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FAA Medical Exemption

Due to the COVID-19 pandemic and the difficulties created within the health care system, many pilots have had difficulty renewing both normal and Special Issuance medicals.

In response to this problem, the FAA, through the Assistant Chief Counsel for Enforcement, issued an Enforcement Policy on March 26. This directive states that no enforcement action will be taken against a pilot whose medical certificate expires between March 31 and June 30, should they choose to operate under this expired medical certificate. This policy applies to all classes and types of medicals, whether regular issuance, CACI (Conditions AMEs Can Issue), or Special Issuance. It also applies to both Domestic and International qualified pilots.

In practical terms, this means a pilot who cannot get in for a medical with their AME or who cannot gain the necessary medical documentation to renew a special issuance can continue to fly during the period stated above. This does not relieve the pilot of the requirement to abide by 14 CFR 61.53, which requires a pilot to self-ground if they believe or have reason to believe that they are not medically fit to exercise the privileges of the medical certificate they hold. For the airman who cannot get in for medical testing and who will be flying during the expired period of their medical, they would be strongly encouraged to discuss the condition for which they have the Special Issuance and see if it is medically sound for them to fly during the grace period.

A pilot who has access to their AME and/or has the ability to gain the necessary medical documentation should try to stay on their normal schedule of renewal. Failure to plan ahead could cause legality issues on June 30 if they are unable to get an appointment to be seen or don’t have enough time to renew a Special Issuance, particularly in cases where the Special Issuance does not allow for issuance of the medical “in the field.” Examples of this are AME Assisted Special Issuances (AASI) and the CACI program.

Common sense and some planning should allow those who need the extra 90 days to avail themselves of it and at the same time keep most people on the regular schedules of FAA medical renewal. Please contact APA’s Medical Advisors at medical-advisors@alliedpilots.org or 817-302-2400 for further details.

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