This past weekend I logged 1.4 hours of Pilot In Command time. This isn’t new — I’ve got over 300 hours under my belt — but for the last six months, there’s been some significant doubt about whether I would ever be able to fly again thanks to a 20 year old ADHD diagnosis that was holding up my medical. I didn’t have a clear guide to what would happen or how to navigate this process, so I wanted to write up my experience to help others who might be going through a similar ordeal.
Why ADHD Is An Issue
Pilots need to be attentive and alert, constantly scanning instrument panels and looking out the window for traffic. All of these are repetitive tasks that someone with ADHD might not be able to adequately perform, especially when piloting a commercial aircraft. From the FAA’s website, this is their statement on that situation:
Attention-Deficit/Hyperactivity Disorder (ADHD), formerly called Attention Deficit Disorder (ADD), and medications used for treatment may result in cognitive deficits that would make an airman unsafe to perform pilot duties.
The key difference between this and other disorders is that with ADHD, there are no medications approved by the FAA for use as a treatment. From the AOPA:
Some of the medications that individuals take for ADHD are Adderall, Concerta, Ritalin, Strattera, Vyvanse, and Dexedrine. Take note: These medications are either amphetamine-based or methylphenidate-based stimulants. The FAA does not accept the use of any of these medications.
So for those with this disorder, there doesn’t seem to be a path to the left seat. The disorder itself is disqualifying, and the medication used to treat it isn’t permissible. The only way out is to prove that you don’t actually have ADHD.
My History
Like many 90’s kids, I was consuming too much sugar / caffeine (on top of just being a normal, energetic kid) and my parents thought that I had Attention Deficit Disorder — as it was known at the time. They brought me to a specialist while I was in elementary school, who diagnosed me and prescribed a low dose of Ritalin which I continued to take on a daily basis until sometime in middle school.
That was nearly 20 years ago. Maintaining a healthier lifestyle, I have since then completed high school, college, and have a decently successful career in tech. I have never felt the need to go back on that medication and promptly forgot about it.
A Quick Trip to the Doctor
I was issued a first class medical certificate in 2014 without any issues. ADHD isn’t something that’s asked on the 8500-8 form (application for a medical certificate) — it only asks about medication currently being used, and in the history section it broadly asks about neurological issues. It didn’t even occur to me to include my childhood diagnosis, and the doctor didn’t ask many questions, and certainly not any pointed ones. He rubber stamped my application after a quick pee in a cup.
When I went back in April of this year to renew my first class medical, this time the doctor asked the right question. “Have you ever been on any long term medication?” It triggered a memory of being on Ritalin for ADD and I told him about it.
What I appreciate is that my AME was calm, cool, and collected. He let me know about next steps and gave me a vague idea of what’s about to happen. He told me he couldn’t issue a medical certificate that day and instead needed to send a letter to the FAA to follow up. In the meantime, I could still fly under my current medical certificate since this wasn’t an outright denial — but he could not directly issue me my medical certificate. That would have to come from the FAA directly at this point.
Step 1: Medical Records
The one thing that the AME told me to do immediately, which was super helpful, was to start tracking down my old medical records. He said that would be the first thing the FAA would ask for and it might take some time to collect.
The logic is pretty straightforward. They’re looking to verify that the ADHD diagnosis was made and that medication was issued. Maybe I mis-remembered something and it was a different disorder, but the medical records would be clear.
In my case, this was easier said than done. According to HIPAA requirements medical records only need to be maintained for about five years following the end of treatment, and most shops would rather purge those records than have them sitting around waiting for a data breach or theft. I was, understandably, concerned since my treatment was nearly 20 years ago, but thankfully my pediatrician at the time had kept the records and was able to send me a copy.
The records they had were treatment reports from a specialist to whom they had referred me, only containing a brief narrative of what was going on and prescriptions that were issued. This was enough to confirm the diagnosis, but not enough to confirm that I no longer needed the medication.
I tried to get a copy of the full medical records from that specialist, but in the intervening 20 years (A) they had retired, (B) their office had dissolved, and (C) the facility they were treating me at had closed. So that wasn’t happening.
I gathered all of this information proactively, knowing thanks to the AME’s advice. Six weeks after he submitted his letter to the FAA, a note finally arrived in my mailbox asking for, and I quote:
- A personal statement detailing your ADHD history and medication use.
- Al treatment records and evaluation from the physician(s)who prescribed the ADHD medications in the past.
