Aviation Medical Test Questions with Gary Crump from AOPA

Jessica’s full interview with Gary Crump about if and how Jessica can meet the requirements of the Third Class Medical without arms.

Transcript:

(This transcript may have been edited for clarity. AOPA is a supporter of Project 2025: The Impossible Airplane)

Jessica: I'm the first armless pilot, and I'm on a mission to design the first ever foot-controlled airplane. I currently have a light sport certificate, so I need to upgrade to a private pilot's license, which is gonna require a medical. So this medical is very critical, and I'm here to speak with Gary from AOPA to ask him a couple of questions because if I get denied the medical, I can not fly at all. So I hope that it'll answer some of your questions for others who have disabilities and wanna pursue aviation.

Thank you so much, Gary, for joining us today. Can you let everyone know what you do with AOPA?

Gary: Sure, Jessica, I'm thrilled to be here. This is a great project that we're partnering with you on. My name is Gary Crump. I'm the director of medical certification group within the pilot information center here at AOPA. I've been with the AOPA for over 30 years, and pretty much that whole time has been with medical certifications. So we interact with lots of members about their medical certification issues. We interact with the FAA. So we're kinda the intermediary between pilots who have issues with their medical certificates and the FAA who's given them all the grief about their medical certificates.

Jessica: Wonderful, well, thank you so much for your time today and helping us better understand this process many of us with disabilities don't always know how it's going to be handled, and I really appreciate your time today. So I have a few questions if you don't mind, and we'll go ahead and start.

Gary: Yes, absolutely.

Jessica: Thank you, so am I actually eligible as a light sport pilot and someone with a disability, am I eligible for the Third Class medical?

Gary: Absolutely. That's one of the big misconceptions among pilots who are dubious of the FAA in general, and that's probably an appropriate thing to be cautious about the FAA, but they're a medical group.

Really, their mission is obviously safety as is all of the FAA, but at the same time, they want to get as many pilots qualified to legally fly in the national airspace as possible. So they're always looking for a way to get to yes, sometimes the pathway to a yes is a little more complicated and complex and frustrating, but the FAA does certify the vast majority of applicants who actually apply for a medical.

So the short answer is yes, absolutely. You'll be able to qualify for a medical certificate and ultimately your private pilot certificate through the process that we're gonna talk about today.

Jessica: Okay, well, thank you for that. That's really encouraging to start off to let people know that, you know, people with disabilities should be encouraged in that regard.

As far as the process, I understand it is different, and there's been a lot of talk and a lot of people who've told me about the SODA, which is the Statement of Demonstrated Ability. Do you mind further explaining what that is, and how that works in with the medical?

Gary: Certainly, SODA is the Statement of Demonstrated Ability. There are a couple of different what the FAA calls waivers. And even till just a few years ago, I was actually confused about this myself, but a waiver in certainly aeromedical speak, and even in military medical speak as well, a waiver is basically any condition or any certification that goes beyond what's required by the existing regulations that pertain to that particular operation.

So, in this case, a waiver can be either a statement of demonstrated ability, and those are issued for conditions that are considered to be static. That is the condition is what it is, and it's not likely to progress over time. An applicant who has no useful vision in one eye, that's a static condition there, it's not gonna get any worse, it's not gonna get any better. So, in that case, the FAA would be issuing a statement of demonstrated ability.

Whereas the other kind of waiver is called a special issuance authorization, and that's the one that most people are familiar with because that part of the regulation, it's part 67, the airman medical standards gives the federal air surgeon much discretion to issue medical certificates to pilots who are not otherwise qualified, but can be certificated under a time limited certificate called a special issuance authorization and both of those situations are referred to as waivers kinda generically, but we always hear it at AOPA.

We'll always talk about them individually because there's a big difference between a SODA, which as I said, is a based on a static condition that's not likely to change and a special issuance, for instance, like someone that's had a coronary stint and requires a special issuance. Well, coronary artery disease is considered a progressive disease, and so the FAA does special issuances for those people, but it's still technically a waiver, but it's a time-limited certificate and requires annual or some type of periodic reevaluation and usually additional testing just to make sure that the FAA is satisfied that the condition hasn't progressed as with, you know, the static condition with the loss of vision or in your case, an amputation or any other condition that's just considered it's not gonna change beyond where it is now.

Jessica: Wow, that really clarifies that for me because I understand people have different situations, whether it's something that's temporary or something that's permanent. So I'm wonderful, thank you for that clarification, Gary. I really appreciate that.

Gary: Sure.

