Starting in December of 2025, UDS Aviation has launched a structured review of the FAA aeromedical certification system as part of a broader public-interest research effort focused on transparency, consistency, and administrative performance.
The purpose of the project is to examine whether the current aeromedical certification system can demonstrate the level of transparency, consistency, timeliness, and evidence-based decision making expected of a modern aviation regulator. A mission focused aeromedical certification system is crucial to safety and the future of aviation, this project transcends individual medical cases and conditions, focusing on a review of the current system’s performance without assumptions or influence.
The current FAA aeromedical system exists to protect safety in the National Airspace System by identifying medical conditions that could create unacceptable risk in flight. UDS Aviation’s position is simple: if that is the system’s mission, then it should be possible to evaluate whether the system is functioning effectively, whether its standards are consistently applied, and whether it is tied to measurable safety outcomes.
As part of this effort, UDS Aviation has submitted five Freedom of Information Act requests seeking aggregated, non-personally identifiable data and internal policy documents related to aeromedical certification. The core purpose of these requests focuses on key testable aspects of the current system outlined below.
These FOIA requests were filed in December of 2025, as of the publication of this article no response has been received from the FAA.
Areas of Review
1. Aviation Medical Examiner Oversight
The first request examines how FAA-designated Aviation Medical Examiners (AMEs) are supervised and evaluated.
This request seeks records related to:
- Complaint volumes involving AMEs
- Investigation outcomes
- Retraining, suspension, or corrective actions
- Internal scorecards, audit criteria, or evaluation standards
- Policies governing when examiner errors trigger review
2. Additional Medical Information Requests
The second request examines how often applicants are required to submit repeated rounds of additional testing, records, physician statements, or clarifying documentation before a final decision is made.
This request seeks records related to:
- The number of cases requiring one, two, three, four, or more requests for additional information
- Median and high-end processing times between each request and the next FAA action
- Internal guidance used when issuing or evaluating such requests
3. Reversals and Modifications of Initial Decisions
The third request examines how often an initial denial, deferral, or adverse determination is later reversed, modified, or resolved through Special Issuance.
This request seeks records related to:
- Annual counts of reversed or modified decisions
- Special Issuances granted after an initial adverse determination
- Time elapsed between the initial decision and the eventual resolution
- Internal analyses concerning inconsistency, error rates, or reconsideration outcomes
4. In-Flight Medical Incapacitation and Safety Feedback
The fourth request examines how the FAA reviews in-flight medical incapacitation or impairment events involving pilots who held a valid FAA medical certificate at the time of the event.
This request seeks records related to:
- Policies and procedures governing review of such events
- Whether these events are used to update certification standards or examiner guidance
- Annual counts of medically relevant in-flight incapacitation events reviewed by the FAA
This area is especially important because it goes directly to the FAA aeromedical system’s stated purpose: reducing the risk of in-flight medical incapacitation.
5. Internal Reform and Modernization Efforts
The fifth request examines whether the FAA has internally identified problems within the aeromedical certification system and what actions, if any, have been taken.
This request seeks records related to:
- Working groups, task forces, or reform efforts
- Internal discussions of delays, bottlenecks, or backlog risks
- Proposed changes to certification timelines, Special Issuance processing, or examiner oversight
- Management decisions to implement, defer, or decline reforms
Project Goal
The purpose of this project is not to begin with a conclusion.
The purpose is to determine whether the FAA aeromedical system can demonstrate:
- Clear and measurable standards
- Consistent application of those standards
- Timely administrative performance
- Accountability for examiner errors or process failures
- A meaningful connection between certification policy and real-world safety outcomes
UDS Aviation believes these are reasonable questions for any aviation safety system.
As records are received, UDS Aviation will publish updates, timelines, findings, and supporting documents as part of an ongoing review process. Research and analysis will be published publicly as part of a public service to improving aviation safety and the future of flight.
This project will remain focused on evidence, documentation, and measurable outcomes rather than speculation or rhetoric.
