Essay 3rd Class Medical Expiration

The Federal Aviation Regulations, Part 67, Subpart E, allows the Federal Air Surgeon latitude to consider persons with serious medical conditions for a discretionary medical certificate, or special issuance authorization. An authorization is required when the applicant for medical certification is considered unable to meet the medical standards prescribed in Subparts B, C, and D of Part 67.

A discretionary issuance carries with it additional requirements for more frequent reevaluation and testing to determine that the condition for which the authorization is issued has not progressed to a point that public safety will be endangered during the time the authorization is in effect. An authorization differs from a Statement of Demonstrated Ability (SODA) in that a SODA is issued for a disqualifying condition that is static or non-progressive, such as a loss of vision in one eye or limb amputation.

Even though an Authorization may require reexamination every six or twelve months, the date of renewal of your FAA medical application and physical examination does not change.  It is still required every 6 or 12 months for a First-class medical, every 12 months for Second, and either 24 or 60 months, depending upon your age for Third-class.

Following is the text of an FAA Authorization letter with explanation and interpretation (in italics) of what the authorization is stating.

Dear Mr. Member:  PI# 100111

I have reviewed the information submitted by you in support of your request for an airman medical certificate.  The medical evidence reveals a history of myocardial infarction and coronary artery disease requiring coronary artery bypass surgery.  You are ineligible for third-class medical certification under Section 67.111(a) (1) (3), 67.211(a) (c), and 67.311(a) (c) of the Federal Aviation Regulations (FARs).

The letter must state the medical history presented to the FAA.  Because of the disqualifying conditions, the medical regulation that makes the condition disqualifying must also be stated.  Section 67.111 details the requirements for a First class medical, 67.211 for Second class, and 67.313 for Third.  The parenthetical numbers refer to the specific medical condition, in this case, myocardial infarction and coronary heart disease.

However, based on the complete review of the available medical evidence, I have determined that you may be granted authorization for special issuance of Third-class airman medical certification under Section 67.401 of the FARs.

Your Aviation Medical Examiner is authorized by this letter to issue you a third-class medical certificate bearing the limitation “NOT VALID FOR ANY CLASS AFTER APRIL 30, 2014” provided you are found to be otherwise qualified.

Despite your disqualifying condition, the Federal Air Surgeon has found that your current medical condition does not put you at an unacceptable risk that would endanger public safety during the time the authorization will be in effect (April 14, 2013 through April 30, 2014).  For our purposes, assume this pilot’s last FAA medical examination was more than two years ago, and he will be reapplying for a new medical with his AME this month.  It is usually best to undergo a current FAA flight physical at the same time you are providing the FAA with medical records in support of a special issuance request.  That way, the periodic reexamination (usually at yearly intervals) will come in the same month that your regular FAA medical examination is due according to FAR 61.23.

This Authorization expires on April 30, 2014

Only the authorization expires one year from now.  The FAA physical examination done by your AME is still valid for twenty-four or sixty months as specified in 61.23, so you will not need to go back to your AME until April, 2014. (Assume also that this pilot is over age 40 and requires a new medical examination and application every 24 months.)

Consideration for a new Authorization will be contingent upon the following, performed in accordance with the enclosed specifications:

On or about March 1, 2014:

  1. A current cardiovascular evaluation and current lab work.
  2. A current radionuclide scintigraphy exercise stress test.

If there have been no significant adverse changes in your medical status, you have complied with all conditions of certification described in your Authorization, and I am satisfied that the duties permitted by our medical certificate can be performed without endangering public safety, the Medical Appeals Branch may then grant you a new Authorization for an additional time.  You will still be required to have your regular third-class physical examination at the frequency prescribed under the provisions of CFR 61.23.

In order to avoid a lapse in certification, the necessary testing should be completed near the date noted above and forwarded in one package to the following office.

