Medical Mondays: FAA Updates OSA Treated Status Report
In this edition of Medical Mondays, aviation attorney Matthew Bulow explains a recent update to the FAA’s obstructive sleep apnea (OSA) protocol and what it means for pilots treating sleep apnea with a CPAP, other PAP device or dental appliance.
At the end of May, the FAA replaced its previous initial and research status reports with a new OSA Treated Status Report. The updated report provides clearer guidance on when treatment is required, what physicians must evaluate and what the FAA considers adequate treatment compliance. For pilots with OSA, understanding these requirements can help avoid unnecessary delays or complications during the FAA medical certification process.
Key Insights
- The FAA Has Introduced a New OSA Status Report: The FAA replaced its previous initial and research status reports with the new OSA Treated Status Report for pilots being treated for obstructive sleep apnea.
- An AHI Above 15 Requires Treatment: Under the updated guidance, an untreated apnea-hypopnea index (AHI) above 15 requires treatment with a PAP device. Pilots should not assume positional sleeping or a dental device will satisfy the FAA’s requirements when a sleep study shows an AHI above 15.
- The Report Asks Four Key Questions: The new report focuses on whether OSA is the primary diagnosis, whether the pilot can safely fly and perform their duties, whether the current treatment is effective and whether there is evidence of adequate treatment compliance.
- Safety and Symptoms Matter: Physicians must consider whether the pilot has symptoms or other clinical concerns that could affect their ability to safely operate an aircraft or perform aviation duties.
- PAP Compliance Has Specific Benchmarks: The FAA’s updated report identifies adequate PAP use as more than 75% of nights, with an average of at least six hours of use per night and a treated AHI of five or less.
- Dental Device Users Have Different Considerations: Pilots using a dental device should not have symptoms associated with their OSA while using the device. The appropriate treatment and documentation can depend on the pilot’s individual circumstances.
- Pilots No Longer Have to Send PAP Data Directly to the FAA: Under the updated process, pilots and Aviation Medical Examiners (AMEs) are no longer required to submit PAP machine data to the FAA for further review in Oklahoma City.
- AMEs Still Need to Review Treatment Data: Although the data does not have to be submitted directly to the FAA, the AME still needs to review the information to complete the OSA Treated Status Report.
- The Update May Streamline Recertification: By simplifying the documentation process and establishing clearer treatment benchmarks, the new report could make OSA-related medical certification and recurrent examinations less burdensome for pilots and AMEs.
- Understanding the Requirements Can Help Prevent Delays: Pilots being treated for OSA should understand the FAA’s current expectations before their medical examination and work with their treating physician and AME to ensure the necessary information is available.
