SI Medical Voluntary Surrender

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doneflying

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This is a long shot, but I'm hoping someone with FAA medical or SI experience can answer a niche question.

Assume an airman has an active Special Issuance medical, is fully compliant, and voluntarily surrenders the medical certificate for cancellation under FAA Order 8500.1D before it naturally expires.

The FAA Chief Counsel has said that after a medical certificate expires, SI reporting obligations end because there's no longer a certification purpose.

Has anyone seen what happens after an accepted voluntary cancellation?

Does the SI authorization effectively end with the canceled certificate, or is there an FAA authority saying the reporting obligations continue until the original expiration date?

I'm looking for actual experience or an FAA citation if anyone has one.

The reason I'm asking is that this affects whether the airman could later operate under BasicMed, so I'm trying to understand the status of the SI authorization after an accepted cancellation.

Please and thanks for any insight!
 
doneflying said:
This is a long shot, but I'm hoping someone with FAA medical or SI experience can answer a niche question.

Assume an airman has an active Special Issuance medical, is fully compliant, and voluntarily surrenders the medical certificate for cancellation under FAA Order 8500.1D before it naturally expires.

The FAA Chief Counsel has said that after a medical certificate expires, SI reporting obligations end because there's no longer a certification purpose.

Has anyone seen what happens after an accepted voluntary cancellation?

Does the SI authorization effectively end with the canceled certificate, or is there an FAA authority saying the reporting obligations continue until the original expiration date?

I'm looking for actual experience or an FAA citation if anyone has one.

The reason I'm asking is that this affects whether the airman could later operate under BasicMed, so I'm trying to understand the status of the SI authorization after an accepted cancellation.

Please and thanks for any insight!
Click to expand...
If a legit medical and SI exist (which I now have, after only six months) why not let the medical expire on its own?
I can see no reason to do otherwise, considering one can also get a BasicMed ticket at the same time.
 
Kenny Phillips said:
If a legit medical and SI exist (which I now have, after only six months) why not let the medical expire on its own?
I can see no reason to do otherwise, considering one can also get a BasicMed ticket at the same time.
Click to expand...
Unless there is some ongoing requirement BEFORE it expires, that's the simple way.
 
Thanks for the replies! I think my question may not have been clear, and I apologize.

I'm not asking whether it's better to let the medical expire naturally. I'm asking a procedural question about what happens if the FAA accepts a voluntary surrender for cancellation of an active SI medical certificate.

Specifically:

- Is the SI authorization left in place unless the FAA separately withdraws it under § 67.401(f)?
- Or does acceptance of the certificate cancellation also terminate the practical effect of the authorization?

I'm not looking for opinions on which approach is preferable. I'm trying to determine whether anyone has actually seen the FAA process an accepted voluntary cancellation of an active SI medical, or knows of an FAA Order, Chief Counsel interpretation, or other authority that addresses the relationship between the certificate cancellation and the underlying SI authorization.

Yes, I realize this is a rather niche question. To clarify the fact pattern, assume the airman is currently in full compliance with the SI authorization, has not been found medically unqualified by the FAA, and is not the subject of any enforcement investigation or enforcement action. I'm specifically interested in what happens after an accepted voluntary cancellation under those circumstances.
 
Kenny Phillips said:
why not let the medical expire on its own?
I can see no reason to do otherwise, considering one can also get a BasicMed ticket at the same time.
Click to expand...

Reading between the lines, I would guess that the OP is worried about the FAA withdrawing the authorization after the certificate expires. The authorization can remain valid long after the certificate; if the FAA withdraws it, the pilot is no longer able to use BasicMed.

Tim
 
timrb said:
Reading between the lines, I would guess that the OP is worried about the FAA withdrawing the authorization after the certificate expires.
Click to expand...
That would happen if there's ongoing compliance requirements that aren't met. But it wouldn't affect the medical certificate, because there wouldn't be one.
timrb said:
The authorization can remain valid long after the certificate; if the FAA withdraws it, the pilot is no longer able to use BasicMed.
Click to expand...
Why not?
 
timrb said:
This FAA memo, posted in another thread by Midlifeflyer, explains:


Tim
Click to expand...
Can you point me to the part you're referring to? Because I read it as saying there's no basis to withdraw the SI once the underlying medical is expired.

