It is possible to obtain a FAA medical certificate with pre-diabetes. The good news is that if you have appropriate documentation in place prior to submitting your FAA medical application, your Aviation Medical Examiner (“AME”) does not have to defer your medical application to the FAA for further review. Instead, pre-diabetes is a condition that falls under the FAA’s “CACI” program. “CACI” stands for Conditions AMEs Can Issue. With CACI conditions, your AME can issue a regular medical certificate for that condition on your first exam or the first time you are reporting that condition. Other diagnoses considered acceptable under the pre-diabetes CACI include metabolic syndrome, impaired fasting glucose, insulin resistance, glucose elevation/intolerance, and polycystic ovary syndrome.
What qualifies for the pre-diabetes CACI? In order to get your FAA medical certificate with pre-diabetes, the FAA requires that you provide to your AME a detailed clinical progress note from your treating physician, authored within 90-days of your exam with your AME. This progress note should be detailed and include the following information:
- A notation from your physician identifying that the condition is stable on your current regimen and no changes recommended;
- A notation that you have no symptoms associated with diabetes;
- A notation that you have had no hypoglycemic events (symptoms or glucose less than or equal to 70 mg/dl) within the past 12 months;
- A notation that your fasting blood sugar is less than 126 mg/dl;
- A notation that your A1C from within 90 days is less than or equal to 6.5 mg/dL;
- A notation that, if performed, your oral glucose tolerance test is less than 200 mg/dl at 2 hours; and,
- A notation that you are not taking diabetes, with the only exception being Metformin.
If your AME reviews a detailed clinical progress note from your treating physician, which falls within these parameters, your AME may issue you a medical certificate, if you are otherwise qualified. If your AME believes that these parameters are not achieved, your AME must defer your application to the FAA for further review. One consideration should always be to remain cautious about your treating physician’s note containing insufficient information or containing information which may warrant unnecessary scrutiny. A deficient record from your treating physician could prevent you from getting your FAA medical certificate with pre-diabetes.
Why involve a FAA attorney with your FAA medical certificate with pre-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 pre-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 pre-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 pre-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 obtaining your FAA medical certificate with pre-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.