Medical Mondays: Your Medical Condition Isn't Listed? Here's What the FAA Will Do
In this edition of Medical Mondays, aviation attorney Matthew Bulow explains how the Federal Aviation Administration (FAA) evaluates pilots whose medical conditions are not specifically listed in the FAA Aviation Medical Examiner (AME) Guide. According to Bulow, the FAA updated the AME Guide on March 25, 2026 to provide aviation medical examiners with clearer instructions for handling conditions that fall outside existing published guidance. Rather than automatically deferring every unlisted condition for lengthy FAA review, AMEs now have greater discretion to determine whether a pilot may safely hold a medical certificate based on the risk of incapacitation.
This episode explains the FAA’s decision-making framework when evaluating uncommon or undefined medical conditions. The key issue for AMEs is whether the condition itself, or the treatment used to manage it, could increase the risk of sudden or subtle incapacitation while flying. If the AME determines the risk is not elevated, the medical certificate may be issued during the appointment. However, if the condition presents uncertainty or possible increased risk, the application must still be deferred to the FAA for further review. Bulow also emphasizes that even when an AME issues a certificate immediately, the FAA retains the authority under 14 CFR 67.407 to request additional records or reverse the issuance within 60 days pending further evaluation.
Key Insights
- Unlisted Conditions Are Not Automatic Disqualifiers: A condition not specifically listed in the AME Guide does not automatically prevent a pilot from obtaining medical certification.
- FAA Updated the AME Guide in 2026: The FAA revised the AME Guide on March 25, 2026 to provide AMEs with clearer guidance for evaluating undefined medical conditions.
- AMEs Now Have Greater Discretion: Aviation Medical Examiners may use their qualified medical judgment when evaluating conditions without clear FAA policy guidance.
- Risk of Incapacitation Is the Primary Concern: The FAA focuses on whether the condition or its treatment could increase the risk of sudden or subtle incapacitation.
- Some Conditions May Be Approved Immediately: If the AME determines the condition does not increase incapacitation risk, the medical certificate may be issued during the appointment.
- AMEs Must Document Their Reasoning: When issuing a medical certificate for an unlisted condition, the AME must document the rationale supporting the decision.
- The FAA May Still Reevaluate the Certificate: Under 14 CFR 67.407, the FAA may request additional information or reverse an issuance within 60 days.
- Uncertain Cases Still Require Deferral: If the AME cannot confidently determine the risk level, the application must be deferred for FAA review.
- Medical Documentation Can Speed Up Review: Pilots should provide recent physician progress notes, testing results and treatment records to help expedite FAA evaluation.
- Pilots Should Not Panic Over Undefined Conditions: Many unlisted conditions can still be evaluated successfully depending on the individual medical history and overall risk profile.
