Aviation Safety: FAA Has Taken Steps to Determine That It Has Made Correct Medical Certification Decisions
Published: 2008-09-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Federal Aviation Administration (FAA) seeks to make the U.S. aviation system one of the safest in the world. However, a 2005 Department of Transportation Inspector General investigation found that FAA had issued medical certificates to a small percentage of pilots with disqualifying medical conditions, such as heart conditions, schizophrenia, and drug or alcohol addiction. In response to your request, our report addresses the following questions: (1) what procedures does FAA use to certify that pilot applicants meet medical standards and (2) how does FAA determine that medical certificates have been properly issued? In addressing these objectives, GAO researched FAA guidance and federal regulations; interviewed federal officials; analyzed FAA's application review procedures, quality assurance program, and its use of the National Driver Register; and conducted a data match between FAA's pilot registry and Social Security Administration's disability programs. The data match does not determine if pilots receiving disability benefits have medical conditions that would disqualify them from holding an FAA medical certificate. GAO is not making recommendations in this report. The Department of Transportation generally agreed with our findings. FAA and the Social Security Administration provided technical clarifications, which we incorporated as appropriate.
section_title: What GAO Found
paragraphs: FAA's pilot medical certification procedures consist of a multi-step process intended to determine whether pilots meet medical standards. As part of its certification procedures, aviation medical examiners (AME) review information provided by pilot applicants and the results of their physical examination before issuing medical certificates. In the majority of cases (about88 percent in 2007), applicants meet medical standards and AMEs issue certificates. FAA uses a computer system to process all the applications. It designates some applications for additional review by FAA application examiners, such as when AMEs do not issue the medical certificate or defer the decision. The computer system also identifies for FAA review the applications in which AMEs issued the medical certificate and the application indicates potentially disqualifying medical conditions. Finally, FAA checks each pilot applicant against the National Driver Register to look for drug- and alcohol-related motor vehicle actions and indications of substance abuse. FAA has developed programs to help it determine whether it has properly issued medical certificates. Specifically, FAA has established two quality assurance review programs--one evaluating certificates that the AMEs issued and the other evaluating certificate decisions made by FAA application examiners. In its 2007 reviews, FAA identified 19 instances in which AMEs issued certificates to pilots who have disqualifying medical conditions as well as 16 cases in which FAA application examiners overlooked relevant medical documents and 44 with clerical errors. According to FAA officials, they plan to continue reviewing AME-issued certificates and collecting the results. These additional data from subsequent years could help FAA identify how well its procedures are ensuring that medical certificates are being properly issued. In addition, FAA relies on the National Driver Register check to help ensure pilots meet medical standards. Finally, due to recently resolved litigation, FAA currently does not check federal disability benefits databases for indications that pilots may have disqualifying medical conditions. Although our analysis of the Social Security Administration's disability databases found that 1,246 of 394,985 medically certified pilots were receiving disability benefits, this does not necessarily mean these pilots do not meet FAA medical standards. It may, however, indicate that federal disability databases can provide useful information on potentially disqualifying medical conditions.

section_title: Letter
paragraphs: The Federal Aviation Administration (FAA) is charged with regulating the  aviation industry and seeks to make the U. S. system one of the world’s  safest. As part of its regulatory role, FAA currently oversees about 590,000  active pilots, in part by requiring periodic medical exams that certify the  pilots meet federal medical standards. Pilot medical checks are critical  because physically or mentally unfit pilots can pose a danger to  themselves and to the public. Conditions that disqualify applicants for  medical certification include heart disease, diabetes, impaired hearing or  vision, psychosis, drug and alcohol dependence, and any disease,  condition, defect, or treatment that prevents or could prevent a pilot from  safely performing his or her duties. During 2007, 438,152 pilots applied for  a medical certificate and were examined by FAA-designated physicians.
A 2005 joint investigation by the Department of Transportation Office of  the Inspector General (DOT IG), Social Security Administration’s Office of  Inspector General, and California’s U.S. Attorney Office, known as  “Operation Safe Pilot” and reported by the DOT IG revealed that FAA had  issued medical certificates to a small percentage of pilots who had  disqualifying medical conditions that they did not report on their medical  certification applications. The DOT IG study compared pilots with medical  certificates in the state of California with the Social Security  Administration’s disability information and found 48 pilots who had not  made FAA aware of their disqualifying medical conditions. Because of  concerns raised by this investigation, you asked us to assess FAA’s efforts  for screening medical certification applicants and identifying medically  unqualified pilots. Accordingly, we answer the following questions (1)  what procedures does FAA use to certify that pilot applicants meet  medical standards and (2) how does FAA determine that medical  certificates have been properly issued? In addition, you asked us to  identify the number of pilots with current medical certificates who are  receiving disability benefits and determine if they provided FAA a Social  Security number. We issued a report in February 2008 describing federal  requirements for medical certification and background checks for pilots,  vessel masters, and commercial drivers.
