Aviation Safety
FAA Has Taken Steps to Determine That It Has Made Correct Medical Certification Decisions
Gao ID: GAO-08-997 September 17, 2008
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.
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.
GAO-08-997, Aviation Safety: FAA Has Taken Steps to Determine That It Has Made Correct Medical Certification Decisions
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Report to the Chairman, Committee on Transportation and Infrastructure,
House of Representatives:
United States Government Accountability Office:
GAO:
September 2008:
Aviation Safety:
FAA Has Taken Steps to Determine That It Has Made Correct Medical
Certification Decisions:
GAO-08-997:
GAO Highlights:
Highlights of GAO-08-997, a report to the Chairman, Committee on
Transportation and Infrastructure, House of Representatives.
Why GAO Did This Study:
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.
What GAO Found:
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 (about 88 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.
Figure: Overview of FAA‘s Medical Certification Application Process:
[Refer to PDF for image]
This figure depicts the following information:
Step 1:
The pilot completes personal information and medical history sections
of application.
Step 2:
The medical examiner reviews medical history and completes physical
examination. Based on this information, the medical examiner determines
whether to issue medical certificate. The medical examiner sends FAA
the application.
Step 3:
FAA collects application information, sends the deferred and denied
applications to FAA staff for review, and closes others.
Source: GAO analysis based on FAA information.
[End of figure]
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-997]. For more
information, contact Susan Fleming at (202) 512-2834 or
flemings@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
FAA Uses Medical Examinations and Application Review Procedures to
Determine Whether Pilots Meet Standards:
FAA Has Developed Quality Assurance Programs to Check That Medical
Certificates Have Been Properly Issued:
Concluding Observations:
Agency Comments:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Description of Match of Data from FAA's Civil Airman
Registry to SSA's Disability Databases:
Appendix III: List of Potentially Disqualifying Medical Conditions:
Appendix IV: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Frequency of Pilot Medical Certification Examinations:
Table 2: General Description of Priority and Non-Priority Applications:
Table 3: Description of FAA Medical Certificate Quality Assurance
Reviews:
Table 4: Examples of Potentially Disabling Medical Conditions and
Factors That Affect FAA Medical Certification:
Table 5: Medically Certified Pilots Receiving Social Security
Disability Benefits as of February 2008:
Table 6: Breakdown of Pilot Records by Pilot-Provided and FAA-Provided
Social Security Numbers:
Table 7: Results of Matching Pilot Social Security Numbers to
Disability Benefits Program Data:
Table 8: Pilots Receiving Disability Benefits, Listed by Medical Class:
Table 9: Breakdown of Pilots Receiving Disability Benefits by Pilot-
Provided and FAA-Provided Social Security or Other Nine-Digit Numbers:
Table 10: The Most Common Disabling Medical Conditions for Pilots
Receiving Disability Benefits:
Figures:
Figure 1: Overview of FAA's Medical Certification Application Process:
Figure 2: Overview of Applications Routed to FAA Application Examiners
in 2007:
Figure 3: National Driver Register Check Process:
Abbreviations:
AME: aviation medical examiner:
DIWS: Document Imaging Workflow System:
DOT IG: Department of Transportation Office of Inspector General:
EVS: Employee Verification System:
FAA: Federal Aviation Administration:
NCIC: National Crime Information Center:
SSA: Social Security Administration:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
September 17, 2008:
The Honorable James L. Oberstar:
Chairman:
Committee on Transportation and Infrastructure:
House of Representatives:
Dear Mr. Chairman:
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,[Footnote 1] in part by requiring periodic
medical exams that certify the pilots meet federal medical standards.
[Footnote 2] 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.[Footnote 3] 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.[Footnote 4]
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.
[Footnote 5] 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.
