of things are adding up. I have decided to never again attempt a primary student - mostly because every time I turn around a new requirement pops up. I just heard of a mechanic who has to travel halfway across the country to give a deposition concerning an aircraft that stalled and killed a lot of folks - how in the world can a mechanic control how hard a pilot yanks back on the yoke in a turn? There were twelve endorsements required for the last sport pilot I recommended. He was told to carry a copy of the preflight checklist in his hand during the walk around. Grumble . . .

 

[stewartb]

In the (selfish) interest of information I did contact my RFS to ask about any change in the SI process. There is none. It sounds like this is about AASI and not "standard" SI. The AASI process does include some cardiac SIs but that still requires an FAA-issued SI and allows the local AME to renew the SI under the terms and conditions of the FAA SI. That's not a new concept. My old thyroid SI worked that way for years. My current SI condition doesn't qualify for that program so I'm stuck with submitting my records and files to the FAA annually. Would I prefer to have my annual renewal handled by my AME? Absolutely I would. It wouldn't change the requirement for me to have the exact same cardiology work-up but it would make my renewals less stressful. I guess if some AMEs don't want to participate in the AASI process they can choose not to but that doesn't make the program bad. I hope the FAA expands upon it. Of note, the cardiac SI list isn't applicable for 1st and 2nd class AASIs.

https://www.faa.gov/about/office_or...ffices/aam/ame/guide/special_iss/third_class/

 

[WindOnHisNose]

Stewart, thanks for the information. I wasn't implying that there was a change in the SI process, as the gentleman I described already had his SI. It was, rather, the significant change in the AMEs role in renewing the SI. I thought that was clear in my original post, but perhaps not clear enough.

Randy

 

[stewartb]

It's all good. You got my attention because I'm at 90 days from SI expiration. I have to coordinate doctor visits in two states in order to renew the SI on time without any lapses so I try to stay on top of this stuff. I'm lucky to live where we have a very responsive RFS office but I still envy your patient and his ability to renew his medical without dealing with the FAA.

 

[WindOnHisNose]

Good luck, Stewart!

 

[sniffler]

I have to be honest Doc, you are making me nervous, for years Randy you have been the calming voice of reason regarding FAA medicals and SIs the wise AME tells us all to take a breath work with the system and everything will be OK (pun intended). With this post you sound more like one of us :-(

The whole Special Issuance (SI) program seems to be coming off the rails and primary care Doctors are pushing back at the concept of signing off. My SI is simple, type two diabetes, non-insulin. My class 3 medical is good for two years but in the off year I must submit a A1C blood test and have my primary care Doctor sign off. My primary care Doctor reads things carefully but as she has signed off before she signed again. However she was not happy that the FAA changed the reporting form from what I had her sign in the past. And to be honest the change in the new recommended FAA form is pretty simple, nothing at all like what the proposed class 3 revision will be. As I understand the proposed form I am not certain at all that she will be willing to sign off and accept the liability.

But the real kicker is I am running out of available AME’s in our area, the good ones have moved or retired, couple of old timers left but they want to do the cookie cutter medicals not happy to do my SI and as they are older than dirt I will be looking for a new one next year. Figured smart guy that I am, I should find a AME how is first younger then me, and second is part of industrial medicine doing DOT test drug testing that sort of thing in a major city. Which meant I had to drive 2 hours. FAXed everything to the AME’s office two days in advance, including the pages from the FAA website that showed the AME how to renew my SI. Got a confirmation from the nurse they got the information. All of this while simple requires timing similar to the invasion of Normandy, Primary care doctor can't see me too soon or insurance squaks, blood tests need to be on hand prior to seeing primary care doctor but can't be too old or FAA will kick them back as being too old. Again not hard just a lot of schedule juggling.

So after driving 2 hours and then sitting in AME office waiting room for 1 hour the AME calls me into the inner hallway and said he would not renew my SI because he did not do my initial class 3 physical last year. I politely explained my original AME had retired and this is just the simple mid year renewal, he still said he would not do it. My impression is the industrial medicine doctors only want to do the simple stuff and make a fast easy buck, if it takes any effort or mental effor they show you the door.

My original FAA SI letter says I can send the mid year documentation in directly to OK City so am trying that, however that is in conflict with the AME rapid renewal system, AME Assisted Special Issuance (AASI), so time will tell if I get a medical renewal or not.

randi

 

[TurboBeaver]

This is sounding more and more like the goverments attempt to do the samething to flying as it is trying to do to the second amendment, when are people going to wake up and realize that the government is completely out of control, by over controlling everything, those folks that are creating all this BS probably wouldn't have a clue weather the pilot is safe to fly or not, anymore than a have a clue how to stop crimes committed with a firearm. However if you don't play ball with these wackjobs they have Federal penalty's that ALWAYS include Felony charges and huge fines to scare all of us into not disobeying all the BS that Washington can come up with............................. they are destroying the flying community one rule at a time to the point unless you are prepared to break the law it has lost its whole lure................ what a pack of jackwagons we now have to rule our lives! And if Hillary can get in I will live to see this country as I once knew it ...................... history.

 

[n40ff]

Nothing they do to make things better will be positive! Sorry.

The old adage is truer and truer,

"I/we are from the government, we are here to help you."

It's all BS!

The firearms analogy is valid too. I was a FFL/dealer for 23 years, gave it up in 2006 because it became impossible to comply with all the BS. Too much chance of either loosing your livelihood and/or going to jail for either a small I dotting error or just LEAGALLY selling a gun to the "wrong" person who happens to do something bad.

Same with a CFI, A&P/IA, AME and now a private doctor.....just happen to have signed off the "wrong" aircraft or pilot and something bad happens, They come looking for YOU!

Why do it when you can make more $ doing something safer?

We are dying on the vine

Jack