Medical Appeals Branch, AAM 320
Aeromedical Certification Division
FAA Civil Aeromedical Institute
Post Office Box 26080
Oklahoma City, OK 73126
Medical Appeals Branch, AAM 320
Aeromedical Certification Division
FAA Civil Aeromedical Institute
6700 S. Mac Arthur Blvd. B-13
Oklahoma City, OK 73169

The FAA will allow you to send your renewal information up to 90 days prior to the expiration date of the authorization.  Even though the letter indicates 60 days is enough lead time, we suggest you take the full 90 days to allow for delays in getting testing done, receiving final reports from the doctor’s office, and other last minute delays that always seem to pop up.  Make copies of everything for your own files in case something gets lost, which does happen occasionally.  Send the information yourself; don’t depend on someone else to get the information to the FAA.  Either address will work, but the best way to send information is by overnight or registered mail to the South Mac Arthur Blvd. address.  Regular first class can go to the PO Box number.

You must promptly report any adverse changes in your medical condition to the FAA Medical Appeals Branch, AAM 320.

Because your medical is at the discretion of the Federal Air Surgeon, there is an implied “automatic invalidation” of the authorization if you have an “adverse” change in your medical condition.

Use of the above reference number and your full name on any reports or correspondence will aid us in locating your file and expediting a reply to you.


Courtney D. Scott, D.O.
Manager, Aeromedical Certification Division
Civil Aeromedical Institute

Be sure to use the PI number assigned you at the top of the letter.  This is your unique ID for the FAA to identify you among the one million-plus medical records on file.

Updated 4/15

“Much of the general aviation community is ecstatic about BasicMed,” AOPA President Mark Baker said of the new alternative to medical certification. “May 1 can’t get here soon enough!”

Pilots will be able to fly under BasicMed starting May 1, and many want to know how they can prepare in advance to take full advantage of the benefits of the rule the first day. Before flying under BasicMed, pilots must get a physical exam by a state-licensed physician, have the associated checklist completed, and then complete the online aeromedical course. It is important that pilots take those steps in that order because the exam information will need to be transmitted upon successful completion of the aeromedical course. AOPA encourages pilots to review the regulation and the advisory circular that were released so that they can get an overview of the privileges and limitations of BasicMed.

“We want to make it as easy as possible to understand and comply with BasicMed, so we’ve also created a wealth of Fit to Fly resources for pilots and physicians that further explain the rules,” Baker said.

AOPA created an interactive online quiz to help pilots determine whether they can participate in BasicMed as well as an expansive FAQ page. But many pilots have contacted AOPA with the same questions. Here are answers to the most common questions the association has received since the Jan. 10 announcement.

I want to fly under BasicMed on May 1, but how does my current medical certification factor into that?

Under BasicMed, pilots who have held a valid medical certificate any time in the decade prior to July 15, 2016, may not need to take another FAA medical exam. The 10-year lookback period applies to both regular and special issuance medicals.

In the final rule, the FAA explained that pilots whose medicals have expired should check the expiration of their most recent medical certificate to determine if they fall within the lookback period. The lookback applies to the expiration date of the medical certificate, which is determined using the “Date of Examination” on the certificate and the duration periods listed in 14 CFR 61.23(d). For those who had a regular medical certificate, the expiration date depends on their age—age 40 or over, or under 40—at the time of the exam. (Expiration dates are listed on special issuance certificates.)

“Persons age 40 or over on the date of their examination would meet the 10-year period described in FESSA if their examination was on or after July 15, 2004. This date is based on the two-year validity period for third class medical certificates issued to persons age 40 or over. Persons under age 40 on the date of their examination would meet the 10-year period described in FESSA if their examination was on or after July 15, 2003. This date is based on the three-year validity period for third class medical certificates issued to persons under 40 years of age that was in effect prior to 2008,” the rule states.

Pilots whose most recent medical certificate was revoked, suspended, or withdrawn or whose most recent application for a medical certificate was denied will need to obtain a new medical certificate (regular or special issuance) before they can operate under the reforms. Individuals who have never held an FAA issued medical certificate, such as new student pilots, will need to obtain an FAA issued medical certificate (regular or special issuance) one time only.