Jessica: So the plan is that I will first get my Third Class medical in the Ercoupe, then take the PPL, the private pilot license test in the Ercoupe as well, and eventually move on to the RV-10 because it takes building in order to get there, but will it require that I also get, basically get the permission through the RV-10 in the same way that I had to do that with the Ercoupe. Could you clarify that, please, Gary?

Gary: That's correct, and that's really the best way to do this with your situation because you're already comfortable in the Ercoupe, you've been flying it for a long time, so you can go out. Anybody can apply for a medical certificate. They don't have to be pilots. So I mean, obviously a brand new student pilot is not a pilot yet. So anybody can apply for a medical.

So you can apply for the medical, then you'll get the authorization from the FAA to do the medical flight test in your airplane.

Then down the road, when you're ready to take your private pilot checkride, you will already have the medical certificate out of the way. And we still have yet to determine exactly how the flight standards district office will handle your private checkride. But if you've already got the SODA, basically based on the medical flight test, your private pilot checkride should just be a private pilot flight test in the Ercoupe, and then you'll be issued your private pilot's certificate.

Then next time when the RV is ready to go, you're gonna have special accommodations for that. So the FAA will authorize another medical flight test in the RV-10 'cause it's like a category in class type of a situation, you're transitioning in obviously a higher performance airplane.

So the FAA will wanna see that you can demonstrate competency in that airplane and also perform the duties as required with whatever appliances and other accommodations that'll be part of the RV-10 instrumentation. So yeah, it'll work out fine and it's a very logical way to approach it.

Jessica: That is good to hear. Any pros or cons in that area?

Gary: Well, yeah, there's always potential cons. Dealing with the FAA is, I'll say challenging for lack of a better term, primarily because of the timing and the time it takes to get correspondence back and forth from the FAA. But as long as you build in plenty of lead time for that, it should go pretty smoothly. In your situation being where you are, we'll be coordinating everything through the Western-Pacific regional flight surgeon's office, and then they, in turn, will coordinate with the flight standards district office, where you're gonna be taking the medical flight test.

So because FAA medical and FAA flight standards are two different animals within the jungle of the FAA bureaucracy. Sometimes, you know, the coordination of communication is a little bit more challenging, but if you build in enough time and be patient, then everything will work out. But sometimes you do the best you can and plan the best you can, and you just have to deal with delays and those kinds of inconveniences. So it's just like dealing with any bureaucracy, but we've thought it through. And I think we'll have a good plan for you.

Jessica: I know that period is considered a deferral period. And I guess this was the biggest question that I wondered about is during this period of time, when all the approval is processing and all that, can I still practice as a sport pilot and fly the Ercoupe?

Gary: Absolutely, there'll be no problem with that. The AME will defer your application, as you said, which means that you just won't be issued the medical certificate on the spot at the time of the examination, that'll go to the FAA as a deferral. The advantage to having that go in with a new FAA flight physical is that it gets a form of priority review and recognizing that within the FAA's aeromedical division priority has a different meaning than for the rest of us. But when you submit the application, and it's deferred, it goes through a slightly different routing system.

Once it gets into the FAA workflow system, and then probably within a few weeks, maybe a couple of months, then you'll receive a letter back from the FAA with instructions on what's gonna happen next and the authorizations for the flight tests. And so that will set the wheels in motion. So again, those are the cons.

The pros other than the timing issue are obviously, you know, the FAA is gonna be able to consider you for the medical certificate. And if the flight desk goes well, you'll be issued. And that'll be really the biggest hurdle you're gonna run into because after you deal with all this, getting your private pilot certificate is gonna be, you know, kinda like a walk in the park.

You're gonna learn a lot, obviously, but you're gonna get that private pilot certificate, and your medical is already behind you. That's one of the key things that we run into here at AOPA is brand new student pilots, they're excited, they're ready to go, and they jump right into their flight training, and they get up to the point where they're almost ready to solo, and their flight instructor then says, okay, now you need to go get your medical. And then, they show up in the medical examiner's office and have something on their medical application that does not allow the AME to issue the medical certificate. So that application gets deferred like yours will, however, then the FAA comes back and ask for more information, and it really sets these student pilots back.

So I always encourage the CFI's certificate flight instructors to encourage their students to jump on the medical first thing and get that out of the way so you don't run into a delay 'cause it's very costly if you get ready to solo and then it's another three or four months by the time you get the medical situation sorted out before you can actually solo. So you've had to spend additional money staying proficient and keeping your currency up to speed to actually do your solo. So there's lots of reasons why you wanna do the medical first.