Results in Brief:
Overall, FAA's pilot medical certification procedures consist of a
multi-step process intended to determine whether pilot applicants meet
medical standards. (See fig. 1.) As part of these procedures, aviation
medical examiners--generally private practice physicians whom FAA has
designated to examine pilots' medical conditions--review information
provided by pilots on their medical certification applications and the
results of their physical examinations before issuing pilots a medical
certificate.[Footnote 6] In the majority of cases (about 88 percent in
2007), applicants meet the medical standards for certification and
medical examiners issue a medical certificate.[Footnote 7] FAA uses a
computer system to process all the applications received from the
medical examiners. It identifies some applications as ones that FAA
staff must evaluate and decide whether to issue a certificate, for
example those in which medical examiners have deferred or denied the
medical certificate. The computer system also designates other
applications for further review, namely those in which medical
examiners issued the medical certificates and the application indicated
potentially disqualifying medical conditions. Finally, FAA checks an
independent database, the National Driver Register, each time a pilot
applies for medical certification for drug-and alcohol-related motor
vehicle actions and indications of substance abuse.
Figure 1: Overview of FAA's Medical Certification Application Process:
[See PDF for image]
This figure depicts the following information:
Step 1:
The pilot completes personal information and medical history sections
of application.
Step 2:
The medical examiner reviews medical history and completes physical
examination. Based on this information, the medical examiner determines
whether to issue medical certificate. The medical examiner sends FAA
the application.
Step 3:
FAA collects application information, sends the deferred and denied
applications to FAA staff for review, and closes others.
Source: GAO analysis based on FAA information.
[End of figure]
FAA has developed programs to check whether it has properly issued
medical certificates. Specifically, FAA has established two quality
assurance review programs to help ensure that FAA medical examiners and
FAA staff are following FAA standards and guidelines for issuing
medical certificates.
* One quality assurance review program evaluates certificates that
medical examiners issued. FAA began this program in 2006 and, in its
most recent review in 2007, identified 19 instances in which medical
examiners issued medical certificates to pilots who had disqualifying
medical conditions. 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
weaknesses in its processes and demonstrate how well its procedures are
ensuring that medical certificates are being issued according to
standards.
* A second review program evaluates certificates that FAA staff issued
or denied. These are applications that were deferred or denied by
medical examiners and subsequently evaluated by FAA staff. In 2007, FAA
reported reviewing 1,646 applications and found that staff overlooked
relevant medical documents in 16 applications and made clerical errors
in 44. FAA did not report finding any medical certificates that staff
had inappropriately issued. FAA uses the results of this quality
assurance program to evaluate individual FAA staff and provide training
as appropriate.
In addition to reviewing applications, FAA relies on the previously-
mentioned National Driver Register check for indications of substance
abuse. If FAA finds a conviction for a drug-or alcohol-related motor
vehicle action, FAA officials investigate the incident and take action
including possibly revoking the pilot's medical certificate. Finally,
due to legal concerns about recent litigation, FAA currently does not
check sources of information on federal disability benefits for
indications that pilots may have disqualifying medical conditions.
[Footnote 8] Although our analysis of the Social Security
Administration's disability databases found 1,246 of 394,985 pilots
holding current medical certificates while receiving disability
benefits, this does not necessarily mean these pilots do not meet FAA's
medical standards. It may, however, suggest that federal disability
databases can provide useful information on potentially disqualifying
medical conditions.
We provided a draft of this report to the Department of Transportation
and the Social Security Administration for review. The Department of
Transportation indicated that it generally agreed with our findings.
FAA and the Social Security Administration provided technical
clarifications, which we incorporated in the report as appropriate.
Background:
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.[Footnote 9]
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.[Footnote 10] 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).
Table 1: Frequency of Pilot Medical Certification Examinations:
Class of certificate: First-class;
Frequency: Every 6 months if 40 years of age or older; Every year if
under 40 years of age.
Class of certificate: Second-class;
Frequency: Every year.
Class of certificate: Third-class;
Frequency: Every 2 years if 40 years of age or older; Every 5 years if
under 40 years of age.
Source: GAO analysis of federal regulations and FAA information. See 14
CFR Part 61.23.
[End of table]
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.[Footnote 11]
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.
FAA Uses Medical Examinations and Application Review Procedures to
Determine Whether Pilots Meet Standards:
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.
