Can you get a FAA medical certificate with diabetes? It is possible to get a FAA medical certificate with diabetes if you can meet the FAA’s nuanced requirements for demonstrating stability and control. If you have diabetes, the FAA will require that you establish your eligibility to be issued a FAA medical certificate first, but then require that you continue to show stability with the condition while being monitored on a special issuance authorization or AME Assisted Special Issuance. What will you have to show the FAA to be issued a FAA medical certificate with diabetes? The FAA’s initial consideration will always be as to what type of diabetes you have. In this regard, the FAA most commonly triages applicants with diabetes into three categories: 1) diabetes mellitus, type 1; 2) diabetes mellitus, type 2, controlled with insulin; and 3) diabetes mellitus, type 2, controlled with medication (not insulin). After determining which category you may fall into, the FAA will consider the class FAA medical certificate for which you are applying (i.e. first-class, second-class, or third-class). Based on these triaged categories, the FAA will then ascertain what information will be needed in order to issue you a FAA medical certificate with diabetes.
Diabetes Mellitus, Type 1 and Diabetes Mellitus, Type 2, Controlled with Insulin
If you wish to get a FAA medical certificate with diabetes and you either have diabetes mellitus, type 1 or diabetes mellitus, type 2, which is controlled with insulin, the FAA will treat your case virtually the same. The FAA will require the same information in these cases for first-class and second-class applicants. Applicants applying for a third-class medical certificate are not required to provide Continuous Glucose Monitoring (CGM), as are first- and second-class applicants. Nevertheless, applicants who seek a FAA medical certificate with diabetes, who fall into this must demonstrate to the FAA that the condition is stable and adequately controlled. This stability and control must be verified through a minimum of 6 months of CGM data (for first- and second-class applicants).
As an applicant applying for a FAA medical with diabetes mellitus, type 1 or diabetes mellitus, type 2, which is controlled with insulin for the first time, you should be prepared to be deferred by your Aviation Medical Examiner when you submit your exam. All first-time applicants with diabetes will be deferred by his or her Aviation Medical Examiner. A deferral will cause the FAA’s Office of Aerospace Medicine to request various documentation from you to establish your stability and control of your diabetes. If this information is prepared in advance of your application, you will save time in the FAA’s review of whether you can be issued a FAA medical certificate with diabetes.
Typically, the documentation the FAA will require from first- and second-class applicants who present with diabetes mellitus, type 1 or diabetes mellitus, type 2, which is controlled with insulin, is as follows:
- Initial Comprehensive clinical consultation from your treating board-certified endocrinologist;
- Initial/Annual comprehensive panel;
- Monthly CGM data with a device that meets FAA requirements for the preceding 12 months (when available) in overlay view;
- Eye evaluation from a board-certified ophthalmologist (M.D. or D.O.); and,
- Cardiac Risk Evaluation from a board-certified cardiologist. It should be noted that applicants age 40 and over will require a maximal exercise stress test, as well.
It has been noted in our practice that most applicants with diabetes mellitus, type 1 or diabetes mellitus, type 2, which is controlled with insulin, are already undertaking the necessary precautions and treatment to ensure stability and control, just as a matter of course. Nevertheless, the nuances of what the FAA requires to establish stability and control to regulatory standards is what can cause a FAA medical denial. In our practice, we often see airmen who do not have the appropriate period of “time in range” on their CGM. To that end, the FAA requires that the time in range of glucose between 80-180 mg/dl should be 70% or greater.
For third-class applicants electing not to use a Continuous Glucose Monitor, the FAA will accept data from the two most recent measurements of glycosylated hemoglobin. In theory, if you are a third-class applicant and your doctor does not require that you use a CGM, it is not typically recommended by our firm that you start using a CGM just to satisfy the FAA.
Diabetes Mellitus, Type 2, Controlled with Medication (Not Insulin)
In the alternative, if you wish to get a FAA medical certificate with diabetes and you have diabetes mellitus, type 2, medication controlled (not insulin), the FAA will require the same information, whether you are applying for a first-class, second-class, or third-class certificate. In our practice, applications falling within this category of diabetes is the most common and is a frequent issue on review for the FAA. For first time applicants, the FAA will require that the applicant provide information to support stability and control; however, all subsequent issuances to the airman will be subject to an AME Assisted Special Issuance. This is a process that provides Aviation Medical Examiners the ability to re-issue an airman medical certificate without as much FAA scrutiny.
Typically, the documentation the FAA will require applicants with diabetes mellitus, type 2, controlled with medication (not insulin) to provide will be one of the following, either:
- The FAA’s form to be executed by your treating physician called The Diabetes or Hyperglycemia on Oral Medications Status Report; or,
- A current, detailed Clinical Progress Note generated from a clinic visit with the treating physician or endocrinologist no more than 90 days prior to the AME exam.
Note that the FAA will always require a current Hemoglobin A1C lab test performed no more than 90 days prior to the AME exam (and 30 days after medication change).
It is critical that applicants and their treating physicians understand that the FAA has provided a list of medications which are approved for control of diabetes mellitus. What is often missed is that the FAA does not accept certain combinations of these acceptable medications. Therefore, it is important that you and your doctor consider which medications you are taking and confirm that if you are taking more than one medication, that you are on an acceptable combination of these medications.
Pre-Diabetes and Diabetes Mellitus, Type 2, Controlled with Diet
Pre-diabetes and diabetes mellitus, type 2, controlled with diet, are discussed in a separate article. It should be noted that these categories exist, but that stability and control can be established with a lessor level of scrutiny.
Why involve a FAA attorney with your FAA medical certificate with diabetes? Despite what you may hear from your AME, 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 diabetes, 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 diabetes. 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 diabetes on your FAA medical application, a FAA medical attorney can give you counsel on how to rectify your omission.
If you are concerned about your FAA medical and diabetes, 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.