To identify FAA’s procedures for pilot medical certification, we reviewed  agency guidance and federal regulations and met with FAA officials to  discuss FAA’s procedures for assessing, certifying, and documenting the  physical condition of pilot applicants. We obtained information about how  FAA’s application computer system sorts applications and identifies which  ones can be closed and which need review. We also obtained information  about how FAA accesses the National Driver Register to determine  whether pilot applicants have recent convictions for drug- and alcohol-  related motor vehicle actions. To identify how FAA determines that  medical certificates are properly issued, we analyzed FAA’s application  review procedures and quality assurance programs. We obtained  information about FAA’s progress in implementing DOT IG  recommendations to identify pilots receiving disability benefits. Finally,  we matched FAA’s list of medically certified pilots with the Social Security  Administration’s disability databases as of February 2008, to identify  whether pilots with medical certifications received disability benefits and  how many pilots who provided FAA with their Social Security numbers  received disability benefits compared to those who did not provide FAA  their Social Security numbers. We conducted our performance audit from  July 2007 through September 2008 in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform the audit to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings based on our audit objectives. See appendix I for  further information on our scope and methodology and appendix II for  detailed methodology on our FAA and Social Security Administration  disability databases match.
subsections: section_title: Background
paragraphs: According to FAA, safety is the FAA’s most important mission and its goal  is to achieve the lowest possible accident rate and constantly improve  safety. Supporting this safety goal are a number of activities and  requirements including federal regulations that require pilots to have both  a pilot certificate and medical certificate prior to operating an aircraft and  meet several requirements, depending on the level of certificate FAA  issues the applicant.
In order for FAA to issue a pilot certificate, applicants must demonstrate  various piloting skills; pass written tests of aeronautical knowledge; log  specified hours of flying time; read, speak, write, and understand the  English language; and meet certain age restrictions, in addition to meeting  the physical qualifications for a medical certificate and undergoing certain  background checks. FAA authorizes pilots to fly specific types of  airplanes or use specific types of aeronautical instruments after they meet  certain training and testing requirements.
Federal regulations establish three classes of medical certification that  correspond to the duties that pilots perform. Airline transport pilots that  serve as pilots in command of scheduled air carrier operations must hold  first-class medical certificates. Pilots that fly for compensation or hire or  serve as flight engineers or flight navigators, as well as air traffic control  tower operators, generally hold second-class medical certificates. Private  pilots hold third-class medical certificates. Pilots must undergo medical  examinations periodically to renew medical certificates (see table 1).
A pilot begins the medical certification process by completing an  application, including reporting his or her medical history on the  application, certifying that it is complete and true, and authorizing the  National Driver Register, through a designated state department of motor  vehicles, to furnish to the FAA information pertaining to his or her driving  record.
A pilot applicant is examined by an aviation medical examiner (AME),  who is a qualified physician in private practice in whom FAA has  delegated the authority to examine pilot applicants and make certification  decisions on behalf of FAA. To become an AME, FAA requires physicians  to receive basic training at its Civil Aerospace Medical Institute and  recurrent training through seminars to stay abreast of any changing  medical science. FAA collects information through a database to monitor  and evaluate the performance of AMEs. For example, if an AME makes an  error, FAA describes the type of error that was made in its database.
Finally, FAA has the authority to supersede and modify an AME’s decision  to issue or deny a medical certificate.
section_title: FAA Uses Medical Examinations and Application Review Procedures to Determine Whether Pilots Meet Standards
paragraphs: FAA has established medical certification procedures to identify whether  pilots meet medical standards. As part of these procedures, AMEs decide  whether or not to issue pilot medical certificates based on information  gathered from pilots and their physical examinations. In the majority of  cases, pilots meet the medical standards for certification and AMEs issue  the medical certificate. In addition to the AME examination, FAA has a  computer system that initially processes all the applications and prioritizes  some for review, such as those where the AMEs deferred the decision or  denied the certificate. The computer system also identifies for further  review applications where the AME has issued the medical certificate and  the application indicates potentially disqualifying medical conditions.  Finally, FAA checks the National Driver Register to help ensure pilots  meet standards by checking for indications of substance abuse.
subsections: section_title: AMEs Determine Whether Pilots Meet Medical Standards Based on Pilots’ Applications and Physical Examinations
paragraphs: AMEs determine whether a pilot meets FAA medical standards based on  their review of the pilot’s medical certification application and the results  of their physical examination. Pilots are responsible for providing  information on the application describing their medical history to alert the  AME of any health-related condition, such as cardiac problems or mental  disorders. Pilots also report whether their FAA medical certificate has  ever been denied, suspended, or revoked. In addition to answering medical  questions, the application requires the pilot to report any convictions and  administrative actions (e.g., suspensions or revocations) involving driving  while intoxicated, impaired, or under the influence of alcohol or drugs.  The AME is responsible for reviewing the applicant’s responses on the  application form to identify inconsistencies, missing information, and  disqualifying conditions.
The AMEs next conduct a physical examination. In 2007, FAA had about  4,400 AMEs conducting physical exams. To verify pilot information and  identify potential medical issues, the AME examines the pilot for vision,  hearing, mental, neurological, cardiovascular, and general medical  conditions. Additionally, if the pilot is applying for a first-class medical  certificate, the AME must conduct an electrocardiogram annually for  pilots over the age of 40. During the course of the medical examination,  the AME should use the information obtained from the review to ask the  applicant pertinent questions, especially questions that deal with type of  medications and pilot’s medical history. For example, if the applicant  reported use of anticoagulants or indicated that he or she had a coronary  artery angioplasty procedure, then the AME would be prompted to ask the  applicant to provide a copy of any FAA correspondence that authorized  medical certification on the medication or following the procedure; or  request the applicant to provide medical documentation regarding these  treatments and conditions. Certain aspects of the applicant’s medical  history may require more information. For example, if the pilot answered  yes to having experienced heart or vascular trouble on his or her  application, the AME is required to ask the pilot to clarify the significance  of that item of history by asking for supplementary reports from the  applicant’s personal physician.