I get the feeling that if I were able to produce some documentation from the treating physicians to the effect that I no longer suffered from ADHD, the rest of this may have gone much quicker. But unfortunately I didn’t have anything even close. I just had a note that at some point we discontinued the medication, not that I no longer had ADHD.
Step 2a: Neuropsychological Exam Prep
The FAA sent their request for my medical records on May 8th. They processed my request on June 10th. On July 11th, they sent the next request, which was exactly what I had hoped to avoid:
In order to issue my medical certificate, they requested that I be evaluated by a forensic neuropsychologist to determine if I still had ADHD. The request came in a single sentence from the FAA, but there were a lot of sub-requirements that really only became clear when you read further into the documentation.
Oh, and they gave me 60 days to complete all of the necessary steps and submit the results in a single mailing.
Before even attempting the exam, you need to gather all the necessary documentation so the neuropsychologist can make a thorough assessment of your situation. The FAA published a PDF talking airmen through what documentation is needed prior to the exam, and it includes:
- All medical records pertaining to the ADHD diagnosis
- Academic records, including transcripts, from school if diagnosed as a child including IEPs and academic awards from time both on and off the medication
- A copy of your driving record from every state in which you lived for the last 10 years
- All previous psychological reports (if any)
- Any reports from psychological hospitalizations
- A complete copy of your FAA medical records
As it turns out the items I thought were easiest actually took the longest to get back.
The treatment records were already provided in the first submission so I made another copy and held onto them.
I started with the FAA medical records, as the PDF from the FAA includes a handy reference to where to find that. I filled in the form and sent it back, arriving and being acknowledged by the FAA on July 31st.
Those records would eventually arrive… on September 30th. For those keeping count at home, that’s well more than 60 days. In fact, that’s 81 days from start to finish just to get those records. So, just to recap: the FAA gives you 60 days to fulfill their request, but the only documentation aspect that they are directly responsible for providing you (to then provide back to them)… takes 80+ days for them to fulfill. And the neuropsychologist was unable to finish their report before they had those records, so that’s another two weeks before I could even submit anything back to the FAA.
All in all I had to ask for three extensions to ensure they didn’t send the enforcement arm of the FAA on my tail.
Academic records was next on the list and was about as problematic as the medical records. This was something that I went through between elementary school and middle school, and while I absolutely got report cards in the mail there’s no way my parents saved them longer than a few days. Those were lost to the ages. I was able to pull a copy of my transcript from Penn State though, which I hoped would give me partial credit.
The only thing left that I could actually provide was my driving record from each state for the last 10 years. Which was a bit tough — I’ve lived in four states in that time period. There is no centralized driving record database, so I needed to individually go to each state, submit a request for my records, pay a fee, and wait for the results to come in the mail. Surprisingly this was fairly quick considering the bad reputation for the DMV. Certainly, better than the FAA — but that’s a pretty low bar.
Records in hand, I trundled off to the forensic neuropsychologist for my assessment.
Step 2b: Forensic Neuropsychologist Exam
What I found interesting about my trip to the neuropsychologist was that apparently I was a bit of a rare treat. Their job is to act in an official capacity to perform an assessment and render an opinion on my mental capacity, which is normally something that happens for people who want to do things like claim an “insanity defense” for their murder trial. Not really a pleasant conversation to have. Which apparently made spending a day chatting with me a welcome departure from their normal clientele.
The very first thing I did when I got there was pee in a cup. The test was to screen out any ADHD medication I might be taking, which would show up in my urine up to a month after I stopped taking it.
Urine test completed, I spent a little time chatting with the psychologist, giving my family history and talking about why I was now sitting in his office. It was very informal and only took a few minutes.
The remainder of the day was for the testing. To be as impartial as possible, the FAA seems to favor objective tests with measurable results over subjective assessments, and every single test over the next few hours was designed to be as boring as possible.
Here’s each test that was performed and what it entailed.
CogScreen-AE
Administered on a computer, this series of tests is about the cognitive abilities of the test taker and specifically for those in the aviation environment. Tests include:
- Backward Digit Span (BDS): Recall of a sequence of visually presented digits in reverse order.
- Math: Traditional math word problems with multiple choice answer format.
- Visual Sequence Comparison (VSC): Comparison of two simultaneously presented series of letters and numbers.
- Symbol Digit Coding (SDC): Substitution of digits for symbols using a key, followed by immediate and delayed recall of symbol-digit pairs.
