Not renew 3rd class and only go basicmed?

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basicmed-gal

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Is it possible to just let a 3rd class expire, not renew it, and continue flying under an existing basicmed? Any issues with renewing a basicmed in that situation?
 
Ok cool! Thank you. I had some trouble with FAA and medicals in the past and just wanted to be sure. Basicmed is no problem for me.
 
Be sure to get "off" your SI properly:

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Thread 'Transition from Class III Special Issuance to Basic Med'

First-time poster here. I am a PPL SEL in the Midwest that flies just for recreational purposes, 25-30 hrs a year. After being out flying for 30 years, I got a Class III physical in 2017, 2019, and 2021 with no problems. However, my latest renewal attempt in April 2023 resulted in a very unexpected deferred due to a minor procedure that was successfully completed 18 months earlier with no problems. After 18 months of frustration last week I finally received my Class III Special Issuance (SI) medical certificate and Statement of Demonstrated Ability (SODA) in the mail. It states the...
 
Kenny Phillips said:
As long as you've never had a denied/deferred FAA medical, of course.
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As long as your current or last medical held has not been deferred or denied. As mentioned, if on an SI, make sure to comply with all the requirements of the current issuance period up to the final day. You do not have to wait for expiry to actually get your BM in place, however.
 
GeorgeC said:
Be sure to get "off" your SI properly:

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Thread 'Transition from Class III Special Issuance to Basic Med'

First-time poster here. I am a PPL SEL in the Midwest that flies just for recreational purposes, 25-30 hrs a year. After being out flying for 30 years, I got a Class III physical in 2017, 2019, and 2021 with no problems. However, my latest renewal attempt in April 2023 resulted in a very unexpected deferred due to a minor procedure that was successfully completed 18 months earlier with no problems. After 18 months of frustration last week I finally received my Class III Special Issuance (SI) medical certificate and Statement of Demonstrated Ability (SODA) in the mail. It states the...
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Yep. The key is that you must continue to abide with the conditions of the SI until the underlying medical certificate has expired. .
 
basicmed-gal said:
I had some issues a while back, where it was deferred while we sorted it out. But after it was reinstated (with a special issuance) I got a basicmed, which I still have and plan to renew.
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This is exactly what it is for. Fly, have fun.
 
Kenny Phillips said:
I used poor wording. It cannot be "in deferral" when you apply for BM.
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Do you have a reference for that? There may be some risk involved but I'm not convinced that's true either.

Here is what the reg says in terms of the prohibitions to operate under BasicMed [snip]
The most recently issued medical certificate— ... Cannot have been suspended or revoked.​
The most recently issued Authorization for a Special Issuance of a Medical Certificate cannot have been withdrawn.​
The most recent application for an airman medical certificate submitted to the FAA cannot have been completed and denied.​

I don't see "deferred," "in deferral," "pending," or anything other than suspension, revocation, and denial.
 
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basicmed-gal said:
Is it possible to just let a 3rd class expire, not renew it, and continue flying under an existing basicmed? Any issues with renewing a basicmed in that situation?
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A better answer is, it depends....

If, for instance you had an SI for substance abuse, you let that medical expire and went to Basic Med. Then you choose not to continue monitoring or otherwise keep your record of sobriety with your HIMS AME. You can then stay Basic Med, happily every after. However, if you then need an SI for another condition, cancer, heart, etc, you will then need to get the SI for the new condition and also, likely, start all over and get an SI for the Substance issue.
 
Flyxaos said:
A better answer is, it depends....

If, for instance you had an SI for substance abuse, you let that medical expire and went to Basic Med. Then you choose not to continue monitoring or otherwise keep your record of sobriety with your HIMS AME. You can then stay Basic Med, happily every after. However, if you then need an SI for another condition, cancer, heart, etc, you will then need to get the SI for the new condition and also, likely, start all over and get an SI for the Substance issue.
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That's an interesting observation. I haven't heard of anything indicating how the FAA handles that. but I note that the regulation for those conditions requires "obtaining an Authorization for Special Issuance of a Medical Certificate for each of the following..."

That sounds like obtaining an SI for the specific condition and not necessarily a medical certificate. Even the SI regulation itself appears to decouple the SI from the certificate. You can get the medical certificate if you have the SI and meet the other qualifications, but it doesn't say you must het the medical certificate.

The Federal Air Surgeon may authorize a special medical flight test, practical test, or medical evaluation for this purpose. A medical certificate of the appropriate class may be issued to a person who does not meet the provisions of subparts B, C, or D of this part if that person possesses a valid Authorization and is otherwise eligible.​

Edit: I'll give an example of what I mean by decoupling based on a real SI, although I am making up the dates and not giving the reason for the SI.
The SI is dated December 2024.​
The SI expires May 31, 2026​
The current medical certificate issued in accordance with the SI expires May 31, 2025.​
Basically, all the SI does is authorize an AME to issue a new certificate after May 31, 2025 if certain conditions are met.
 