After reviewing the medical history and completing the medical  examination, AMEs make one of the following determinations: issue a  medical certificate, issue a special certificate, defer making a decision, or  deny the certificate.
The AME may issue a medical certificate when the applicant meets all  medical standards. In such cases, the pilot leaves the AME’s office with his  or her medical certificate in hand.
AMEs may also issue a special, time-limited medical certificate (or special  issuance) to pilots whose medical conditions do not meet the federal  medical standards but have received FAA authorization to obtain a  medical certificate because they can perform their duties without  endangering public safety. FAA may require pilots to take a special  medical flight test, practical test, or medical evaluation for this purpose.
The AME may defer the application for FAA review when the applicant  exhibits one or more disqualifying medical conditions. (See app. III for a  list of disqualifying medical conditions.)
The AME may deny certification when the applicant does not meet the  medical standards.
When the AME defers or denies the application for a medical certificate or  issues a certificate under an authorization for special issuance, the  application is routed to FAA application examiners who decide whether to  issue or deny the certificate.
section_title: FAA’s Priority-Based Workload Procedures Target Resources to Selected Applications for Review
paragraphs: FAA established a computer system that prioritizes application review  procedures in order to target its resources toward applications that it  determined needed the most review. FAA’s computer system, called  Document Imaging Workflow System (DIWS), initially processes all  medical certification applications and designates each one as either a  priority or a non-priority application. See table 2 for definition of priority  and non-priority applications. In 2007, of the 438,152 medical certification  applications received, DIWS designated 34,590 applications as priority  applications, 399,962 applications as non-priority, and 3,600 as in process.  FAA’s computer system identifies and closes most non-priority  applications. In 2007, for example, FAA automatically processed and  closed the applications where AMEs issued medical certificates—about 88  percent of all medical applications.
After AMEs submit the applications, DIWS routes priority applications to  application examiners for review. These examiners review the medical  certification applications, supporting documentation, and any previous  medical issues in a pilot’s medical file. They follow FAA regulations,  guidance, and consult with FAA physicians in order to decide whether to  issue or deny the certificate. In 2007, FAA application examiners  evaluated all 34,590 priority applications (see fig. 2). In 2006, as a result of  growing concern by pilots and FAA’s management about the length of time  to review priority applications, FAA established a goal of completing each  application review in 30 days. According to FAA, as of February 2008, the  average time to process a priority application is 24 days.  0.82% In process(3,600)
71.2% (34,590)
Priority applications  (deferred, denied, and  special issuances)
28.8% (13,967)
Non-priority  applications with  potentially disqualifying  medical conditions  (48,557)
FAA’s computer system also evaluates non-priority applications  (applications where the AME decided to issue a certificate) and identifies  ones where the pilot or AME indicated one or more potentially  disqualifying medical conditions on the application. FAA programmed  DIWS to route these applications to application examiners for review due  to the presence of a potentially disqualifying medical condition. For  example, in 2007, of the applications that were designated as non-priority  applications, DIWS identified 13,967 with one or more potentially  disqualifying medical condition such as a history of heart or vascular  trouble, diabetes, or epilepsy. However, according to FAA officials, FAA’s  application examiners rarely if ever review these applications due to  workload and time constraints and these applications are removed from  the examiners’ workload after about two months. Once removed, non- priority applications are closed without being reviewed by an application  examiner, thus making the AME’s decision to issue the medical certificate  final. A random sample of closed non-priority applications are  subsequently selected for quality assurance review.
FAA officials indicated that one impact of not reviewing non-priority  applications is a greater reliance on AMEs to make a correct  determination and identify pilots that may have potentially disqualifying  medical conditions. Because FAA application examiners rarely have time  to review these non-priority applications, the burden is on the AME to  make the correct determination. According to FAA, this makes the AMEs  the first and sometimes the only line of defense because few if any non- priority applications are ever reviewed. More often than not, the AME  decisions are considered final.
Because of their importance, FAA trains AMEs to identify pilots that have  potentially disqualifying medical conditions or may not be medically fit to  fly. Moreover, FAA teaches AMEs how to detect discrepancies in  applicant responses. However, officials we spoke to also acknowledged  that no matter how well-trained the AMEs, the current medical  certification procedures are based on an honor system and rely on pilots  being truthful on the application form. Failure to disclose medical  information on the application form can be the basis for suspension or  revocation of a medical certificate. This is one reason why high-ranking  FAA officials visit air and pilot conventions around the country to teach  pilots about the importance of disclosing medical conditions on their  applications.
section_title: FAA Checks for Drug- and Alcohol-Related Motor Vehicle Actions Using National Database
paragraphs: FAA checks the National Driver Register each time a pilot applies for  medical certification to look for indications of substance dependence. The  National Driver Register identifies applicants who have had their drivers’  licenses revoked or suspended or been convicted of serious traffic  violations such as driving while impaired by alcohol or drugs. FAA  transmits applicants’ names, dates of birth, and Social Security numbers, if  available, to the National Driver Register weekly. If the search results  indicate the applicant has drug- or alcohol-related motor vehicle actions,  the FAA investigator contacts the state motor vehicle agency for  information to request the driving record for review. When applicants do  not provide their Social Security numbers, FAA investigators use  applicants’ demographic information and physical descriptive information  to validate identities. According to FAA officials, the lack of a Social  Security number does not present a significant barrier, at this time, for  completing their investigation. However, according to FAA officials,  access to the Social Security number is the most efficient means of  verifying a pilot’s identity.