"Because alternate avenues are provided to collect information, it does not appear that Congress, who mandated BasicMed, wanted an airman to be beholden to continued requests for information related to a prior Authorization after the most recent special issuance medical certificate has expired and the airman is not in the process of seeking a renewed special issuance medical certification."
 
Lindberg said:
I read it as saying there's no basis to withdraw the SI once the underlying medical is expired.
Click to expand...

Among other things, the memo refers to 14 CFR 67.401. If you look at it, in particular subpart (f), you'll see that there are several reasons an authorization may be withdrawn, and failure to provide information is only one of them.

Tim
 
Kenny Phillips said:
If a legit medical and SI exist (which I now have, after only six months) why not let the medical expire on its own?
I can see no reason to do otherwise,
Click to expand...

Could be many reasons.

Some SIs require onerous or expensive testing to maintain, and that testing may be considered not medically necessary and not covered by insurance. Also, an SI holder may wish to travel abroad and have no way to get the tests while overseas. Or, an SI holder might wish to stop doing random pee tests so he can drink again without waiting four years for a medical certificate to expire.
 
See post #19 and 20 from this thread. Jon lays it all out well. Ignore the thread title. I asked a tangential question which is I believe is what you are asking.

S

Thread 'Basic med while awaiting class 3 SI renewal.'

Hi all, long time lurker, first time poster. I started flying in November of ‘23 and passed my checkride a couple months ago. I had to navigate the class 3 special issuance process for some past episodes of uveitis. It was pretty simple but painstakingly slow. The SI renewal process has generated a question I haven’t been able to satisfactorily answer based on my searching.

As part of my renewal I had to submit documentation from my eye doctor. There have been no changes in my vision or any other developments. However, despite my submission 7 weeks in advance of my 12/31/24 certificate...
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doneflying said:
Thanks for the replies! I think my question may not have been clear, and I apologize.

I'm not asking whether it's better to let the medical expire naturally. I'm asking a procedural question about what happens if the FAA accepts a voluntary surrender for cancellation of an active SI medical certificate.

Specifically:

- Is the SI authorization left in place unless the FAA separately withdraws it under § 67.401(f)?
- Or does acceptance of the certificate cancellation also terminate the practical effect of the authorization?

I'm not looking for opinions on which approach is preferable. I'm trying to determine whether anyone has actually seen the FAA process an accepted voluntary cancellation of an active SI medical, or knows of an FAA Order, Chief Counsel interpretation, or other authority that addresses the relationship between the certificate cancellation and the underlying SI authorization.

Yes, I realize this is a rather niche question. To clarify the fact pattern, assume the airman is currently in full compliance with the SI authorization, has not been found medically unqualified by the FAA, and is not the subject of any enforcement investigation or enforcement action. I'm specifically interested in what happens after an accepted voluntary cancellation under those circumstances
Click to expand...
The Domingo 2018 Legal Interp sets the guardrails for when Aerospace medicine (AAM) can withdraw a letter of authorization for a special issuance. Basically, after the medical certificate expires, you can’t withdraw it.

Thst said, if you ask to surrender your medical, they could could very well oblige, but they could also withdraw the SI at the same time, since the underlying medical has not expired. I can’t say whether that’s policy or not, as I’ve never seen someone voluntarily surrender their medical certificate to go BasicMed, but I think it’s possible. My guidance has always been to let the medical expire in 6 months or a year…what ever the case may be…
 
timrb said:
Reading between the lines, I would guess that the OP is worried about the FAA withdrawing the authorization after the certificate expires. The authorization can remain valid long after the certificate; if the FAA withdraws it, the pilot is no longer able to use BasicMed.

Tim
Click to expand...
The SI authorization is not a medical certificate.
 
Correct. But I have had one properly withdrawn as the auth was valid and the cert was not (timed out), because he had a positive test and the HIMS AME obligation to report ANY positive test.....had he not been testing this could not have occurred.

Happily, after a lotta spade work, the FAA's toxicology consultant agreed and reinstated the auth. The system DOES work.
 
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