- Matching to Sample (MTS): Immediate recognition for a checkerboard pattern.
- Manikin (MAN): Mental rotation task requiring respondent to identify the hand in which a rotated human figure is holding a flag.
- Divided Attention (DAT): Task employs a visual monitoring task, which is presented alone and in combination with the Visual Sequence Comparison task.
- Auditory Sequence Comparison (ASC): Comparison of two series of tone patterns.
- Pathfinder (PF): Visual sequencing and scanning task that requires respondents to sequence numbers, letters, and an alternating set of numbers and letters.
- Shifting Attention (SAT): Rule-acquisition and rule-application test requiring mental flexibility and conceptual reasoning.
- Dual Task (DTT): Consists of two tasks, each of which is performed alone and then together as a simultaneous test. One task is a visual-motor tracking test. The second task is a continuous memory task involving serial digit recall.
This was probably the test I was most concerned about, but in reality wasn’t that bad. The hardest sub-task was the Dual Task, which was simultaneously trying to keep an artificial horizon level and recalling some numbers.
COWAT
This is a verbal fluency test. The proctor will give you a prompt of a letter and ask you to name a category of items which start with that letter. For example, food starting with “P” might include pizza, pineapple, poppy seed bagels, etc. You then are asked to name as many as you can think of in a set time period.
CPT / TOVA
The Continuous Performance Test is about whether you can correctly press a button when a “stimulus” is shown on a computer screen and ignore it in other situations. In my version, the computer would display a series of letters and I needed to press the button when the displayed letter was an X. It would appear randomly, at varying speed, and often multiple times in a row. This would continue for some time.
MMPI-2
The Minnesota Multiphasic Personality Inventory is a series of a few hundred statements for the test taker to mark as “true” or “false” on the paper. Things that stood out in my mind are statements like “I enjoy hunting” and “my father was a good man”. These are then cross referenced to produce a personality report.
PASAT
This test is designed to assess how well you can process auditory inputs. A proctor puts on a pre-recorded tape where a person reads off a string of numbers. The goal is to add each subsequent number to the previous one and respond with the sum. Here’s an example of how that would work:
Recorded Person: 2
RP: 4
Subject Response: 6
RP: 3
SR: 7
As you might have figured out, the hard part is remembering the previous number and adding it to the one the recorded person just said before they say the next number. You want to remember the number that just came out of your mouth but you need to immediately forget it instead.
As the test goes on the numbers come faster and faster, and this process goes on for a good 30ish minutes.
Trail Marking Test
The test taker is presented with a sheet of paper with letters or numbers arranged on a page. They are asked to start from one of those numbers and draw a continuous line through the correct series of letters or numbers. They might be all numbers, they might have alternating patters, any number of challenges. The test taker is asked to perform this task as quickly as possible. The challenge is finding the next item in the series.
WRAT
The Wide Range Achievement Test asks the test taker to read and understand word problems within a specific time frame, perform the calculation and respond with the correct answer.
Conners Adult ADHD Rating Scale
Probably the most straightforward of the questionnaires, this one asks some very obvious questions about whether you have the symptoms of ADHD.
Once all of the tests were completed they packaged up the results and sent them directly to the FAA. I never got a copy.
Potential Step 3: Demonstrated Proficiency
I never got this far. As you’ll see in a second things worked out for me, but if they hadn’t I would have needed to prove to the FAA that I was capable of performing the tasks of a pilot. Basically I would have needed to go take a flight with a medical examiner in the back seat and a flight instructor at the controls and prove that I could perform all of the tasks. This would have killed any chance I had for a 1st class medical, but at least I would be able to fly.
Step 4: Receive Medical Certificate
On November 15th, about 7 months after my AME first flagged my case, I finally got my new medical certificate in the mail. Attached was a caution from the FAA to be aware of my past history with ADHD and be cautious if any of those symptoms started appearing, but in the envelope was an unrestricted 1st class medical.
What I want to point out most of all is that while this process was long and tedious and cost a significant chunk of cash (probably around $5,000 all told) the people at the FAA were surprisingly polite and helpful. The handful of times I called in to talk about a question I had or check on the status of some paperwork they were super nice and helpful, even going out of their way to help me get an extension on the deadlines.
Moving forward, every time I go for a medical certificate I now need to notify them that I have a previous ADHD diagnosis. But I can say that the FAA has already gone through their process and it’s a known non-issue, providing the reference number from the documentation they provided as proof.