Once FAA verifies the alcohol-related action, it determines whether the  person was a pilot at the time of the offense and whether he or she  reported the conviction to FAA. If the FAA investigator finds that the  pilot failed to properly report a drug- or alcohol-related action, he or she  conducts the investigation and sends the case to FAA legal counsel for  possible enforcement action. If an applicant did not report the convictions  or license actions on the application for medical certification, FAA may  deny, suspend, or revoke the applicant’s pilot and/or medical certificates,  if the applicant was aware of the conviction or license action. Applicants  can appeal certificate denials, suspensions, and revocations. (See fig. 3).  According to FAA officials, in 2007 FAA found 2,708 potential matches in  the National Driver Register and recommended 875 enforcement actions  for failure to properly report an alcohol-related motor vehicle action.  These enforcement actions included issuing warning letters, assessing civil  penalties, and suspending or revoking the pilot’s license and/or medical  certificate.
FAA officials reported that the National Driver Register investigation is  taking longer to complete than before July 2007, because FAA  investigators no longer have electronic access to each states’ records. FAA  investigators had used the National Crime Information Center (NCIC) to  access state records electronically and obtain driving-related conviction  information back from the states’ motor vehicle agencies in minutes.  However, in May 2007, FAA lost access to NCIC after the Justice  Department concluded FAA’s investigations unit did not have a criminal  justice function and therefore had no need to access databases containing  criminal information. According to FAA officials, the lack of electronic  access to states’ data has increased the time it takes to complete the  preliminary investigation to confirm a reportable alcohol-related incident  is on the driving record. FAA officials told us staff turnover at the state  agencies also creates delays because new employees do not understand  why FAA is requesting the information and investigators have to take time  to educate the new staff about FAA’s authority. During the first half of  fiscal year 2008, FAA investigations took about 59 days on average,  although the time it takes to complete an investigation varies depending  on the facts of the case. However, FAA has tried to limit the impact by  shifting staff and workload and authorizing compensatory time. Further,  beginning January 2008, FAA has been able to get limited electronic  information from 14 states’ motor vehicle records.
section_title: FAA Has Developed Quality Assurance Programs to Check That Medical Certificates Have Been Properly Issued
paragraphs: FAA has developed programs to help it determine whether AMEs and FAA  examiners properly issued medical certificates. Specifically, FAA has  established two quality assurance review programs in which FAA has  identified instances in which AMEs issued medical certificates to pilots  that have disqualifying medical conditions and in which FAA application  examiners overlooked relevant medical documents and made clerical  errors. According to FAA officials, they plan to continue reviewing AME- issued certificates and collecting data from the reviews. Also, as  previously mentioned, FAA checks the National Driver Register for  indications of substance abuse to help ensure pilots who are issued  medical certificates meet medical standards. FAA currently does not  check federal disability benefits for indications of disqualifying medical  conditions. Our comparison found that federal disability benefits  databases can provide useful information on pilots’ medical conditions.
subsections: section_title: FAA Has Programs for Checking Whether AMEs and FAA Application Examiners Properly Issued Medical Certificates
paragraphs: FAA has established two quality assurance programs to review selected  medical certificate applications. The first program evaluates whether  AMEs issued applications appropriately (see table 3). According to FAA  officials, the impetus for this quality assurance program was that FAA  recognized it needed to see if AMEs issued medical certificates  appropriately because the majority of these determinations are closed  without FAA review, thus making the AME decision final. In addition, this  quality assurance program in part takes the place of application  examiners’ reviews. Application examiners rarely review these  applications under current staffing levels, according to FAA officials, if  they are to meet the 30-day performance goal.
FAA conducted the first quality assurance review of AME issuance  decisions in 2006, and found that about 95.7 percent of the applications  were appropriately issued, 1.8 percent had insufficient information, and  2.5 percent were inappropriately issued. In most cases, the applications  that were inappropriately issued contained information that should have  led the AMEs to defer the decision to FAA rather than issuing the medical  certificate. This quality assurance review evaluated 2,000 of the  applications for AME-issued certificates from December 2004 to July  2005—0.6 percent of total applications. Quality reviewers based their  review on the pilots’ applications and AMEs examinations as well as other  information stored in FAA’s medical computer system.
FAA conducted the second quality assurance review in 2007 on 1,000  applications wherein AMEs issued medical certificates from January  through June 2007.
FAA randomly selected a sample of 500 non-priority applications from  189,239 applications that had no potentially disqualifying medical  conditions. Of those selected, FAA found that AMEs appropriately issued  96.6 percent or 483 of the certificates and issued 3.4 percent (17  certificates) when the application lacked complete information. However,  once FAA collected the appropriate documentation, it determined that  none of these certificates were inappropriately issued by AMEs.