Jessica: That's awesome. Thank you for that, Gary. And if I ever talked to anyone who wants to pursue a private pilot's license or even a light sport certificate, well, not light sport, but the private pilot's license, I'll definitely encourage them in that regard as well. So that is really good to know also that I'll be able to continue flying as a light sports certificated pilot flying the Ercoupe. So thank you for that. That's really encouraging.

Now, are there any pitfalls to avoid during the medical process?

Gary: Well, filling out the medical application is an important thing but we could do a whole seminar just on the medical application because it's complicated, it's much more complicated than someone that's seeing it for the first time might even think about, it is a legal document, and it does carry some ramifications if someone, even ended verdantly doesn't disclose information that should have been reported on the application.

So, you know, most, everybody is very honest, and they would never think about intentionally falsifying their medical application, but the FAA doesn't really like to see pilots falsify their medical applications. So it really pays to pay attention to what's in the application, read each item very carefully. There are sections in part 18 or item 18, which is the medical history section that to get kinda complicated because they're asking about past or current medical history, and it gets kinda detailed so you really wanna reread the application really very, very carefully and know exactly what you're reporting.

There are three main areas I'll just touch on those real quickly, the current medications, and that's important because they're not asking you to report medications that you're no longer taking. The questionnaire asks, are you currently using any medications prescription or non-prescription. You want to read the question carefully because a lot of people don't look at the currently and they report medications that they haven't been on in a long time, and yet that triggers a response from the FAA. The second part is the medical history section, that's item 18 that I was just mentioning.

There are about 26 or so items in section 18 that asks, have you ever at any time in your life had, or do you currently have any of the following? And there's little icons on there with dropdown menus that get into more specifics about exactly what types of medical diagnoses the FAA wants to know about. So that's the really the most important section.

And then the final section is business to health professionals in the last three years. So they're interested in pretty much any physician visits for health care providers, other than routine dental exams, routine eye exams, and aperiodic visits to an FAA aviation medical examiner.

So those three areas, you know, it's only three, but there's a lot of neat on each of those items that people wanna pay attention to so that they don't inadvertently misrepresent their medical history on the application. So that's probably a little bit more than you wanted them to know about it, but it is an important part of the process and it's the first step, and so you don't wanna get off on the wrong foot on the first step because otherwise, you get into the situation we just talked about with delays when the FAA has to come back and ask you for more information.

Every time the FAA has to reach out to a pilot and ask for information that adds potentially about three months to the process for the pilot to go out and get all the information that the FAA is asking for, mail it back into the FAA, wait for the FAA to run it through their workflow and get it reviewed again and then for the FAA to get a response back to the airman. So again, it's a bureaucratic process, and the FAA is making some really good strides to improve their efficiency, but it's a big bureaucracy. They do a lot of work out of the aerospace medical certification division, which is kinda the main repository where most of the medical certification work is done.

But again, you know, the mandate is safety. So the FAA doesn't mess around, and they're extremely critical in their review of any medical information, but because there's so much information that they're asking for, so many pilots that are being asked for information that the process takes a little bit longer than any of us would like to see.

Jessica: Yes, thank you very much. That explains why a lot of things do take awhile, and that helps other people to understand that. So that's good. Good to know ahead of time.

And my next question was, do you have any advice when I meet with this AME, obviously to get my third class medical, is there a special particular person that I should try and meet with or try to avoid?

Gary: Well, that's kinda a tricky question. So I'll answer that one somewhat carefully. Your situation, obviously Jessica, is unique. So whichever AME that you see for your flight physical is probably gonna be seeing something he or she has never seen before because of your particular circumstance and absolutely nothing wrong with that. You are in fact, you know, you on a pacesetter, you are on the pointy end of the sphere, as far as advancing people with physical disabilities, but still it's gonna be something new for an AME, most likely.

So in some cases, it's people ask, well, should I do a consult with my AME before I go in for a flight physical, I say, there's nothing wrong with that. Sometimes it's an appropriate thing to do. Sometimes it's not. The AME has basically three choices when he or she is doing a flight physical on an applicant. And the vast majority of cases, the AME is able to issue the medical certificate to the pilot at the time of the exam.

The other option is defer the application like we talked about earlier, if the AME sees that the applicant clearly doesn't meet the standards, or the AME just has, you know, yeah, not really sure, and maybe there's something in the way that the pilot presents in the AME's office, it gives the AME a little bit of a calls for concern. If the AME is not comfortable, that the FAA says, go ahead and defer it. The third and very least likely scenario is that the AME can just issue a denial of the application outright. And that doesn't happen very often because AME don't like the issue of denials and they can only issue a denial if the airman clearly doesn't meet the standards prescribed in part 67.

