FAA adds another hoop for medicals
- Thread starter stagecoachco
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Matthew
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FAA would have to consider this: someone who aleady knows they have OSA and is on CPAP falls into one of these categories: they have an SI, or they have not reported it on their medical.
Just going out and buying a CPAP on your own, preemptively, is supposed to require a script (although it's pretty easy to work around that on-line). A prescription for CPAP pretty much means a diagnosis of OSA. So reporting you are on CPAP is pretty much an admission of OSA.
If FAA would allow AMEs to issue an SI in-office (and waive repercussions for pilots on CPAP who have not reported it) they would easily get the guys already on CPAP a simple to renew SI. It would also help the guys who think they have it, but don't want to know for sure because they don't want to deal with FAA medical. Currently an SI needs to be issued by OKC but can be renewed annually with a simple AME visit.
That just leaves the guys who probably have it, but don't know they have it.
The even simpler thing would be to eliminate the SI altogether. You have OSA, you get on CPAP and show CPAP compliance to the AME at the visit, done. Lots of simple conditions that are treated require no SI, this wouldn't be without precedent.
Thing is, if we in aviation don't work with the FAA to make this happen without rules, we will end up with the worst situation. If we say to the FAA, "Yes, this is an issue and we are willing to deal with it, how about we start with this voluntary compliance and amnesty from SI and prior reporting repercussions and get these people treated. That way we can save everybody time and money. You won't end up with the SI burden and the aviators won't end up with the high cost sleep study burdens."
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Palmpilot
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I've tried it on Internet Explorer 8 and the latest version of Firefox (25.0.1). Is there a Firefox version for the iPad?
It's a very informative personal history on this issue, so I hope you can find a way to load it. Meanwhile, I'm attaching a text file of it.
TangoWhiskey
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Link only works sometimes... Tried different browsers, probably a server farm or server load issue.
Here are screen shots of the blog entry:
JimNtexas
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Jim - In Texas!
That is the kind of discussion the FAA ought to have the aviation community.
It is possible to get the OSA SI the day you take your physical, if you have all the required documentation and if the AME is willing to call the FAA on your behalf. Like Dr. Bruce did for me.
Once you have the SI you have to update it every year by getting a statement from your doctor that you don't look sleepy and provide 31 days of CPAP machine data showing that you used the machine at least six hours a night for most of those 31 days, I don't recall the exact percentage.
TangoWhiskey
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Interesting proposal at the end of the aforementioned blog post, except I'd say "private pilot" and leave out the instrument requirement. For day VFR short flights... Not all flying is the same.
Still, addressing apnea is critical.
Still, addressing apnea is critical.
bbchien
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The intent is to let the sleep specialist make that decision.
All the insurors are going that way.
As for miley, et al.....if you don't get good advice, it's hell to get any SI. He either did pay the AME to do some homework, or he was a maroon, in which case miley should have gone someplace else.
Get good advice, you can get the SI in 31 days....
If you're a d_mn fool, and are too cheap or too stupid to get good advice, then nobody can help you. You MIGHT eventually find a chestnut. Maybe.
Kent, if you stumble around, yes it will be hard.
I got a SkyWest captain flying in 31 days.
What have you done with the real Henning? Of course if you already have the SI, screening doesn't apply to you-->you already have done the ICAW mod.henning said:
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Matthew
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That would be ideal. But there's still the problem that FAA is trying to solve right now - how do you find the pilots with undiagnosed OSA?
Unfortunately, not all AMEs are created equal. And few seem to have a direct line to OKC like Dr Chien. Some AMEs will try to work with you by calling their Regional Flight Surgeon to see if there is a way to do same-day (mine did). Some RFSs are less than helpful (like mine was), and I got deferred.
If they can do same-day SIs, I really wish all AMEs could do it and not just those who have somehow figured out the system.
Thanks Troy, interesting read, however there was one fallacy, truck drivers DO require a DOT medical.
For the pilots that won't self screen, the BMI/neck screen and sleep study requirement is still there. The difference is we create a "We can do this the easy way, or we can do this the hard way" option.
It's 85° and the sun is shining, he went diving and left me his iPad.