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midlifeflyer said:
That's an interesting observation. I haven't heard of anything indicating how the FAA handles that. but I note that the regulation for those conditions requires "obtaining an Authorization for Special Issuance of a Medical Certificate for each of the following..."

That sounds like obtaining an SI for the specific condition and not necessarily a medical certificate. Even the SI regulation itself appears to decouple the SI from the certificate. You can get the medical certificate if you have the SI and meet the other qualifications, but it doesn't say you must het the medical certificate.

The Federal Air Surgeon may authorize a special medical flight test, practical test, or medical evaluation for this purpose. A medical certificate of the appropriate class may be issued to a person who does not meet the provisions of subparts B, C, or D of this part if that person possesses a valid Authorization and is otherwise eligible.​

Edit: I'll give an example of what I mean by decoupling based on a real SI, although I am making up the dates and not giving the reason for the SI.
The SI is dated December 2024.​
The SI expires May 31, 2026​
The current medical certificate issued in accordance with the SI expires May 31, 2025.​
Basically, all the SI does is authorize an AME to issue a new certificate after May 31, 2025 if certain conditions are met.
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That is my situation. SI expires 2028, Third Class medical expires, Oct 2026. BM in place. Just going to let the Class 3 expire, and notify the FAA I am transitioning to BM prior to the Class 3 expiration.
 
Rcmutz said:
and notify the FAA I am transitioning to BM prior to the Class 3 expiration.
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What notification? I took the class and filled out the basicmed forms. My class III was still active when I did it.

Did I miss a step? I went through the AOPA site to get it.
 
That is the distinction that sometimes gets confused, the authorization for a SI medical certificate and the actual medical certificate. The authorization gives the AME/HIMS AME the authority to issue a medical, over the specified time period, if all the condition in the SI authorization are met. The authorization is usually for a period of several years and a medical certificate is valid for a shorter period. One does not have to wait until the authorization period is over, they just have to opt to not renew a medical certificate at its expiry. At that point, assuming all conditions were complied with until the time of expiration, you are now in the position of having held a valid medical class and can qualify for flying on BM only.
 
Rcmutz said:
That is my situation. SI expires 2028, Third Class medical expires, Oct 2026. BM in place. Just going to let the Class 3 expire, and notify the FAA I am transitioning to BM prior to the Class 3 expiration.
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There is no need to notify the FAA that you're going to basicmed. Just let the class 3 expire, and make absolutely sure the AME handling the SI doesn't send anything to the FAA regarding the SI after the class 3 has expired, otherwise the FAA may interpret it as a new class 3 application.
 
pfarber said:
What notification? I took the class and filled out the basicmed forms. My class III was still active when I did it.

Did I miss a step? I went through the AOPA site to get it.
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It an unofficial recommendation for those with a current SI that has a pilot obligation. It’s a proactive step so the FAA doesn’t “accidentally” think you haven’t complied with the SI. Just to avoid the hassle.
 
Dana said:
...make absolutely sure the AME handling the SI doesn't send anything to the FAA regarding the SI after the class 3 has expired, otherwise the FAA may interpret it as a new class 3 application.
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The notification letter is how you make absolutely sure.
 
Can’t you just skip Basic Medical and go straight to Mosaic ? Flying a Mosaic plane of course with Mosaic restrictions? With simple driver’s license.
 
bonefishpete said:
Can’t you just skip Basic Medical and go straight to Mosaic ? Flying a Mosaic plane of course with Mosaic restrictions? With simple driver’s license.
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Sure. You can do that without ever having had an FAA medical. And you can do it in the OP's scenario, i.e., let a 3rd class expire, not renew it, and continue flying under under sport privileges and limitations. But the SI and deferral issues mentioned in the thread exist there too.
 
midlifeflyer said:
It an unofficial recommendation for those with a current SI that has a pilot obligation. It’s a proactive step so the FAA doesn’t “accidentally” think you haven’t complied with the SI. Just to avoid the hassle.
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As is the recommendation to let the AME and his staff know you intend to not renew and terminate any HIPAA releases. To prevent a proactive provider from starting the renewal process on your behalf without even knowing it.
 
Be careful. HIMS authorizations have monthly requirements and yo have to satisfy them right up to the end of the current certificate (the "not valid for any class after __/__/____ date).
 
midlifeflyer said:
That's an interesting observation. I haven't heard of anything indicating how the FAA handles that. but I note that the regulation for those conditions requires "obtaining an Authorization for Special Issuance of a Medical Certificate for each of the following..."

