FAA Medical Certification With ADHD: Why the Standard Track Can Be Difficult
I have now performed close to 500 FAA aviation medical examinations. Of the pilots I have seen with ADHD, I have yet to see someone successfully complete the FAA Standard Track ADHD process and receive a medical certificate.
I don't say this to discourage pilots with ADHD from pursuing certification. And this is certainly not a scientific study—500 FAA medical examinations does not mean 500 ADHD cases. It is simply something I have noticed repeatedly in my practice as an AME.
There is a good reason for it.
The FAA Has Two ADHD Tracks
The FAA currently has two pathways for applicants with a history of ADHD or ADHD medication use: Fast Track and Standard Track.
Fast Track is for people whose ADHD diagnosis or treatment is in the more distant past. Among the FAA's requirements, the applicant must have been off ADHD medication for at least four years, without ADHD symptoms or instability in academic, occupational, or social functioning during that time.
For someone who does not qualify for Fast Track, the process becomes more involved.
The Standard Track requires an in-person evaluation by a HIMS neuropsychologist (think $$$). Before the evaluation, the applicant must be off ADHD medication for at least 90 days, which must be verified with a laboratory test. The FAA also requires the applicant to be free of ADHD symptoms.
And this is where I see a problem for some pilots.
ADHD Is Real
Sometimes I meet pilots who were diagnosed with ADHD years ago but probably never had ADHD in the first place. Perhaps they struggled in school for a period of time, were prescribed a stimulant, stopped taking it, and subsequently functioned perfectly well for years.
Those cases are very different from the pilot who actually has ADHD and functions substantially better while being treated for it.
ADHD is a real disorder. Among other things, it can cause difficulty with attention, organization, planning, time management, and completing complicated tasks.
Unfortunately, completing the FAA Standard Track is itself a complicated task.
A pilot has to track down old medical records, pharmacy records and school records; communicate with several physicians and offices; make an appointment and meet with a HIMS neuropsychologist; schedule and complete drug screening; pass all neuropsychological testing; and make sure that everything eventually gets submitted correctly.
This can take months. And it's expensive.
Now ask someone who genuinely struggles with executive function to accomplish all of that—after stopping the medication that helps with executive function.
That is the paradox I have noticed.
What Happens in Real Life
I have seen pilots start the process enthusiastically and then struggle to move it forward. Records don't get requested. Emails go unanswered. Testing doesn't get scheduled. Months pass.
I cannot say that ADHD caused any particular pilot to have difficulty completing the process. There are plenty of other explanations. FAA medical certification can be confusing even for people without ADHD.
But after seeing this pattern repeatedly, I think it is worth discussing.
There is also another hurdle waiting at the end of all that paperwork.
The FAA Standard Track evaluation isn't merely asking whether a pilot can perform adequately on a battery of cognitive tests. The HIMS neuropsychologist is specifically asked to address whether the applicant currently displays symptoms of ADHD and whether the applicant currently meets diagnostic criteria for ADHD. This is a reasonable ask because because ADHD "may be" a disqualifying condition for pilots.
That puts a pilot with genuinely active ADHD in a difficult position.
So What Should a Pilot With ADHD Do?
My first advice is simple: don't stop your ADHD medication just because you want an FAA medical.
Treatment decisions should be made with the physician who is treating you. Your health comes before your FAA application.
My second recommendation is to understand which FAA pathway applies to you before starting the medical examination. A history of childhood ADHD with no medication or symptoms for many years is very different from currently taking Adderall every day and doing well on it.
Those two pilots should not walk into an AME's office expecting the same process.
If Standard Track is likely to be required, I also recommend understanding the entire process before starting it. Know which documents you will need. Make an appointment for the neuropsychological evaluation (I will give you the referrals to the appropriate evaluators). Have a realistic idea of the time and expense involved--likely many months and thousands of dollars.
A consultation with an AME like me who regularly handles complicated FAA medical cases can be useful before submitting MedXPress or making changes to treatment.
One Final Thought
I don't interpret my experience to mean that pilots with ADHD cannot become safe pilots or cannot obtain FAA medical certification. Nor do I know the success rate of Standard Track applicants nationally.
I simply find it striking that after nearly 500 FAA medical examinations, I have yet to personally see a pilot with active ADHD make it all the way through Standard Track and emerge with a medical certificate.
Maybe part of the explanation is obvious.
The FAA asks these applicants to stop ADHD treatment, remain asymptomatic, and then successfully navigate a process requiring sustained attention, organization, persistence, and completion of a rather large assignment.
For someone who truly has ADHD, that can be a tall order.
I will update this article when I have found a pilot who successfuly completes the Standard Track ADHD protocol and obtains the FAA medical certificate. I am currently helping several pilots in their pursuit of the medical certificate. We will see.
Comments