December 3, 2001
Commercial airline pilots are required, under federal law, to adhere to specified medical standards (Federal Aviation Regulations, Medical Standards and Certification, Part 67, 2001) to qualify for an Airman Medical Certificate. One regulation applies to Mental Standards (Subpart B, 67.107). Under Part 67.107 a commercial pilot must have "No established medical history or clinical diagnosis. . . of substance dependence. . . or substance abuse. . . " to be eligible to hold an Airman Medical Certificate.
After a commercial pilot has been identified as having a substance abuse/dependence problem the pilot is medically grounded under federal regulations and not able to perform the job functions of a commercial pilot. The determination whether the pilot meets criteria for substance abuse or dependency is made by a doctor qualified and knowledgeable in the area of substance abuse/dependency.
To be eligible for re-issuance of an Airman Medical Certificate, the pilot must demonstrate
". . .satisfactory evidence of recovery (DOT, FAA, Specifications for Psychiatric and Psychological Evaluations In Cases Involving Substance Abuse/Dependence, 1997). The clearest evidence of satisfactory recovery is completion of an inpatient treatment program, a comprehensive recovery program, and medical, psychological/neuropsychological and psychiatric fitness.
After the commercial pilot is discharged from an inpatient program the pilot can apply for a Special Issuance of his/her medical certificate (Subpart E, 67.401). Granting of such a waiver will allow the pilot to resume his/her piloting duties. To apply for the Special Issuance the pilot must undergo comprehensive medical, psychiatric and neuropsychological/psychological evaluations. Soon after discharge the pilot is referred to an FAA approved team of "qualified" doctors who conduct the medical, neuropsychological/psychological and psychiatric evaluations required by the FAA. The FAA maintains and distributes to the airlines a list of "qualified" doctors that are eligible to conduct the special issuance evaluations.
The standards and specifications for the psychiatric and psychological evaluations are described in the FAA publication, Specifications for Psychiatric and Psychological Evaluations In Cases Involving Substance Abuse/Dependence (Department of Transportation, Federal Aviation Administration, Revised 6-5-97). All approved doctors are knowledgeable about substance abuse/dependence consequences, treatment options and recovery, are familiar with the applicable federal aviation regulations, and are available to provide training for medical, flight and employee assistance personnel. The Medical Sponsor member of the team must be a physician who is an FAA designated Senior Aviation Medical Examiner (AME). Not only are the qualifications of the doctors specified but the parameters of the evaluations are described in the Specifications document.
The purpose and medical necessity for the psychological evaluation is to determine if there are significant neurological, cognitive, affective and/or psychomotor deficits remaining following the patient's inpatient treatment for alcoholism. The focus of the evaluation is to formulate, from the data compiled, any relevant diagnoses which will be of assistance in the development of a treatment plan. Without such information an individualized treatment plan cannot be developed.
Alcoholism is an incipient disease that has varying degrees of adverse effects upon the nervous system. Research has shown that many factors determine the extent and nature of the residual neurological effects. Alcoholism can lead to temporary or chronic brain damage. An adequate neuropsychological/psychological evaluation can identify the functional consequences and possible damage to the nervous system. In addition, there may be mental and emotional problems that are inextricably related to recovery and the effectiveness of various treatment modalities. A comprehensive neuropsychological/psychological evaluation can systemically investigate such issues and use the data generated to develop an effective treatment and rehabilitation plan.
Research has demonstrated that, for the alcoholic, a period of time is needed following cessation of drinking for the nervous system to recover from significant physiological adverse effects related to alcohol toxicity. Because of the adverse acute effects of alcohol toxicity the evaluation process takes place after discharge from an inpatient treatment program. The resultant fees, for an outpatient versus an inpatient evaluation, are less resulting in lower costs to the insurance company and to the patient. After several weeks of sobriety a better perspective of the patient's recovery and rehabilitation potential becomes apparent.
The patient's neuropsychological evaluation is medically necessary to track the patient's recovery curve and to provide and plan for appropriate treatment.
Rober W. Elliott, Ph.D., ABCN, ABPN
Diplomate in Clinical Neuropsychology
Fellow, National Academy of Neuropsychology
This reference letter was written by Dr. Robert W. Elliott of the Aerospace Health Institute in 2001 to explain the role and procedures that FAA approved doctors follow in re-certifying pilots for a Special Issuance medical upon a diagnosis of alcoholism.
(Re-printed with permission)
POST TREATMENT EVALUATIONS
Commercial Pilot Post-Treatment FAA Designated Medical/Neuropsychological/Psychiatric Evaluations
Robert W. Elliott, Ph.D.
Aerospace Health Institute
5777 W. Century Blvd, Suite 1601
Los Angeles, CA 90045
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