In August of 2020, the FAA introduced the HIMS step down protocol for airman who hold a medical certificate pursuant to a special issuance authorization for “substance dependence.” In theory, the step down protocol works two ways for airmen on a “substance dependence” special issuance. In some regards, the new protocol works to eliminate the frequency of a costly, HIMS psychiatric evaluation, time-consuming aftercare requirements, and other monitoring requirements, faster than would otherwise be required.

However, on the other hand, the step down protocol extends the duration of a special issuance for the airman’s entire life as a medical certificate holder. While the monitoring that is required may not be too extensive following year 7 of the airman life, the step down protocol does, at least, still provide some level of FAA oversight.

What airmen should be aware of is that the time course of the HIMS step down protocol may be modified on a case-by-case basis. To that end, the specified reduction of requirements is discretionary by the HIMS AME. In essence, if an airman is not providing the HIMS AME with sufficient evidence of recovery within any given phase of the protocol, the HIMS AME may represent insufficient compliance to the Federal Air Surgeon’s office. So, while it may seem like the reduction of requirements throughout the protocol are hard-and-fast, they are not.

If you are an airman on a “substance dependence” special issuance, the HIMS step down protocol may be to your benefit. Be careful, however, because providing evidence of satisfactory recovery to your HIMS AME is paramount to avoiding going back to the beginning of the protocol or worse, having your special issuance withdrawn. If you have questions regarding the HIMS step down protocol, call your FAA medical attorney at The Ison Law Firm.

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