AMEs Determine Whether Pilots Meet Medical Standards Based on Pilots'
Applications and Physical Examinations:
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.[Footnote 12] 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.[Footnote 13] 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.[Footnote 14] FAA may require pilots to take
a special medical flight test, practical test, or medical evaluation
for this purpose.[Footnote 15]
* The AME may defer the application for FAA review when the applicant
exhibits one or more disqualifying medical conditions.[Footnote 16]
(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.
FAA's Priority-Based Workload Procedures Target Resources to Selected
Applications for Review:
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.
Table 2: General Description of Priority and Non-Priority Applications:
Priority level: Priority applications;
Application characteristics:
* Applications where the AME denied the certificate or deferred the
decision to FAA application examiners in the Aerospace Medical
Certification Division;
* Applications where the AME issued the medical certificate under a
special issuance.
Priority level: Non-priority applications;
Application characteristics:
* Applications where the AME issued the medical certificate.
Source: GAO based on FAA information.
[End of table]
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.[Footnote 17] 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.
Figure 2: Overview of Applications Routed to FAA Application Examiners
in 2007:
[See PDF for image]
This figure is a pie-chart with additional data extracted into a
sidebar. The following data is depicted:
Overview of Applications Routed to FAA Application Examiners in 2007:
Total applications: 438,152;
Total non-priority applications: 399,962 (91.3%);
Priority applications: 34,590 (7.9%);
In process[A]: 3,600 (0.82%).
Total applications routed to application examiners in 2007: 48,557;
Priority applications (deferred, denied, and special issuances): 71.2%
(34,590);
Non-priority applications with potentially disqualifying medical
conditions: 28.8% (13,967).
Source: GAO analysis of FAA data.
[A] In process applications are considered those that are 'pending' in
the electronic review process.
[End of figure]
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.
[Footnote 18] 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.[Footnote 19] 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.
FAA Checks for Drug-and Alcohol-Related Motor Vehicle Actions Using
National Database:
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.[Footnote 20] 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.[Footnote 21] 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.
Figure 3: National Driver Register Check Process:
[See PDF for image]
This figure is an illustration of the National Driver Register Check
Process, as follows:
Up to 14 days:
Medical examiner conducts physical exam, issues, defers, or denies the
medical certificate, and submits the application information.
5 days:
FAA sends applicants‘ names to National Driver Register and receives
potential matches.
Up to 60 days:
* For potential matches, FAA begins preliminary investigation by
contacting state motor vehicle agencies.
* FAA has instant access to records for the 14 states where they have
electronic access.
* For the other states, it can take state motor vehicle agencies up to
60 days to reply.
Time depends on nature of investigation:
Depending on the nature of the investigation, FAA investigators take
additional steps, including notifying pilot, obtaining certified court
records, and taking administrative action if appropriate.
Time depends on nature of enforcement case:
AA‘s legal office carries out enforcement proceedings, which in the
case of an emergency revocation, can take up to 29 days.
Source: GAO analysis of FAA information.
[End of figure]
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.[Footnote 22] 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.[Footnote 23]
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.
FAA Has Developed Quality Assurance Programs to Check That Medical
Certificates Have Been Properly Issued:
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.
FAA Has Programs for Checking Whether AMEs and FAA Application
Examiners Properly Issued Medical Certificates:
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.[Footnote 24]
Table 3: Description of FAA Medical Certificate Quality Assurance
Reviews:
Type of quality assurance program: Review AME decisions;
Number of quality assurance specialists as of May 2008: 2;
Type of applications reviewed:
* A random sample of non-priority applications;
- with potentially disqualifying medical conditions;
- without potentially disqualifying medical conditions;
Description of responsibilities:
* Examine a sample of applications that were issued by AMEs;
* Determine whether AMEs issued the medical certificate appropriately;
* Share results of their quality assurance reviews with managers,
supervisors, and AMEs.