FAA randomly selected another 500 non-priority applications from 5,305  issued applications that DIWS identified as having one or more potentially  disqualifying conditions. FAA found that AMEs appropriately issued 93.8  percent or 469 of the certificates, issued 2.4 percent (12 certificates) when  the application lacked complete information, and inappropriately issued  3.8 percent (19 certificates) of the sampled certificates. According to FAA,  if this rate were also applied to the 5,305 pilot applications that were  processed without further review, 202 medical certificates would have  been issued inappropriately in the January through June 2007 period. In  general, these were applications in which the AME issued the certificate  when he or she should have deferred the decision to FAA due to  indications of disqualifying medical problems. For example, a pilot who  had reported having a seizure was hospitalized overnight, and prescribed  anti-seizure medication for a month. The AME issued the medical  certificate when the application should have been deferred to FAA for  final determination. According to FAA, it took a range of actions  depending on the nature of the error, such as gathering additional  information about the medical condition, contacting the pilot or AME, and  revoking the medical certificate, although it did not track the number of  medical certificates that were revoked. FAA officials noted that they share  the results with managers, supervisors, and AMEs and at meetings to make  AMEs aware of the problems they are finding.
FAA officials indicated that they plan to continue the quality assurance  reviews of non-priority applications on a semi-annual basis and collect  data from the reviews. These additional data from subsequent years could  help identify increases or decreases in incomplete or inappropriately  issued certificates and demonstrate how well its certification procedures  are ensuring that medical certificates are being properly issued.
The second quality assurance program consists of quality assurance  specialists reviewing at least ten percent of (1) priority applications that  each FAA application examiners had evaluated and (2) some non-priority  applications with potentially disqualifying medical conditions. These  applications are selected randomly by DIWS. FAA established this  program in 2002 to ensure application examiners’ determinations comply  with FAA documentation standards and certification guidelines. FAA  officials told us that quality assurance specialists review up to 50 percent  of applications for application examiners who are new or in training.  Following their review of the applicant’s medical information, the quality  assurance specialists determine whether they agree with the decision the  FAA application examiner made and look for errors that may lead to  incorrect determinations. FAA uses monthly reports on the results of these  reviews to identify trends in error types. For example, FAA reported in  2007 it reviewed 1,646 applications and found that application examiners  made clerical errors in 44 applications and overlooked relevant medical  documentation in 16. In its 2007 reviews, FAA did not find any medical  certificates that application examiners had inappropriately issued. When  the quality assurance specialists identify errors, they discuss their findings  in person or hold group training sessions help application examiners avoid  making the error in the future.
section_title: FAA Has Not Completely Implemented DOT IG’s Recommendations to Identify Pilots Who Receive Disability Benefits
paragraphs: Another approach FAA could use to ensure pilots are medically qualified is  using disability information from other federal agencies for indications of  disqualifying medical conditions. In 2005, as a result of its Operation Safe  Pilot investigation, DOT IG recommended that FAA come up with a  strategy, such as database matching, to identify pilots who receive  disability benefits. DOT IG’s investigation indicated that federal agencies  that provide disability benefits (e.g., the Social Security Administration  (SSA) or the Departments of Labor or Veteran Affairs) would have  information that FAA could use to compare with its information about  pilot medical qualifications. Because disability benefits programs have  different disability standards, FAA would have to investigate the pilot’s  medical condition to assess whether the disability would disqualify him or  her from being medically certified under FAA’s standards.
The DOT IG conducted the investigation jointly with the SSA’s Office of  Inspector General and California’s U.S. Attorney Office. The investigation  compared medical certificates for pilots in northern California with the  SSA’s databases to determine, in part, if pilots were receiving Social  Security disability benefits. They found that 70 of 40,000 pilots were  receiving disability benefits and 48 pilots had disqualifying medical  conditions that were not reported to FAA. As a result of their  investigation, 45 of 48 pilots were indicted for falsification. All 45 pilots  either pled guilty or were convicted at trial.
As a result its investigation, DOT IG recommended that FAA work with  SSA and other disability benefits providers to implement a strategy to  check pilots against disability benefits recipients. According to FAA  officials, FAA has not implemented this recommendation because of  litigation resulting from the investigation. FAA will need to make  decisions about using information from disability benefits providers now  that the litigation is resolved. However, FAA is implementing two related  DOT IG recommendations by amending its medical certification  application to include a question about whether pilots are receiving  disability benefits currently and a notification that information pilots  provide on their medical certification application may be shared with  other federal agencies. According to FAA, these revisions should be in  place in October 2008 and establish the groundwork for checking  information on pilots applying for medical certification with other federal  information.
section_title: GAO’s Database Match Results Indicate Disability Databases Have Information on Potentially Disqualifying Medical Conditions
paragraphs: We found that for February 2008, less than 1 percent (1,246 of 394,985  pilots) of U.S. pilots with a current medical certificate were receiving  Social Security disability benefits. Of the pilots receiving a disability  benefit, private pilots with third-class medical certificates were most likely  to be receiving a Social Security disability benefit (79 percent or 989 of  1,246 pilots). Commercial pilots who generally fly small commercial  aircraft and have second-class medical certificates were the second largest  group of pilots to be receiving disability benefits (16 percent or 201 of  1,246 pilots). Finally, transport pilots who operate large passenger aircraft  and have first class medical certificates were least likely to be receiving a  Social Security disability benefit (4 percent or 56 of 1,246 pilots).
We found that back, spinal, and muscle medical problems, such as  degenerative back disorders, were the most common medical conditions.  They represented 40 percent or 495 of the pilots receiving disability  benefits. Psychotic and non-psychotic conditions, such as anxiety  disorders, were the second most common medical conditions,  representing 19 percent or 237 of the pilots receiving disability benefits.  Injury related conditions, such as skull fractures, were the third most  common conditions, representing 11 percent or 138 of the pilots receiving  disability benefits.