My medical expires before May 1. What should I do?

If your medical certificate expires before May 1 and in the meantime you wish to continue flying as pilot in command under recreational or higher certification levels, you must hold a current and valid medical certificate in order to continue exercising those privileges. Sport pilot privileges and light sport aircraft are still options for a driver’s license medical.

Pilots also have the option to let their medical certificate expire and not fly as pilot in command between the expiration of their medical certificate and the start of BasicMed on May 1. Pilots who opt to do this might consider flying with an instructor to keep their flying skills sharp during this period.

My medical certificate expires after May 1. Does that affect my ability to fly under BasicMed?

Pilots whose medical is still valid as of May 1 may opt to fly under BasicMed or their valid medical certificate. If pilots opt to fly under BasicMed, they will need to comply with the operating limitations listed in the rule. They also would need to have a physical exam, complete the associated checklists (and keep the paperwork in their logbook or a digital reproduction that can be shown upon request), and take an approved online aeromedical education course—all prior to flying under BasicMed.

I just got my medical certificate. Will that satisfy the requirements of BasicMed?

No, because BasicMed requires an exam by a state-licensed physician performed in accordance with the new rules, and the completion of the medical examination checklist. So, pilots’ third, second, or first class medical exams will not meet the requirement for the physical exam. Pilots could either fly under their current and valid medical, or take the steps outlined above to fly under BasicMed.

If I want to fly under BasicMed May 1, when do I need to go see my physician, complete the doctor’s checklist, and take the aeromedical course?

Pilots will need to complete the physical exam, associated checklists, and online medical education course before operating under BasicMed privileges. AOPA is working with the FAA to make the medical education course and physical exam checklist form available as soon as possible. 

Can a physician’s assistant perform my physical and complete the checklist?

The FAA uses the term "physician extender" to include health care providers who are not physicians but who do perform medical activities that are also performed by physicians or on behalf of physicians. According to the FAA's frequently-asked-questions web page, "Physician extenders are generally nurse practitioners or physician assistants. Registered nurses, medical technicians, and medical support personnel may assist certain elements of an examination but are not considered physician extenders. Section 2307 of FESSA requires that the examination must be performed by a state-licensed physician, but the language of the statute did not specifically exclude participation of a physician extender. As long as the physician is the signatory for the medical checklist, he or she can delegate some or all elements of the actual physical exam to a physician extender."

Can my aviation medical examiner do the physical exam for BasicMed?

Aviation medical examiners are required to be state-licensed physicians, so pilots could continue to visit their AME for the physical exam required by BasicMed.

When will the online aeromedical course and doctor’s checklist be available?

The FAA is currently reviewing the AOPA Air Safety Institute’s online aeromedical education course. AOPA and the FAA are working together to bring the course online and ensure it meets all of the BasicMed medical education course requirements. AOPA will notify pilots as soon as the course is available. The FAA will hopefully release the doctor’s checklist as soon as possible as well.

Can I fly internationally (namely to Mexico or Canada) under BasicMed?

According to the rule (based on the legislation Congress created), flights under BasicMed “must be geographically limited to operations within the United States” unless pilots receive authorization from the country in which they will be flying.  AOPA recommends calling its Pilot Information Center (800/USA-AOPA) or the country’s aviation authority to see what is needed to fly in that country.

Can I flight instruct under BasicMed?

Yes. The FAA has stated that “flight instructors meeting the requirements of this rule may act as PIC while giving flight training without holding a medical certificate, regardless of whether the person receiving flight training holds a medical certificate.” The FAA considers the flight instructor who is acting as PIC to be “receiving compensation for his or her flight instruction” under instructor privileges but is “exercising private pilot privileges while acting as PIC of the flight.”

AOPA offers answers to a host of member questions on its Fit to Fly FAQ page. Members are encouraged to contact AOPA’s Pilot Information Center (800/USA-AOPA) if they wish to discuss their specific situation one-on-one with an aviation specialist.

Topics: Advocacy, Medical Reform, Airman Regulation

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