You can be issued a FAA medical certificate with colitis if you meet the FAA’s “CACI” requirements. “CACI” stands for Conditions AMEs Can Issue. Essentially, with certain “CACI” conditions, such as colitis, the FAA will allow your Aviation Medical Examiner (“AME”) to issue you a medical certificate if documentation from your treating physician establishes that you meet acceptable certification criteria. The acceptable “CACI” criteria for colitis requires that you provide your Aviation Medical Examiner (“AME”) a detailed clinical progress note from your treating physician, authored within 90 days of your FAA medical examination. If the detailed clinical progress note identifies certain, positive criteria, your AME is authorized to issue you a FAA medical certificate with colitis.
The “CACI” criteria required to be addressed by your treating physician and identified in the detailed clinical progress note includes the following:
- Notation that your general health status is favorable, despite your colitis;
- Notation that you have no or mild diarrhea with or without mild abdominal pain/cramping;
- Notation that the cause of colitis is Crohn’s Disease, Ulcerative colitis, or Irritable Bowel Syndrome;
- Notation that you have not had any surgery for your colitis within the past 6 weeks; and,
- Notation that your use of medication for colitis does is nothing more than a combination of the following:
- Oral steroid (including budesonide) which does not exceed equivalent of prednisone 20 mg/day (see steroid conversion calculator)
- Imuran or Sulfasalazine
- Mesalamine (5-aminosalicylic acid such as Asacol, Pentasa, Lialda, etc.)
- Steroid foams or enemas/ budesonide enema
- Loperamide less than or equal to 16 mg a day and no side effects
- Hyoscyamine – use 1-2 times a week with no side effects and no-fly 48 hours after use
- Mercaptopurine (6-MP) • Tofacitinib (Xeljanz)
- Vedolizumab (Entyvio): 4-hour no-fly after each dose
- Humira (adalimumab)
It should be noted that you will not be able to achieve a FAA medical certificate for colitis under the “CACI” program if you experience fatigue which limits your activity or if you experience severe abdominal symptoms. Also, if your colitis is not caused by one of the above-referenced underlying conditions, the FAA will not find your condition to be “CACI” qualified. Your AME will also defer your application for further consideration by the FAA if you use infliximab, hyoscyamine greater than 2 times per week, Prednisone equivalent greater than 20 mg/day, or Loperamide greater than 16 mg per day. If you do not meet the “CACI” criteria for colitis, that doesn’t mean that you can’t be considered for a special issuance authorization and medical certificate.
Why involve a FAA attorney when you are attempting to obtain your FAA medical certificate with colitis? Despite what you may hear from other pilots, the medical certification process is more so a legal process than a medical process. Ensuring that your doctor is developing the proper documentation regarding your colitis, as needed, can be a difficult task. To that end, everything that is submitted to the FAA (i.e. records, statements, evaluations, etc.) goes into your airman medical file. This file is what the FAA then utilizes to evaluate whether you are eligible to hold a medical certificate, despite your colitis. If you are later denied and wish to appeal that denial, your airman medical file becomes “Exhibit A” before the NTSB or upon reconsideration by the Federal Air Surgeon. So, a FAA attorney can evaluate your records, prepare a plan for best presentation of your case to the AME or FAA, and best argue your medical eligibility to the Federal Air Surgeon, with an eye for potential, future appeal. Furthermore, if your medical documentation is as strong as possible upon initial submission, in doing so, hopefully, you will avoid unnecessary delay. Also, if you have failed to report your colitis on your FAA medical application, a FAA medical attorney can give you counsel on how to rectify your omission.
If you are concerned about obtaining your FAA medical with colitis, call the FAA attorneys at The Ison Law Firm. We are happy to evaluate your case and discuss with you a plan for presenting your case to your AME or the FAA. Aviation law is all we do. Nothing else.