I'm not talking just the guys who have the SI be exempt, but all the people who who already went and got on the CPAP on their own (there is no great mystery to diagnosing OSA really, if you snore, you most likely have OSA since the snoring is caused by the obstructing). The only real question is the effectiveness percentage of CPAP at controlling the effects of OSA. If the treatment record is high enough, the record from the CPAP presented to the issuing AME should preclude any further expenses.
"You can take care of this before your next medical is due and be issued at the time of your exam, just bring the report from your CPAP machine."
bbchien
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I've done a few of those. They bring their doc's visit record, initial study and CPAP printout, I make a phone call, we issue the certificate. It's an on-the-spot kinda thing.
Exactly, it should be that easy. The AOPA and EAA should be out there making deals with some sleep centers rather than fighting for this to go through the regulatory process because that never has a good result.
Matthew
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Doing it yourself could work, with one problem.
Properly adjusted, CPAP is probably pretty close to 100% effective.
Recording CPAPs keep track of 'compliance' and that's what FAA wants to see. This means, have you used it >4 hrs/night for >75% of the time?
Some recording CPAPs will record apnea events. During a sleep study, the CPAP pressure is adjusted until you have a minimum number of apneas, less than what constitutes OSA. This is the prescribed setting. You would need a CPAP that records apneas to do this yourself. Just take a couple nights, adjust the pressure, and check the results the next morning.
The problem: without a sleep study, I don't know if you can differentiate OSA from CSA. And CSA is a denial.
bbchien
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If your screening overnight tracing has no desats, you have neither CSA nor OSA.....sigh.
Guys.........I am getting a bit tired of reposting everything for everyone everytime.
What's the difference between OSA and CSA?
Matthew
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Sorry. I'm mixing up too many different posts. Yeah, that would be a quick, easy screening.
Matthew
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Obstructive SA - tissue in the back if your throat clogs your airway.
Central SA - your nervous system fails to trigger you body to breathe.
OSA is common, but I don't know the % of CSA.
Well then the machine will determine if it's OSA or CSA, if it's OSA the machine will be effective, if it's CSA the machine will not and the apneas will be recorded.
Single percentage points of the population. Not related to weight afaik. Not certifiable.
Even less common is true narcolepsy. It is also a neurologic disorder and oddly enough associated with some antigen on your white blood cells. Again, very uncommon, presents early in life, not certifiable under any circumstances and pretty much precludes you from safely driving a car.
Palmpilot
Touchdown! Greaser!
I apologize if this has been covered previously:
At least one person reported that getting treated for OSA made it much easier to lose weight (70 pounds IIRC). If a person loses enough weight, is it possible that they could get to a point where they no longer need treatment for OSA, and if that happens, do they no longer need an SI, reports from their doctor, etc.?
At least one person reported that getting treated for OSA made it much easier to lose weight (70 pounds IIRC). If a person loses enough weight, is it possible that they could get to a point where they no longer need treatment for OSA, and if that happens, do they no longer need an SI, reports from their doctor, etc.?
denverpilot
Tied Down
Doc. I've met Mike. He's not stupid. And MOST AMEs (note the emphasis on MOST) are god-damned clueless on special issuances OR god-damned lazy about knowing EXACTLY how to get them office-issued. If most of life follows the 80/20 rule, you are on the 20 side of the line. You need to realize that before you rant.
The AVERAGE JOE PILOT thinks all AMEs are created equal. They don't even know about Senior vs Non- Senior, let alone things like HIMS. FAA doesn't exactly push much out in the way of educational material directed at PILOTS because they can't play favorites. In public. But behind the scenes or if you dig carefully and willfully into their documentation aimed at DOCTORS you'll find the different AME "ratings" and real use that yes, they DO play favorites.
Let's no even discuss the BS that is the game of "cut the number off the paper" in MedXpress. Even one other Doc here says he won't do that. I'm fine with it. But he's not the only one.
You can't rant that normal folk are somehow neglectful of funding good advice when 80% of the AMEs are clueless about how to do this stuff. Like I said, I've met Mike and he's not a stupid guy. He's also *clearly* willing to spend money if needed just by reading his story.
