Applying for a FAA medical certificate with migraines or a history of headaches can require a bit of preparation. If you have a history of migraines or other frequent or severe headaches, the FAA requires that you report that history on question 18a. on the 8500-8, application for airman medical certification. There are many different types of migraines and headaches and as a result, the FAA requires different information depending on what kind of migraine or headache you experience. Almost all types of migraines, however, can eventually lead to FAA medical certification, assuming you don’t pose a risk to aviation safety, and you are not using any disqualifying medications to treat your headaches.
The FAA breaks migraines and headaches into the following categories:
- Stress headaches/tension headaches and headaches controlled with over the counter medications: With a history of this type of headache, the FAA will allow your Aviation Medical Examiner to issue to you a medical certificate, so long as you present with 1) an average of less than two headache days per month; 2) you are using medications which are acceptable; 3) your headaches are not incapacitating; and, 4) your headaches are not associated with any neurological findings. A detailed clinical progress note from your treating physician is not required for this category of headache.
- Classic migraines, Chronic tension headaches, Chronic daily headaches, Cluster headaches, or any history of a migraine which results in changes to vision: With a history of classic migraines or more chronic headaches, the FAA will require that you be followed under the CACI program (which stands for “Conditions AMEs Can Issue). The CACI program for migraines will allow your AME to issue to you a FAA medical certificate, assuming you provide a current, detailed clinical progress note from your treating physician and you meet all of the CACI requirements. The CACI program will require your AME to assess the treating physician’s detailed clinical progress note and evaluate the frequency of your headaches, the symptoms associated with your headaches, as well as the types of medications utilized for preventing and aborting headaches and migraines.
- Complicated migraines, Post-traumatic migraines, or Retinal migraines: If you have a history of migraines which are more involved, the FAA will require that you be considered and potentially monitored via a special issuance authorization. A special issuance authorization is necessary when the FAA believes that you are not eligible for airman medical certification, but that risk to aviation safety can be mitigated through a monitoring protocol developed at the Federal Air Surgeon’s discretion. With respect to migraines, prior to being issued a special issuance authorization, the FAA will typically want to know why you are having more severe headaches and understand your level of risk for future incapacitation. In doing so, the FAA will require that you provide 1) a detailed clinical progress note from a board-certified neurologist; 2) a MRI of the brain performed no more than one year before your examination with an AME; 3) a statement identifying the number of headache days you experience throughout a month; and 4) anything else determined to be necessary by your treating physician.
Of course, one of the most disqualifying features of migraines and headaches that we see in our practice is the medication issued for preventative and abortive measures. Medications such as Tompamax are disqualifying for airman medical certification. Furthermore, other medications such as Triptans, Reglan, and Phenergan require various periods of no-flying.
If you are applying for a FAA medical certificate with migraines, keep the following information in mind before you visit your Aviation Medical Examiner for examination:
- Ensure that you obtain a detailed clinical progress note from your treating physician or specialist prior to your examination with an AME. If you fail to produce a detailed clinical progress note within the period of time your AME has to submit your examination to the FAA, you may be at risk for having your application deferred to the FAA.
- In order to be CACI qualified, the FAA will expect that an applicant experiences symptoms which are only mild. Furthermore, the FAA will require that within the last year you have had no in-patient hospitalizations, no more than 2 outpatient clinic/urgent care visits for exacerbations. You will not be eligible for the CACI program if you’ve had neurological or TIA-type symptoms; vertigo; syncope; and/or mental status change.
- The FAA expects that in order to be CACI qualified, the applicant should not have to use any preventative medications other than daily calcium channel blockers or beta blockers only for prophylaxis without side effects. The FAA only allows over the counter medications for abortive purposes (also Triptans, Reglan, and Phenergan). Injectables and narcotics are not acceptable for the CACI program.
- If you require a special issuance authorization, consider being evaluated by a neurologist which is familiar with FAA medical certification standards. Oftentimes, presenting evidence from someone the FAA believes to be more credible regarding risk to aviation safety may help your case.
- Start your FAA medical certification process as soon as possible. Most applications which are deferred must be reviewed by the FAA’s neurological division, which can be a slow process. Having your documentation and supporting evidence prepared and submitted before the FAA asks for same can save you months of processing time in some cases.
If you are facing a FAA medical with migraines, consider a consultation with a FAA medical defense attorney at The Ison Law Firm before applying for a FAA medical certificate. 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.
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