That sounds like obtaining an SI for the specific condition and not necessarily a medical certificate. Even the SI regulation itself appears to decouple the SI from the certificate. You can get the medical certificate if you have the SI and meet the other qualifications, but it doesn't say you must het the medical certificate.

The Federal Air Surgeon may authorize a special medical flight test, practical test, or medical evaluation for this purpose. A medical certificate of the appropriate class may be issued to a person who does not meet the provisions of subparts B, C, or D of this part if that person possesses a valid Authorization and is otherwise eligible.​

Edit: I'll give an example of what I mean by decoupling based on a real SI, although I am making up the dates and not giving the reason for the SI.
The SI is dated December 2024.​
The SI expires May 31, 2026​
The current medical certificate issued in accordance with the SI expires May 31, 2025.​
Basically, all the SI does is authorize an AME to issue a new certificate after May 31, 2025 if certain conditions are met.
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This was a topic of discussion internally when FESSA passed back in 2016. The reading of the statute suggests somehow that a special issuance is separate from a medical certificate and could be issued for a specific condition.

That's of course not how special issuances work. You can't get a letter for an authorization for a special issuance (SI) without also getting a medical certificate issued along with it.

When I give presentations on BasicMed, I a stress that a medical condition that requires you to get a one-time special issuance puts you back in the medical certification process, and that in reality means getting a SI that includes anything and everything that is otherwise disqualifying under part 67.

So for example, if you suffer a heart attack and properly recover, you'll need to also get your CPAP compliance records in order for the OSA that was previously diagnosed.
 
Brad Z said:
This was a topic of discussion internally when FESSA passed back in 2016. The reading of the statute suggests somehow that a special issuance is separate from a medical certificate and could be issued for a specific condition.

That's of course not how special issuances work. You can't get a letter for an authorization for a special issuance (SI) without also getting a medical certificate issued along with it.

When I give presentations on BasicMed, I a stress that a medical condition that requires you to get a one-time special issuance puts you back in the medical certification process, and that in reality means getting a SI that includes anything and everything that is otherwise disqualifying under part 67.

So for example, if you suffer a heart attack and properly recover, you'll need to also get your CPAP compliance records in order for the OSA that was previously diagnosed.
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That needs to change to comply with the regulations and what I see as their intent in a BasicMed and post-MOSAIC world.
 
Kenny Phillips said:
As long as you've never had a denied/deferred FAA medical, of course.
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That's not a requirement. It's only that your LAST one wasn't DENIED (or withdrawn/revoked) and you currently don't have one of the three categories of disqualifying conditions.

You can certainly have deferrals or denials in you past as long as you subsequently got issued.
 
midlifeflyer said:
That needs to change to comply with the regulations and what I see as their intent in a BasicMed and post-MOSAIC world.
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But there's nothing to suggest in the statute that the FAA create a new type of specific issuance that condition specific for the purpose of BasicMed. This is the problem when Congress attempts to draft regulations through statute without first seeking technical assistance from the agency that is responsible for that regulation.
 
Brad Z said:
But there's nothing to suggest in the statute that the FAA create a new type of specific issuance that condition specific for the purpose of BasicMed. This is the problem when Congress attempts to draft regulations through statute without first seeking technical assistance from the agency that is responsible for that regulation.
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I don’t think it requires anything other that the regs as written. It’s “an Authorization for Special Issuance of a Medical Certificate” not the issuance of a special medical certificate. As my example indicates. It already works that way, unless you are suggesting that the SI requires one to file that next application. Any requirement to apply for a medical certificate rather that apply for ann “Authorization,” is entirely a choice of internal process, not regulatory mandate.
 
midlifeflyer said:
I don’t think it requires anything other that the regs as written. It’s “an Authorization for Special Issuance of a Medical Certificate” not the issuance of a special medical certificate.
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"Authorization," not "Special Issuance," is the operative noun, but what the airman must complete is "the process for obtaining an Authorization for Special Issuance of a Medical Certificate . . . ." That process starts with applying for a medical certificate.
 
midlifeflyer said:
I don’t think it requires anything other that the regs as written. It’s “an Authorization for Special Issuance of a Medical Certificate” not the issuance of a special medical certificate. As my example indicates. It already works that way, unless you are suggesting that the SI requires one to file that next application. Any requirement to apply for a medical certificate rather that apply for ann “Authorization,” is entirely a choice of internal process, not regulatory mandate.
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An “authorization for special issuance of a medical certificate” is described in 14 CFR 67.401. Such an authorization requires that the person must “show to the satisfaction of the Federal Air Surgeon that the duties authorized by the class of medical certificate applied for can be performed without endangering public safety during the period in which the Authorization would be in force.”
 