There's no process to follow to FIND the AMEs with good advice. As best as I can tell you're one of a handful of AMEs who even engage with the pilot community in a social media or readily accessible way. The rest say, "fill out MedXpress, see you in a week". That's IF you even talk to them and not a receptionist. I've seen my AME for a portion of the exams I've had for years and most of the time I'm sitting in the waiting room staring at his reception desk, or his staff is walking me back to the hearing test chamber and the pee cup. If I've truly seem the guy for more than ten minutes a visit, I'd be amazed.
If I thought I had a medical condition FAA would be displeased with (learning it from YOUR posts not his, that's for sure...) I'd like to THINK he'd schedule a consult, non-MedXpress visit to discuss and I'd like to THINK he knows the things needed to issue in-office, and I'd like to THINK he is that good. But if wishes were fishes...
Maybe what you're missing here Doc is that the process to find a *truly knowledgeable* AME doesn't exist and then you end up like Mike, jumping through hoops like a dog at a circus.
You wanna publish a list of AMEs you'd say know everything you do and are at least 95% as effective as you? I bet you cold charge $50 a copy. But I know that's unrealistic. The 80% would hate you 20%'ers.
Now apply the above to the new rule. 80% of pilots who need the new SI will hit a moron or lazy AME who won't push to know how to issue in-office or have all ducks in a row for a fast issuance. They'll go through what Mike did.
Saying he needed better advice doesn't say where to he that advice, Doc. Everyone in the country could come to Peoria but I think you'd probably not like that too much.
Tell us where you'd start looking for clueful AMEs who never post online? A list of Senior AMEs from FAA is basically a crap shoot with 80/20 odds. (No offense to AMEs intended. This problem extends into Primary Care, specialists of all sorts, etc. Anyone can be charismatic enough to get word of mouth that they're a "great" Doc, but you can't find stats on their patient's recovery rates, malpractice suits settled out of Court, nothing. There's a few websites but they're loaded with crap.)
If you are sick you'll spend a lot if energy if you have it, hunting a truly great Doc. If you're not sick or don't know you just tripped over an FAA land mine like Mike did, you're at the mercy of a useless AME list on the FAA website. Especially if you don't hang out in places that you and a tiny handful of active AMEs on the Internet do, Doc.
Be realistic. The rule is going to screw a lot of people because the AMEs don't prepare as well as you do. That's both a commendation on you and a damnation on the way the average pilot finds an AME. You've taught a lot of people to partner with their AME as an important part of their healthcare. MOST pilots view their AME as the same as having to renew a driver's license. Bureaucratic expensive BS. They figure their health care is between them and their GP. They look up the bureaucrat (in their minds) from a list and go in expecting to walk our with a medical or a clear indication of when they'll have one.
They get "it's being processed". See Mike's story. That's unacceptable. The parallels to States that changed to "must issue" on handgun permits are pretty close. I'm not sure that's a good idea for Second Class and higher, but I'd back it wholeheartedly for Third Class and nothing big enough to require a Type Rating. Must issue in 90 days or state why not and give a hard deadline for issue in no more than another 60 days. Adjust as you see fit, but you probably get my bigger point. People need closure on red tape. Give me a date I can plan for. Not, "It's lost in a pile at OKC somewhere."
So there's MY rant. What do you think? I think the process of finding good AMEs is busted. How about specialists like HIMS for various afflictions? Guys who are published as being specialists for OSA, heart conditions, oncology, etc? Even better, MedXpress explicitly routes you to those Docs? Click the heart box, it recommends from only a list of heart specialists who the FAA knows have their crap together. "You may see a different AME but this could considerably lengthen your application and approval." Go another step. MedXpress prints out checklists for conditions and sample letters for Docs?
The whole thing is still run like it's 1960.
flyingcheesehead
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Yeah, he only got that one partially right. However, this statement is true:
http://miley.us/2013/12/07/apnea-no-slapping/ said:
Key being "federally authorized" - There is no DOT equivalent to an AME. You can get a DOT medical from any MD, or DO, or even a PA, LPN, or chiropractor. 49 CFR 390.103(a)(1). And the medical qualifications to drive a CMV are ridiculously easy to pass - This is all of them:
49 CFR 391.41(b) said:
denverpilot
Tied Down
My lord autocorrect trashed that. Oh well.
Palmpilot
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What makes the difference between that and the 31 days that your SkyWest client experienced?
Matthew
Touchdown! Greaser!
