Medical Mondays: Pilots Using Testosterone? Avoid These FAA Deferral Mistakes
In this edition of Medical Mondays, aviation attorney Matthew Bulow explains what pilots need to know about using testosterone or other hormone therapies and how these treatments must be properly reported to the Federal Aviation Administration (FAA) to avoid unnecessary delays or deferrals in the medical certification process. Pilots using testosterone for low T or other medically indicated hormone therapy are required to disclose all current medications on MedXPress, including topical, oral, injectable and adjunct therapies. However, treatment alone does not automatically prevent certification if the condition is stable and properly documented.
This episode focuses on how the FAA evaluates testosterone use under the “Conditions AMEs Can Issue” (KHACI) framework. In many routine cases, Aviation Medical Examiners (AMEs) may be able to issue a medical certificate at the time of the exam if the pilot meets all required criteria. However, certain formulations, lab values and missing documentation can result in deferral to the FAA for additional review.
Key Insights
- Testosterone Must Be Disclosed: Pilots must report all forms of testosterone or hormone therapy on MedXPress under Box 17A, which covers current medications.
- Topical Testosterone Is Often Straightforward: Pilots using only topical testosterone may be issued a medical certificate if the AME determines the condition is controlled, the medication is acceptable and there are no symptoms that could interfere with safe flight duties.
- Other Forms Require KHACI Review: Oral, injectable, Testopel, anastrozole, hCG and clomiphene citrate may fall under the FAA’s KHACI (Conditions AMEs Can Issue) worksheet process if properly documented.
- KHACI Eligibility Can Allow Same-Day Issuance: If all KHACI criteria are met, the AME may be able to issue the medical certificate at the conclusion of the exam.
- Clomiphene and hCG May Require Ground Trials: Certain hormone therapies, including hCG and clomiphene citrate, may require a 7- or 14-day ground trial to confirm no adverse side effects before certification.
- Stable Condition Documentation Is Critical: Treating physicians must provide a detailed progress note confirming the condition is stable, treatment is effective, no changes are recommended and no significant side effects are present.
- Lab Work Is Required: A complete blood count (CBC) is required and hematocrit must be 54% or less for FAA consideration.
- Additional Medical History Is Reviewed: AMEs will confirm there is no history of phlebotomy, blood transfusions or venous thromboembolism (VTE) concerns.
- Not All Therapies Qualify for KHACI: Pilots using therapies outside KHACI guidance, or missing documentation, may require additional FAA review or deferral.