We did not evaluate the individual cases in which a pilot had a current  medical certificate and was receiving disability benefits to identify  whether the disability was a disqualifying condition. According to FAA  officials, they would have to review the facts of each case in order to  determine whether the pilot should hold a medical certificate and be  considered safe to fly. In situations where a pilot is being treated for  anxiety, for example, FAA officials indicated the pilot could operate an  aircraft if he or she met several conditions. The pilot would have to have  been off all medication for 90 days and passed several FAA-administered  evaluations. (See table 4.) According to an FAA official, FAA will need  additional staff to implement a data matching program to examine such  cases.
In addition to determining how many pilots were receiving disability  benefits, we also looked at whether or not pilots provided FAA with their  Social Security numbers. Our analysis indicated that about 78 percent of  the pilots provided FAA with a Social Security or other nine-digit number  while the rest did not supply a number. Of the 1,246 pilots who received  disability benefits, about 86 percent provided FAA a Social Security  number while the remaining 14 percent did not. (See table 5.) See  appendix II for a complete description of our methodology and results.
section_title: Concluding Observations
paragraphs: FAA’s overall goal is to provide the safest aviation system in the world,  and toward that end, FAA has established procedures for ensuring that  pilots obtain certifications showing that they are medically fit to fly.  Although the recent record of safety in this area has been good, an  accident stemming from a pilot’s poor medical condition would be  traumatic. FAA has also developed programs to determine if medical  certificates have been properly issued. As we report above, one of FAA’s  quality assurance programs found that the majority, but not all, of the  sampled medical certificates were properly issued. Because FAA only has  two years of quality assurance data, it has not yet identified potential  trends regarding the number of improperly issued medical certificates.  However, if FAA continues collecting the quality assurance data, as it  plans to do, it will have an opportunity to analyze the data for such trends  and further help FAA identify weaknesses in its guidance and practices.  Finally, due to recent litigation, FAA has decided not to use independent  databases that contain disability information. In the future, however, the  disability benefit information pilots report on the medical certification  application could help to identify pilots who might pose risks.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the Department of Transportation and  SSA for review. They provided comments by e-mail. The Department of  Transportation indicated that it generally agreed with our findings. We  also received technical clarifications from FAA’s Office of Aerospace  Medicine within the Office of Aviation Safety, and SSA’s Office of General  Counsel, which we incorporated into the report as appropriate.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  date. At that time, we will send copies of this report to congressional  committees and subcommittees with responsibilities for aviation issues  and to the Secretary of Transportation and the Commissioner of Social  Security. We will also make copies available to others upon request. In  addition, the report will be available at no charge on GAO’s Web site at  http://www.gao.gov.
Should you or your staff have any questions on matters discussed in this  report, please contact me at (202) 512-2834 or flemings@gao.gov. Contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this report. GAO staff who made contributions  to this report are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: In order to assess the Federal Aviation Administration’s (FAA) efforts to  screen medical certification applicants and identify medically unqualified  pilots, we answer the following questions (1) what procedures does FAA  use to certify that pilot applicants meet medical standards and (2) how  does FAA determine that medical certificates have been properly issued?  In addition, we identify the number of pilots with current medical  certificates who are receiving disability benefits and determine if they  provided FAA a Social Security number.
To identify FAA’s procedures for certifying that pilots meet medical  standards, we reviewed agency guidance and federal regulations. We  spoke with FAA officials about pilots’ application procedures, including  requirements to disclose their medical history, convictions and  administrative actions involving driving while under the influence of drugs  or alcohol, and whether their FAA medical certificate has ever been  denied, suspended, or revoked. We spoke with FAA officials and reviewed  agency guidance to identify aviation medical examiners’ (AME)  procedures for examining and documenting the physical condition of pilot  applicants and to determine under what circumstances AMEs would issue,  defer, or deny a medical certificate. We identified FAA application  examiners’ procedures for reviewing deferred, denied, and special  issuance applications.
We spoke with FAA officials about FAA’s computer system, called the  Document Imaging Workflow System (DIWS), to identify how it processes  and prioritizes applications, in particular how it selects some for  additional review and closes others. From this computer database, FAA  provided 2007 data about the number of medical certification applications  that it received and that DIWS identified as priority, non-priority, and non- priority with potentially disqualifying medical conditions. Based on these  data, FAA officials noted that application examiners reviewed all of the  priority applications in 2007.
Finally, we spoke with FAA investigators to identify FAA’s procedures for  accessing the National Driver Register, an independent database FAA uses  to determine if pilots have recent drug- or alcohol-related motor vehicle  actions that might indicate a substance abuse problem. Based on this  information and data provided by FAA, we identified the steps and the  duration of FAA’s activities to check the National Driver Register,  investigate potential matches, and take enforcement action.
To identify how FAA determines that medical certificates are properly  issued, we spoke with FAA officials about the quality assurance reviews of  priority and non-priority applications, and obtained information about the  frequency of the reviews, how FAA collects and reports results, and the  actions taken following the reviews (i.e., certificates revoked, training,  one-on-one meetings). We obtained the 2006 and 2007 quality assurance  review reports. We spoke with FAA officials about its methodology for  sampling non-priority applications with potentially disqualifying medical  conditions and determined the sample size provided valid measures of the  underlying population of non-priority applications. We identified how  quality assurance specialists review samples of the priority applications  completed by FAA application examiners, the types of errors they look for,  and what they do with the results of their reviews. We obtained and  reviewed the quality review supervisory reports for 2007.
