Received a denial for third class medical due to OCD.

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Superfortress90

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My original medical was deferred due to an OCD diagnosis a few years ago. I took SSRIs which were found to be ineffective. Cognitive Behavioral Therapy (CBT) was recommended, and with some lifestyle changes OCD tendencies went into remission.

I've had no "symptoms" for a couple of years now, and thus haven't undergone any treatment since.

I retained an experienced AME/HIMS AME (at several hundred an hour) to support me through the process after the examination resulted in deferral. The FAA request for records came about a month later requesting the following:

"A current status report from your treating psychiatrist regarding your history of OCD. The report should address history and symptoms, diagnosis, functional capacity, treatment plan, current over-the-counter and prescription medications, and prognosis. Include the results of any current testing deemed appropriate."​

Since I wasn't actually undergoing treatment and hadn't been for a couple of years, I had no current "treating psychiatrist". The psychiatrist I had visited was through Kaiser Permanente, a HMO health insurance plan that I no longer had (I switched employers in the couple of years since treatment). I could not even message her without switching back to Kaiser. I did end up getting a very brief letter that I had to pick up in person by getting the Kaiser Permanente secretary to forward a message to her. The process took like a month and resulted in a very brief letter letter from the psychiatrist that simply outlined the date of treatment and stated that my condition was not in any way disabling at that time. She noted that she had not seen me in a few years and thus could not comment on my current condition.

Additionally, I visited my primary care provider and obtained a letter outlining the treatment that took place a few years prior. The letter indicated that I was no longer taking medication, that my condition was completely stable and did not require additional visits and that my original conditional was not in any way disabling, that I had treated the condition successfully via Cognitive Behavioral Therapy (CBT), that the diagnosis was for OCD not depression (SSRIs are sometimes used for both), and that in his professional opinion I could move forward with certification.

I addition to those documents, the "consultant" AME I hired suggested I write a personal statement outlining my history with OCD and subsequent treatment. He suggested that my case was extremely straightforward and that while issuance was not guaranteed, he did not foresee any circumstance under which a denial would occur. I sent those three documents to the FAA.

Today, two months later, I received a response. To my extreme surprise, I received a denial:

Screen-Shot-2021-12-06-at-1-50-46-PM.png


I'm a bit puzzled, but the last sentence of the first paragraph seems to suggest they think I am still undergoing therapy (which I'm not).

How shall I proceed? I'm thinking of simply sending them a letter stating that they misunderstood and that I am not currently undergoing treatment.
 
I'm sure 1 or more of the AMEs here will be along to opine.

My amateur opinion is they probably have concern that you are no longer receiving treatment for OCD, and haven't done so for many years. They don't know what's been going on since you ceased treatment.

"Obsessive Compulsive Disorder (OCD) requiring continued treatment with Cognitive behavioral therapy (CBT)"

OCD is considered a lifelong disorder, and this sounds to me like they're saying OCD requires continued CBT to make sure things are in check. I suspect if you were in active treatment they may have been more willing to further consider your application. The use of SSRIs in the past complicates the issue. You did the right thing by engaging a HIMS AME, but not all HIMS AMEs are created equal.
 
ThatOtherGuy said:
I'm sure 1 or more of the AMEs here will be along to opine.

My amateur opinion is they probably have concern that you are no longer receiving treatment for OCD, and haven't done so for many years. They don't know what's been going on since you ceased treatment.

"Obsessive Compulsive Disorder (OCD) requiring continued treatment with Cognitive behavioral therapy (CBT)"

OCD is considered a lifelong disorder, and this sounds to me like they're saying OCD requires continued CBT to make sure things are in check. I suspect if you were in active treatment they may have been more willing to further consider your application. The use of SSRIs in the past complicates the issue. You did the right thing by engaging a HIMS AME, but not all HIMS AMEs are created equal.
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Thanks for your input!

Why would they issue for someone who is "symptomatic" and undergoing active treatment versus someone who's symptoms have been in remission for a couple of years and no longer requires treatment?

I took the last sentence of the first paragraph to mean "we're denying your application because you're undergoing treatment now", which is why I'm wondering if this is just some sort of bizarre misunderstanding.
 
ThatOtherGuy said:
I'm sure 1 or more of the AMEs here will be along to opine.

My amateur opinion is they probably have concern that you are no longer receiving treatment for OCD, and haven't done so for many years. They don't know what's been going on since you ceased treatment.

"Obsessive Compulsive Disorder (OCD) requiring continued treatment with Cognitive behavioral therapy (CBT)"

OCD is considered a lifelong disorder, and this sounds to me like they're saying OCD requires continued CBT to make sure things are in check. I suspect if you were in active treatment they may have been more willing to further consider your application. The use of SSRIs in the past complicates the issue. You did the right thing by engaging a HIMS AME, but not all HIMS AMEs are created equal.
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This is it. Furthermore, because you're not being treated, they say you might not have the capability to know you need treatment. I think that's a bit of a cop out, but it's how it's viewed.

I think the FAA's medical decisions are frequently stuck in the 70s while the rest of the world marched on passing out OCD diagnoses like they were candy. But the FAA is the only game in town and they own the ballfield.
 
I'm not a physician nor am I an FAA employee, so this is a guess, but the FAA probably views it this way:

1. Applicant has OCD.
2. OCD is a permanent, lifelong condition requiring lifelong treatment.
3. The applicant is not being treated.
4. Even if the applicant appears to be doing well now, his judgement is questionable because of the untreated OCD. Furthermore, the ability to function normally day-to-day despite the untreated OCD does not ensure that he will function correctly in a cockpit when the engine catches fire.