I think that's the case. If surgery (UPPP) or weight loss can result in no more OSA, I think you can get the SI dropped. I don't know what tests are required to prove you are clean. And, if it's due to weight loss, you better be sure to keep it off.
denverpilot
Tied Down
AOPA will start offering a free CPAP mask for renewals. Heh heh. Compete with travel carry bag embossed with their logo. :-?
I rolled my eyes at their stupid "Plus" membership offer, held my nose, and renewed this year. I know Doc doesn't agree with their approach but at least they did something about, a very expensive and intrusive rule change.
Probably the wrong thing, but at least they acted. That's worth $45.
bbchien
Touchdown! Greaser!
Okay, so you asked. I don't really want to go down this sidewalk....
Let me give you a little insight into medxpress, however...... This is actually bootleg software that ran well for 15 years before OMB stuck their paws into it.
Warren started as head in ?1995? and immediately realized the agency could not go on the way it had. "We're trying to find the CHART"(a paper chart). There was no line item for this project. There were three empty slots at CAMI- he changed the job descriptions and hired 3 Northrup Grumman guys on "long term loan" and had them write the windows app.
It didn't become a problem until OMB declared no tech support line items that were outside their Virginia IT home. Even after March 15th's migration crisis CAMI could not attract enough attention from OMB to garner tech attention to make the migrated database work again. That took a whole quarter to get that fixed.
They just cannot leave working stuff alone. I have a private nickname for the OMB and one the words in the appellation is "clown".
*****
AS for finding a competent AME: FAA cannot guide you to a private party. That is verboten. Pilots have to fix that.
Years ago I was travelling to Commander's Palace in a C150 to burn some hours with a young IR student who had to fry 5 hours. We asked for Cape Giradeau. KC center asked why? (Post 9-11, IFR, and it's "code orange"). We said, LUNCH!. They said, we can't tell you the name of the place, but all the airmen go to KSIK. "The name and phone is apparently engraved on the public phone at the FBO" We said "thanks" and that was my first throwed roll indigestion.
They cannot send you to one private guy or another. That would be comingled interests and would be covered under a number of corruption statutes.
For years I had a string of complicated airmen from the west side of the Chicago burbs. Couldn't figure out why they were coming....turned out there was a guy at the DPA FSDO whose 747 captain spouse I had helped out, and she got the 48 hour turnaround (when my RFS could not. I can call the a/m's doctor, he can't!). Now I'm jus sayin.....
So pilots have to fix the referral system.
So that's up to you, Nate, Mike, and everyone else here.
My comment on the Red Board (which I still moderate), when someone asks for referrals and they appear.... is "hmmmm. Board is working the way is it supposed to".
So fix it.
Mike could have gone to AOPAs board, here or to any of a number of them. the guy's will tell you what they think....If it's not working out, TRY SOMETHING DIFFERENT!
...AND never do an exam if you don't already know you have "sufficiency".
I am a subscriber to the Norman Schwartzkoph rules of engagement. You take fewer casualties that way. I don't have to have an overwhelming case, but it does have to be sufficient, and no applications go though me without meeting sufficiency. You probably would not be surpised by the number of comments to the effect, "but my doc says I'm fine isn't that good enough? Why do we have to get his additional letter?"..........
"BECAUSE IT's NOT GOOD ENOUGH. YOU WANNA GET DENIED?"
"For What did you engage me?"
Even after I send the list of requirements, the pilots all uniformly ask, well can I do without item #3?
"NO. YOU'LL GET DENIED".
On and on it goes. Pilots think a good AME is paid for what he does. NOT TRUE. He's paid for what he knows.
Or the most important one of all, "Advanced".
Well if the AME will not engage with the a/m prior to the 8500, that's a pretty powerful anti-selection criterion, isn't it?
Now that would appear REALLY self-serving....
Being processed. What a load of baloney. It's sitting in a work queue for a mid level document examiner. The AME calls to determine documents are visible in system, then waits in the queue to talk to the medical officef of the day, obtains approval.Now apply the above to the new rule. 80% of pilots who need the new SI will hit a moron or lazy AME who won't push to know how to issue in-office or have all ducks in a row for a fast issuance. They'll go through what Mike did.
Saying he needed better advice doesn't say where to he that advice, Doc. Everyone in the country could come to Peoria but I think you'd probably not like that too much.