We spoke with FAA officials to determine if FAA has implemented the  recommendations related to the Operation Safe Pilot investigation,  including using disability benefit information to identify pilot applicants  who may have disqualifying medical conditions. We obtained documents  and spoke with officials from the Department of Transportation and Social  Security Administration (SSA) Offices of the Inspector General about the  match they completed of pilots in northern California with Social Security  databases reported in their 2005 investigation and the status of the lawsuit  filed by a pilot convicted as a result of that investigation.
Finally, to determine if U.S. pilots with current medical certificates (as of  February 2008) were receiving SSA disability benefits, we obtained FAA’s  airman registry database for February 2008. We matched FAA pilot  medical certification records with two Social Security disability databases  to determine (1) the number of pilots with current medical certificates  who were receiving disability benefits; (2) from the group of pilots  receiving disability benefits, how many had supplied their Social Security  number to FAA and how many did not provide their Social Security  number; and (3) what the most common disabling medical conditions  were for pilots receiving disability benefits. We did not investigate each  case to determine if the pilot receiving SSA disability benefits had a  disqualifying medical condition according to FAA medical standards. (See  app. II for a detailed description of the data match.)
We conducted our performance audit from July 2007 through September  2008 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We also took  steps to assess data reliability by interviewing agency officials, reviewing  documents, performing electronic testing for obvious errors in accuracy  and completeness as well as inconsistencies and concluded that the data  were sufficiently reliable for our purposes. We believe that the evidence  obtained provides a reasonable basis for our findings based on our audit  objectives.
section_title: Appendix II: Description of Match of Data from FAA’s Civil Airman Registry to SSA’s Disability Databases
subsections: section_title: Overview
section_title: FAA’s Civil Airman Registry
paragraphs: Information in the airman registry is supplied by pilots when they apply  for initial certification to operate an aircraft and for medical certification.  When pilots apply for medical certification, they supply demographic  information which is submitted to FAA after an aviation medical examiner  (AME) performs a physical exam on the pilot. For identification purposes,  the application contains a field for a nine-digit number defined as the  Social Security number. Because of provisions in the 1974 Privacy Act,  FAA does not require pilots to provide their Social Security number. When  a pilot does not provide any data in this field, FAA provides a nine-digit  number from a range of numbers that do not conflict with numbers  assigned by SSA.
To determine how many active pilots are operating in the United States, in  February 2008, we obtained the previous 39 months’ worth of FAA’s Civil  Airman Registry certification records. In addition to demographic  information, this database contains information about the date a pilot’s  last medical certificate was submitted. We received records no older than  39 months to ensure that we had a population of pilots with recent first-,  second-, and third-class medical certificates. First-class medical  certificates must be renewed every 6 months for pilots 40 years of age or  older and every 12 months for pilots under 40 years of age, second-class  every 12 months, third-class medical certificates for pilots 40 years of age  or older every 24 months, and every 60 months for pilots under age 40.  There were 693,105 pilot records in the database when it was received  February 14, 2008. The records included U.S. as well as foreign pilots.
section_title: Pilots Included in the Analysis
paragraphs: In the analysis, we eliminated records for pilots who were deceased, who  do not need medical certification (e.g., hang glider and balloon pilots),  foreign pilots, duplicate records, and records for pilots whose medical  certificates were not current.
section_title: SSA Verification of FAA Pilot Records
paragraphs: To verify Social Security numbers, the pilot certificate records—those  with data supplied by the pilot in the field defined as Social Security  numbers and those with nine-digit numbers provided by FAA—were  processed through SSA’s Employee Verification System (EVS). The EVS is  routinely used by employers to verify workers’ Social Security numbers.  The EVS process first tests each number contained in the FAA field  labeled as a Social Security number in its attempt to verify that the number  is a valid Social Security number. This first step tests the number to see if  it is within the range of validly issued numbers and if so, then it checks the  name, date of birth, and gender to determine if it matches the information  in SSA’s database assigned that number. If the number does not meet the  validly issued range test, the EVS process will test the name, date of birth,  and gender to determine if a valid Social Security number matches the  values contained in these fields, and a final attempt to find a verified  Social Security number is made by matching just the name and date of  birth. The result of the EVS process for GAO was 305,063 pilot records  verified by Social Security number, name, date of birth, and gender. An  additional 1,602 records were verified by name, date of birth, and gender.  And finally, another 88,320 pilot records were included because the name  and date of birth matched. In all, 394,985 records had verified Social  Security numbers through the EVS process. The majority of the records  that were not verified were for foreign pilots, while the rest were duplicate  records based on the FAA database conscript.
About 78 percent (308,036) of the 394,985 records with verified Social  Security numbers were records where pilot applicants provided FAA with  a nine-digit number in the Social Security number field, and about 22  percent were pilot applicants for which FAA had provided a nine-digit  number. (See table 6.) We included in the 308,036 records 2,067 cases  where SSA was not able to verify the numbers provided by the pilots but  was able to identify Social Security numbers associated with these  individuals based on other data elements.
section_title: Exclusion of Records
paragraphs: There were 7,889 pilot records for which SSA was unable to verify Social  Security numbers. Eliminating the unverified records left 394,985 verified  records, with 305,969 representing Social Security numbers contained in  the FAA file and verified by SSA’s EVS process, and 89,016 that were  assigned a Social Security number through the EVS process.
section_title: SSA Disability Benefits Programs
paragraphs: Once the EVS process was complete, records were matched to SSA’s Title  II and Title XVI disability databases, both of which contain past and  present benefit information. Those eligible to receive disability benefits  from either disability fund must be considered 100 percent disabled. SSA  defines disability as the “inability to engage in any substantial gainful  activity by reason of any medically determinable physical or mental  impairment which can be expected to result in death or has lasted or can  be expected to last for a continuous period of not less than 12 months.”  Recipients’ cases may be periodically reviewed and if SSA determines the  person’s impairment has medically improved and he or she is able to  return to work, the person is removed from the program.