So I've been doing this a long time and I can probably count on one hand the number of times I've talked to a pilot where an AME actually issued a denial of his or her application. So the deferral and the issuance are really the two main things. So your AME probably, I think like we talked about previously, it would probably be a good idea to at least chat with the AME on the phone before or when you schedule the exam and explain what's going on so that they, you know, have a little idea to think about what they're gonna do, but really your exam is gonna be no different than anybody else that's gonna get a deferral.

So they'll do the basic examination, obviously you'll complete the online application and have it with you with your confirmation number when you go into the AME's office, and AME will do the exam and then defer it, and then you're off to the races. So we talk about not all AME's are created equally, the vast majority of AME's are really very dedicated, many of them are primary care physicians, but there are a lot of specialty physician, anesthesiologists, surgeons, neurologists, nephrologists, urologists.

Most of them are, and many of them are, or most of them are probably pilots and a co-pilot certificates themselves. Some of them may not be pilots, but they were military flight surgeons in a previous life. So obviously there's a lot of work involved in becoming and performing AME flight physicals. So you gotta have a certain amount of dedication and interest in talking to pilots and being really interested in aviation to be an AME.

So the vast majority of them are really, really good at what they do and they're out there to be an advocate to the extent possible for their applicants, but they are designees and they are performing the work of the FAA to administer and issue medical certificate. So you always gotta keep that in mind too. They're doing their job to again, to keep the airspace safe, but in your situation, you're otherwise very healthy.

So I think your flight physical is probably gonna go very routinely, but probably a good idea to chat with the AME beforehand, just to let them know what's going on. They're probably, whoever you choose is probably gonna be thrilled that he or she is gonna be the AME that's gonna be doing your flight physical and you know, potentially setting a trend in doing something that's never been done before. So, if I was your AME, I'd probably be pretty stoked about the idea of doing your flight physical.

Jessica: Well, thank you very much. That's so encouraging. That's awesome to hear, and I'm definitely gonna get right on it. I just have two more questions for you.

And if the FAA says no, what will be next?

Gary: Well, there is an appeal mechanism in place that's kind of a what if question, and I personally, I'll answer what if questions I don't really like to because I say, look, let's get to that point first, but yeah, there is an appeal mechanism within the structure of the regulations. In some cases, appeals can be handled strictly internally.

I'll tell you this, the majority of pilots who are denied medical certification initially based on their first application are denied because they're asked for additional information from the FAA because they need more to determine if they can issue the medical certificate and those pilots for whatever reason, choose not to provide that additional information.

So that's a high percentage of the relatively small percentage of pilots who were ultimately denied a medical certificate and even smaller percentage are denied simply because they have such a complicated medical history that the FAA just doesn't feel that they can issue the medical certificate and still maintain that mandate for safety of the airspace system.

But for those that are denied, initially a lot of times, it's just a matter of providing either the original information that the FAA asks for, or provide additional, maybe current information. Maybe they provided the FAA with information that was a year old initially, and the FAA didn't have anything else to work with so they issued the denial, and then the airmen can come back with a current evaluation. That's why the FAA always asked for a current evaluation, and in their world, current is within the preceding 90 days.

So again, these are all rules that the FAA has in place policies. And if you understand how they're working and what they're trying to do, and you give them the information that they need to make the decision, you know, a high percentage of those pilots that were initially denied will probably be able to qualify for a medical, probably a special issuance and they off and running.

So, yeah, I wanna give the FAA a lot of credit because the total number of pilots that are finally denied a medical certificate is extremely low. I mean, it's like probably in the five or 600 out of the 450. So out thousand applications that get submitted to FAA on an annual basis.

Jessica: That is so awesome to hear. Thank you for the encouraging words. That is exactly what I needed to hear for this next step.

So if I go in and the FAA gives me the green light to get the, yes, what will be the next step?

Gary: Once you've got the approvals, then this is where it gets a little, a little more, not complicated, but it's gonna be more time-consuming 'cause then you gotta start coordinating with the flight standards district office. And in this case, maybe your reasonable flight surgeon to get the actual authorization letter.