(No offense to AMEs intended. This problem extends into Primary Care, specialists of all sorts, etc. Anyone can be charismatic enough to get word of mouth that they're a "great" Doc, but you can't find stats on their patient's recovery rates, malpractice suits settled out of Court, nothing. There's a few websites but they're loaded with crap.)
If you are sick you'll spend a lot if energy if you have it, hunting a truly great Doc. If you're not sick or don't know you just tripped over an FAA land mine like Mike did, you're at the mercy of a useless AME list on the FAA website. Especially if you don't hang out in places that you and a tiny handful of active AMEs on the Internet do, Doc.
Be realistic. The rule is going to screw a lot of people because the AMEs don't prepare as well as you do. That's both a commendation on you and a damnation on the way the average pilot finds an AME. You've taught a lot of people to partner with their AME as an important part of their healthcare. MOST pilots view their AME as the same as having to renew a driver's license. Bureaucratic expensive BS. They figure their health care is between them and their GP. They look up the bureaucrat (in their minds) from a list and go in expecting to walk our with a medical or a clear indication of when they'll have one.
They get "it's being processed". See Mike's story.
Again, unacceptable. The AME has to pick up the phone and call. If he won't do that, WRONG AME. Find another. Many of my pilots end up down here when that happens.
Sure sounds like Warren, to me.
I think most airmen never tried.
Those lists exist. They're published on FAA.gov. I don't harp on them as that would be self serving, as ....I'm on all the lists. I AM NOT HERE TO HOLD OUT.
That is amazingly similar to what Warren Silberman complained to me about in 2010.
Let me give you a little insight into medxpress, however...... This is actually bootleg software that ran well for 15 years before OMB stuck their paws into it.
Warren started as head in ?1995? and immediately realized the agency could not go on the way it had. "We're trying to find the CHART"(a paper chart). There was no line item for this project. There were three empty slots at CAMI- he changed the job descriptions and hired 3 Northrup Grumman guys on "long term loan" and had them write the windows app.
It didn't become a problem until OMB declared no tech support line items that were outside their Virginia IT home. Even after March 15th's migration crisis CAMI could not attract enough attention from OMB to garner tech attention to make the migrated database work again. That took a whole quarter to get that fixed.
They just cannot leave working stuff alone. I have a private nickname for the OMB and one the words in the appellation is "clown".
*****
AS for finding a competent AME: FAA cannot guide you to a private party. That is verboten. Pilots have to fix that.
Years ago I was travelling to Commander's Palace in a C150 to burn some hours with a young IR student who had to fry 5 hours. We asked for Cape Giradeau. KC center asked why? (Post 9-11, IFR, and it's "code orange"). We said, LUNCH!. They said, we can't tell you the name of the place, but all the airmen go to KSIK. "The name and phone is apparently engraved on the public phone at the FBO" We said "thanks" and that was my first throwed roll indigestion.
They cannot send you to one private guy or another. That would be comingled interests and would be covered under a number of corruption statutes.
For years I had a string of complicated airmen from the west side of the Chicago burbs. Couldn't figure out why they were coming....turned out there was a guy at the DPA FSDO whose 747 captain spouse I had helped out, and she got the 48 hour turnaround (when my RFS could not. I can call the a/m's doctor, he can't!). Now I'm jus sayin.....
So pilots have to fix the referral system.
So that's up to you, Nate, Mike, and everyone else here.
My comment on the Red Board (which I still moderate), when someone asks for referrals and they appear.... is "hmmmm. Board is working the way is it supposed to".
So fix it.
Mike could have gone to AOPAs board, here or to any of a number of them. the guy's will tell you what they think....If it's not working out, TRY SOMETHING DIFFERENT!
Knowledge that the documents that he gathers meet federal spec. Or I send him back to the doc, with a HIPAA so that guy can disclose to me, and a letter saying WHAT WE NEED FROM HIM IN WRITING. You don't want to present less than what the spec requires-->rejection.
...AND never do an exam if you don't already know you have "sufficiency".
I am a subscriber to the Norman Schwartzkoph rules of engagement. You take fewer casualties that way. I don't have to have an overwhelming case, but it does have to be sufficient, and no applications go though me without meeting sufficiency. You probably would not be surpised by the number of comments to the effect, "but my doc says I'm fine isn't that good enough? Why do we have to get his additional letter?"..........