Therefore, denied.
 
Half Fast said:
I'm not a physician nor am I an FAA employee, so this is a guess, but the FAA probably views it this way:

1. Applicant has OCD.
2. OCD is a permanent, lifelong condition requiring lifelong treatment.
3. The applicant is not being treated.
4. Even if the applicant appears to be doing well now, his judgement is questionable because of the untreated OCD. Furthermore, the ability to function normally day-to-day despite the untreated OCD does not ensure that he will function correctly in a cockpit when the engine catches fire.

Therefore, denied.
Click to expand...

Regarding #2, you're the second person in this thread to say something similar. Is that something the FAA actually believes? That seems like an outdated and absurd viewpoint. Certainly some individuals have severe and disabling symptoms, but in all of my research and in my visits with my provider it was never regarding as something requiring "lifelong treatment". My own experiences further confirm that notion.

Regardless, how would you recommend I proceed? I have been told that this denial is not a "firm" denial but simply a generic letter meaning they need more information.

As an aside, I noticed something strange. I had called the FAA to check the status of my application on November 30th, and was told the application had been "prepared" but had not yet been reviewed by the doctor. I received the denial on December 6th, however the denial letter was dated November 21st, 9 days before the application was supposedly reviewed. Any ideas how that happened? Surely they don't backdate these documents.
 
Superfortress90 said:
That seems like an outdated and absurd viewpoint.
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The FAA has many outdated and absurd viewpoints. If the docs in OKC were any good they’d be out practicing medicine and earning big bucks as neurosurgeons rather than holding civil service jobs.

And it’s not their job to treat you. Their job is to keep you out of the cockpit until you prove to them that you’re not a risk.
 
Half Fast said:
The FAA has many outdated and absurd viewpoints. If the docs in OKC were any good they’d be out practicing medicine and earning big bucks as neurosurgeons rather than holding civil service jobs.

And it’s not their job to treat you. Their job is to keep you out of the cockpit until you prove to them that you’re not a risk.
Click to expand...

Ouch, that was a zinger. Not sure if it's true.
 
Half Fast said:
1. Applicant has OCD.
2. OCD is a permanent, lifelong condition requiring lifelong treatment.
3. The applicant is not being treated.
4. Even if the applicant appears to be doing well now, his judgement is questionable because of the untreated OCD. Furthermore, the ability to function normally day-to-day despite the untreated OCD does not ensure that he will function correctly in a cockpit when the engine catches fire.

Therefore, denied.
Click to expand...

That's pretty much it.

I recommend you establish with a board-certified psychiatrist. Have your PCP refer you to one so everyone is in the loop. After a visit or two (or as long as it takes for psych to feel comfortable writing a letter outlining EVERY ITEM in the FAA's request, i.e. history and symptoms, diagnosis, functional capacity, treatment plan, current over-the-counter and prescription medications, and prognosis, etc.) then reapply for your medical and take the letter to your AME.
 
Reapplying without treatment would be futile. The AME has no decision to make, they must defer and the FAA will deny again.

The route is to get established with a HIMS AME, a psychiatrist known to the FAA. They will do a lot of testing and arrive at a decision if the OCD diagnosis was just the fad of the day or not. Caution, the testing is expensive and it might not give you the answer you want. THEN you can apply again with the psychiatrist as a sponsor and you'll have a chance.

I think...never been through this myself.
 
I will note that I did seek treatment and the condition was treated. Therefore, I weaned off medications and discontinued therapy.

One of the three documents I submitted to the FAA after their initial request for records was a note from my provider care provider noting the discontinued use of medication (and other anecdotes corroborating that the condition was in remission) in the summer of 2019.

I'm very interesting in hearing everyone's suggestions for next steps based on the letter they sent (i.ibb.co/MRnVGGy/Screen-Shot-2021-12-06-at-1-50-46-PM.png). It has been suggested that I simply send them a brief letter that highlights that I am not currently taking medication and that requests specific criteria for reconsideration.

If there's a better option than that? I'd certainly like to know what the medical professionals on this forum believe.
 
Not an AME, and agree with Half Fast, one of the AMEs here will give the bottom line.

There is a difference between OCD and OCPD. I assume your “diagnosis” is OCD. If so, the issue is that it is indeed lifelong although there are periods of remission. You aren’t “cured” as if you took an antibiotic for an infection, although you may feel that way right now. There is a high rate of relapse. There is also a high rate of comorbidity such as ADHD, anxiety and depression.

What surprises me is that your HIMS AME suggested this would be no big deal. I’m guessing your best outcome would be if testing found that you were free of all these disorders and the history is a misdiagnosis. I suppose being obsessive about germs or a perfectionist or whatever your symptoms were can be within normal range to a point, but the fact that it distressed you enough to seek help implies otherwise. The distress itself is a defining feature of OCD, if I understand correctly.

Curious what our AMEs will say, and I wish you the best whatever the outcome.

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3782190/
 
A simple letter won't solve this. The FAA deems you have OCD and the only path is to prove to the FAA's satisfaction that the diagnosis was wrong. That means their psychiatrist exams you and agrees.

There is no path to fly with an OCD diagnosis, your psychiatrist cannot say "well, he has it, but it's under control and OK".

If you do have OCD, then flying is out and for good reason. Flying isn't about concentration, it's about constantly switching your focus. There are dozens of things to check and to do and constantly switching between them.
 
What does the "experienced AME/HIMS AME" you retained to support you through this process have to say? Seems to me you've invested in their services and that would be a better avenue for "what do we do next?" than seeking internet advice.
 
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