Once the FAA clears you for the flight test, they will send you a letter and they will also send a letter to the FSDO of your choice, which in your case is gonna be the Scottsdale FSDO so that they know what the FAA is expecting to see as far as what do you need to do to demonstrate that you can safely operate in the airspace? So if that can be coordinated just between say FAA, Oklahoma city, or the regional flight surgeon's office directly with the flight standards district office, and all the letters get there in a reasonable amount of time and everybody's talking to one another, it should go fairly smoothly.

The issue is, unfortunately, the issue is in so many things is still COVID. And obviously during the peak of the pandemic last year, the FSDO were basically shut down, nobody was there. And needless to say, they weren't doing anything in the way of flight tests, ramp checks, air carrier inspections, anything like that. So I think the FSDO's are now more or less back up and running, but a lot of the FAA, certainly from the Aero medical group, most everybody is still working remotely. So, thank God we have that capability to work remotely.

So we'll just have to see what's going on in real time when you get ready to do all this, but assuming the FSDO's are back at work and assuming that they are caught up with all their other priority duties, recognizing the medical flight tests are not necessarily at the top of the food chain and as far as the FSDO priority. So again, some of the things we'll need to sort out, but I understand you and Patrick have a good relationship with an inspector there and your FSDO. So that's certainly a good thing.

Again, not all FSDO's are created equally, so they all kind of operate a little bit differently, but hopefully things will be running smoothly, but again, you're a one-off Jessica. So you're gonna be doing something that they've never seen before. So it'll take a little bit of coordination and making sure everybody understands what page we're on and everybody being on the same sheet of music, but I think it's gonna go pretty well once we finally get all the paperwork there and you can get the medical flight test scheduled, and then once it's on the schedule, it should be, you know, pretty much a piece of cake.

Jessica: Oh, this is so good to hear. Actually, the moment I get off this interview with you, I'm actually gonna call up the nearest AME and schedule it and go through whatever process they need to do to line this up, because I think these words of encouragement are exactly what I needed right now in this phase of taking on a new challenge, to build an experimental airplane and be obviously licensed as a private pilot. So thank you so much, Gary.

I hope this has encouraged so many others with disabilities so that they're not afraid to go and acquire their third class medical. So thank you.

Gary: Oh, my pleasure. I just put in a plug for AOPA. If you're a brand new student pilot or prospective student pilot, we have a free six-month flight training membership. And so y'all can call us +1 (800) 872-2672, talk to our membership ladies and sign up for that free membership. And then you can have free reign to talk to us in medical, and we'll help you work through whatever process you got.

Everybody's situation is a little bit different. Most of the time it's handled kinda the same way, but you know, no two cases are exactly the same. So by all means, hopefully, this will encourage folks that have been thinking about it. And it'd been kinda been on the cusp to go ahead and take the leap and give us a call and we'll help you out as much as we can.

Jessica: Thank you. And the thing I also like about that trial membership is getting those magazines in the mail. So those are good. Those are good to flip through, especially when you're just introduced to aviation.

Gary: Flight Training Magazine is a great asset for new student pilots or student pilots who've been student pilots for a long time. So yeah, it is a great benefit, it's a great, great six-month membership. And then hopefully at the end of six months, you convert that to a regular AOPA membership because the benefits and services that we offer to pilots are really second to none. And a lot of pilots, especially those we have helped with medical certificate issues are other than the magazine, a lot of members are members because of the help that they got with their medical certificate. So that's what we're there for and we're anxious to help you out.

Jessica: Wonderful, thank you again. And we'll keep you abreast of all the new developments in this whole new process. And then just knowing that you guys are always there to support us in this has been wonderful for us and encouraging. So thank you again and have a good day.

Gary: Thanks a lot, Jessica, it's been great talking with you and we're anxious to work with you. So hang in there.

Jessica: Okay, sounds good. We'll do, take care, okay.

Gary: All right, bye-bye.

Jessica: Bye-bye. I have to admit when I first started this call, I was hesitant, I was a little scared, not sure how the FAA was gonna handle my request for a Third Class medical. And of course, that fear of getting rejected was behind in the back of my mind. But now I feel a lot more relieved.

I really wanna thank AOPA. I wanna thank Gary for helping at helping ease some of my questions and concerns, and I hope they answered some of your questions as well because this isn't just about me, this is about others with disabilities who wanna pursue aviation, because we wanna make it accessible for everyone.

And again, please be sure and visit my website, building this impossible airplane, the first foot-controlled airplane in aviation history, go to www.theimpossibleairplane.com with your ideas, with your suggestions, if you wanna help us any way, we need a lot of help 'cause this is a major undertaking, but we want to inspire the world with this newly designed foot-controlled airplane.

Thank you.