Under the Title II program, three categories of individuals can receive  disability benefits:    A disabled insured worker under 65.
A person disabled since childhood (before age 22) who is a dependent of a  deceased insured parent or a parent entitled to Title II disability or  retirement benefits.
A disabled widow or widower, age 50 to 60, if the deceased spouse was  insured under Social Security.
The Title XVI program provides supplemental security insurance payments  to individuals, including children under age 18, who are disabled and have  limited income and resources. Under Title XVI, there are two basic  categories under which a financially needy person can receive disability  payments:    An adult age 18 or over who is disabled.
A child (under age 18) who is disabled.
section_title: SSA Disability Benefits Match Results
paragraphs: The 394,985 pilot records match against SSA’s disability databases  identified less than 1 percent of the pilots (1,246) were receiving disability  benefits. Of the pilots receiving disability benefits, 79 percent (989) were  private pilots or third-class medical certificate holders while the remaining  21 percent (257) were commercial and transport pilots. (See tables 7 and  8.)
The data match showed that 1,075 of the pilots receiving Social Security  disability benefits supplied a Social Security or other nine-digit number to  FAA and 171 pilots receiving disability benefits did not supply a Social  Security number (see table 9). Back, spinal, and muscle medical  problems, such as degenerative back disorders, were the most common  disabling medical conditions representing 40 percent or 495 of the pilots  receiving disability benefits. Psychotic and non-psychotic conditions, such  as anxiety disorders, were the second most likely condition, representing  19 percent or 237 pilots receiving Social Security benefits. Injury-related  conditions, such as skull fractures, were the third most likely condition,  representing 11 percent or 138 of the pilots receiving disability benefits  (see table 10). Our review did not make a determination as to whether  pilots receiving disability benefits had a qualifying disability.
section_title: Data Reliability of FAA’s Pilot Data
paragraphs: To assess the reliability of the pilot data that FAA provided us, we   (1) performed electronic testing for obvious errors in accuracy and  completeness as well as inconsistencies; and (2) interviewed officials in  FAA’s Aviation Data Systems Branch and the Civil Aerospace Medical  Institute, Oklahoma City, who are knowledgeable about the content of the  data and how they were entered. The 7,889 pilot records excluded from  our analysis was a limitation to our matching process. However, we   compared the age, sex, and state of residence of the excluded records with  the verified records and found that the verified records and those that  were excluded were similar in the proportion of pilots in each of the three  medical classes. The comparison did show that women pilots comprised   10 percent of the records that could not be verified while making up   5 percent of the group whose Social Security numbers were verified by  SSA. We do not know whether the 7,889 pilot records are different from  the records we were able to put through the matching process with regard  to receipt of disability benefits.
We selected February 2008 as the time frame for the match between FAA  pilot certificates and SSA disability databases. If FAA were to replicate our  study, it might have different results, based on the length of time of the  comparison and the turnover of recipients receiving disability benefits.
In addition, if FAA were to find validated Social Security numbers for the  7,889 records excluded from our analysis, that might impact the results.
section_title: Comparing the DOT-SSA IG Operation Safe Pilot Results with GAO’s Data Match Findings
paragraphs: In 2005, the joint Department of Transportation and SSA Offices of the  Inspector General Operation Safe Pilot investigation reported that 3,220 of  40,000 pilots in northern California were collecting some sort of SSA  benefit. These were pilots who received any SSA benefit at any point in  their lifetime, including retirement and survivor benefits. Our discussions  with SSA IG officials determined that the Operation Safe Pilot  investigation identified 70 pilots who were receiving disability benefits.  The difference between the Operation Safe Pilot investigation and our data  match was the scope of benefits examined. Our examination focused on  pilots receiving only disability benefits for February 2008.
section_title: Appendix III: List of Potentially Disqualifying Medical Conditions
paragraphs: After reviewing the medical history and completing the examination,  aviation medical examiners (AME) must issue a medical certificate, deny  the application, or defer the action to the Aerospace Medical Certification  Division or the appropriate regional flight surgeon. AMEs may issue a  medical certificate only if the applicant meets all medical standards,  including those pertaining to medical history unless otherwise authorized  by FAA. AMEs may not issue a medical certification if the application fails  to meet specified minimum standards or demonstrates any conditions that  are considered “disqualifying.” FAA considers the following medical  conditions as disqualifying under 14 CFR Part 67.    coronary heart disease that has required treatment or, if untreated, that  has been symptomatic or clinically significant;   diabetes mellitus requiring insulin or other hypoglycemic medication;    disturbance of consciousness without satisfactory medical explanation of    personality disorder that is severe enough to have repeatedly manifested  itself by overt acts;    substance abuse and dependence; and  transient loss of control of nervous system function(s) without  satisfactory medical explanation of cause.
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact person named above, Catherine Colwell,  Assistant Director; Colin Fallon; Elizabeth A. Marchak; Gail Marnik; Tina  Paek; Vanessa Taylor; Walter Vance; and Crystal Wesco made key  contributions to this report.