Brad Z said:
An “authorization for special issuance of a medical certificate” is described in 14 CFR 67.401. Such an authorization requires that the person must “show to the satisfaction of the Federal Air Surgeon that the duties authorized by the class of medical certificate applied for can be performed without endangering public safety during the period in which the Authorization would be in force.”
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I don’t see anything in that language which requires an FAA medical certificate be applied for. “Well, that’s the way we’ve been doing it when people had to apply for a medical certificate, so we won’t change it for situations where they don’t” is bureaucratic momentum, not a required interpretation of the language.

The whole concept of a one-time SI is an SI that authorizes BasicMed. I guess it’s not really a one-time SI after all, eh?
 
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midlifeflyer said:
I don’t see anything in that language which requires an FAA medical certificate be applied for. “Well, that’s the way we’ve been doing it when people had to apply for a medical certificate, so we won’t change it for situations where they don’t” is bureaucratic momentum, not a required interpretation of the language.

The whole concept of a one-time SI is an SI that authorizes BasicMed. I guess it’s not really a one-time SI after all, eh?
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It is. Once you obtain the special issuance you can go back to BasicMed.
 
midlifeflyer said:
I don’t see anything in that language which requires an FAA medical certificate be applied for.
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It's in 67.401: "If the person shows to the satisfaction of the Federal Air Surgeon that the duties authorized by the class of medical certificate applied for . . . ."
midlifeflyer said:
The whole concept of a one-time SI is an SI that authorizes BasicMed. I guess it’s not really a one-time SI after all, eh?
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It's not a "one time SI," at all. It's a one time "Authorization for Special Issuance of a Medical Certificate."
 
Brad Z said:
It is. Once you obtain the special issuance you can go back to BasicMed.
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Not according to the way you described it.
Brad Z said:
When I give presentations on BasicMed, I a stress that a medical condition that requires you to get a one-time special issuance puts you back in the medical certification process, and that in reality means getting a SI that includes anything and everything that is otherwise disqualifying under part 67.

So for example, if you suffer a heart attack and properly recover, you'll need to also get your CPAP compliance records in order for the OSA that was previously diagnosed.
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Pilot gets an SI for a resolved psychiatric condition in 2019. Moves to BasicMed when the certificate based on the SI expires in 2020.
Pilot has a heart attack in 2021. Recovers and applies for an SI in 2023.

Unless I misunderstood you, according to you, the pilot will "need to also get your [psychiatric] compliance records in order for the [psychiatric condition] that was previously diagnosed."

As far as I can tell, that's a second SI for the previous psychiatric condition. A "one-time" SI for that condition would mean no records would be required aside from the SI previously issued.
 
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Lindberg said:
It's in 67.401: "If the person shows to the satisfaction of the Federal Air Surgeon that the duties authorized by the class of medical certificate applied for . . . ."
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I disagree that language necessarily requires applying for a medical certificate as opposed to an authorization. Especially in a world where the FAA has a long history of interpreting language in a way that satisfies a policy goal.

And I can't hep but notice that now you say it's not a "one-time SI," but @Brad Z says it is, which makes my point about choices in interpretation.

This reminds me of the arguments I saw about the safety pilot anomaly, with many insisting the FAA was powerless to fix it because the congressional language precluded it.
 
midlifeflyer said:
Not according to the way you described it.


Pilot gets an SI for a resolved psychiatric condition in 2019. Moves to BasicMed when the certificate based on the SI expires in 2020.
Pilot has a heart attack in 2021. Recovers and applies for an SI in 2023.

Unless I misunderstood you, according to you, the pilot will "need to also get your [psychiatric] compliance records in order for the [psychiatric condition] that was previously diagnosed."

As far as I can tell, that's a second SI for the previous psychiatric condition. A "one-time" SI for that condition would mean no records would be required aside from the SI previously issued.
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Brad is correct about this. The congressional (2016) requriement is that the pilot win a third class ONCE for after the cardiac event. And they aren't going to let that through without a new psych clearinace.

However the semantics are that it's a single reauthorization for both conditions, not "two Special issuances". It's one letter with a long set of conditions for renewal. I am seeing a fellow from AZ tomorrow in just this situation....we got him through both parts.
 
But it's a second SI he had to get for the psychiatric thing. I wonder how this would litigate. All of the BM information says "one-time special issuance" for the specified conditions. It doesn't say "one time, unless you get something else on this list, in which case you have to be re-cleared for all of your medical past."
 
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