"BECAUSE IT's NOT GOOD ENOUGH. YOU WANNA GET DENIED?"
"For What did you engage me?"
Even after I send the list of requirements, the pilots all uniformly ask, well can I do without item #3?
"NO. YOU'LL GET DENIED".
On and on it goes. Pilots think a good AME is paid for what he does. NOT TRUE. He's paid for what he knows.
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timwinters
Ejection Handle Pulled
Okay...550 posts and no one has asked the most important question...as least if they did, I didn't see it.
Will this be Santa's last year to fly?
Will this be Santa's last year to fly?
ClimbnSink
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Greg
NORAD will finally shoot him down this year. Do they still do that radio broadcast?
He's already on CPAP.
denverpilot
Tied Down
Here's the only complication, Doc. FAA is already in the biz of choosing one private Doc over another. It's called the AME certification system.
I appreciate all the other info.
As far as pilots setting up an AME rating system, I fear that'll work as well as the websites that try to do that for other Docs and Dentists.
The only way it really gets fixed is from within. Oh well.
I appreciate all the other info.
As far as pilots setting up an AME rating system, I fear that'll work as well as the websites that try to do that for other Docs and Dentists.
The only way it really gets fixed is from within. Oh well.
JimNtexas
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Jim - In Texas!
Thank you for proving my point. Those studies show that going 20+ hours without sleep degrades performance.
All you pilots with no OSA and BMI < 30 raise your hand if you think your performance would not be degraded after being awake for 20+ hours....anybody, no hands? I didn't think so.
These studies show that going with out sleep makes you sleepy, and your performance degrades when you're sleepy. DUH!
The studeis do NOT show that someone with OSA is running around like he was drunk!
Saying OSA == being drunk is BS!
I'm glad we agree on this.
JimNtexas
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Jim - In Texas!
I am that person, and I know (both subjectively and with data from a recording pulse oximeter) my OSA is much less serious than it was before I lost weight. Between now and next June I need to decide if I want to pay for another sleep study to see if I still have OSA. I'd like to know.
I don't know if the FAA even thinks that OSA can be cured with weight loss, I've heard different opinions on that.
I think it would depend, I know some slender people that do that hitching/stop breathing for minute+ snoring as well.
bbchien
Touchdown! Greaser!
Jim if you improve to the point where a sleep study shows no further OSA, and you can maintain the weight loss and show no desats buy sequential home overnight saturimetry recordings, after 3 years we can get you back in the regular issuance pool.
So, the answer is "yes".
Jim, mnewb1's data do not serve your point. Untreated OSA is sleep deprivation. In untreated OSA, just because one sleeps- you don't get rest. You fail to get any REM sleep, and that's sleep deprivation...you confuse sleep with effective rest......yeah 20+ 30+ 50+ hours....
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Matthew
Touchdown! Greaser!
The sleep study EEG will show that at each apnea, you actually 'wake up' into that stage 1 sleep where you are not really awake and not really asleep. You aren't in the deeper stages of sleep long enough to get meaningful rest. So yes, it is sleep deprivation.
timwinters
Ejection Handle Pulled
Here's one...I think...
I heard this morning that as body weight goes up, the size of the brain goes down and cognitive function is also reduced. Supposedly over 140 studies support this claim.
It's my understanding that this has nothing to do with sleep apnea, but rather just being overweight.
I have no idea if there's any merit, maybe our docs can chime in.
Here's an interesting perspective on BMI.
http://espn.go.com/blog/truehoop/post/_/id/23776/putting-the-nba-to-the-fat-test
Maybe the FAA could hire ESPN to do the analysis of BMI in pilots generally and in accidents specifically and see if there is correlation...
Certainly Tilton's position would be strengthened if the fat pilots were overrepresented in the accident population..... But I'm thinking it will not be statistically different.
http://espn.go.com/blog/truehoop/post/_/id/23776/putting-the-nba-to-the-fat-test
Maybe the FAA could hire ESPN to do the analysis of BMI in pilots generally and in accidents specifically and see if there is correlation...
Certainly Tilton's position would be strengthened if the fat pilots were overrepresented in the accident population..... But I'm thinking it will not be statistically different.