Type of quality assurance program: Review application examiner
decisions;
Number of quality assurance specialists as of May 2008: 3;
Type of applications reviewed:
* A random sample of priority applications;
- deferred;
- denied;
- special issuance;
* A random sample of non-priority applications with potentially
disqualifying medical conditions[A];
Description of responsibilities:
* Examine a sample of applications that were reviewed by FAA
application examiners;
* Ensure FAA application examiners are complying with FAA standards and
guidelines;
* Either agree or disagree with the FAA application examiners' final
decision to issue or deny the medical certificate;
* Track error rates of FAA application examiners and report results
monthly to FAA managers.
Source: GAO analysis of FAA information.
[A] According to FAA officials, although the quality assurance
specialists receive non-priority applications with potentially
disqualifying medical conditions for review, they rarely have time to
review them.
[End of table]
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.[Footnote 25] 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.[Footnote 26] 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.
FAA Has Not Completely Implemented DOT IG's Recommendations to Identify
Pilots Who Receive Disability Benefits:
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.[Footnote 27] 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.[Footnote 28] 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.[Footnote 29] 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.
GAO's Database Match Results Indicate Disability Databases Have
Information on Potentially Disqualifying Medical Conditions:
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.[Footnote 30] 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).
[Footnote 31]
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.[Footnote 32]
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.
Table 4: Examples of Potentially Disabling Medical Conditions and
Factors That Affect FAA Medical Certification:
Medical condition: Spinal and muscular problems;
Does SSA consider pilot's condition disabling?
* Yes, if the pilot has documented anatomical or physiological
impairments that are expected to last for 12 months or result in
death[A];
Does FAA consider pilot's condition a disqualifying medical condition?
* Yes, if the pilot feels chronic back pain that requires medication
and cannot operate aircraft controls;
* No, if the pilot does not have chronic back pain that requires
medication.
Medical condition: Psychotic, non-psychotic disorders;
Does SSA consider pilot's condition disabling?
* Yes, if the pilot has documented psychological impairments such as a
lack of vigilance, an inability to concentrate, impaired decision
making, displaying suicidal gestures, that are expected to last for 12
months or result in death;
Does FAA consider pilot's condition a disqualifying medical condition?
* Yes, if the pilot is taking any psychotropic medication or other
medication therapy continuously;
* Yes, if the pilot has schizophrenia, bipolar disorder, depression or
other psychological disorders;
* No, if the pilot has not taken medication for at least 90 days and
passes several FAA-administered evaluations.
Source: GAO analysis of FAA and SSA data and statements.
[A] An impairment must be established by medical evidence consisting of
signs, symptoms, and laboratory findings. The impairment must also be
the result of abnormalities that can be shown by medically acceptable
clinical and laboratory diagnostic techniques.
[End of table]
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.[Footnote 33] 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.
Table 5: Medically Certified Pilots Receiving Social Security
Disability Benefits as of February 2008:
Provided FAA a Social Security number[A];
Number of pilots with current medical certificates: 308,036 (78
percent);
Number of pilots receiving Social Security disability benefits: 1,075
(86 percent).
Did not provide FAA a Social Security number[B];
Number of pilots with current medical certificates: 86,949 (22
percent);
Number of pilots receiving Social Security disability benefits: 171 (14
percent).
Total;
Number of pilots with current medical certificates: 394,985 (100
percent);
Number of pilots receiving Social Security disability benefits: 1,246
(100 percent).
Source: GAO analysis of FAA and SSA data.
[A] These are pilots who provided FAA with a nine-digit number on their
certificate application and for whom the SSA was able to either verify
the number provided or find a different valid Social Security number.
[B] These are pilots for whom FAA provided a nine-digit number and for
whom SSA was able to identify a Social Security number associated with
these individuals based on other data elements even though FAA did not
provide a Social Security number to SSA.
[End of table]
Concluding Observations:
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.
Agency Comments:
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 [hyperlink, 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.
Sincerely yours,
Signed by:
Susan A. Fleming:
Director, Physical Infrastructure Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
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.[Footnote
34] 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.
[End of section]
Appendix II: Description of Match of Data from FAA's Civil Airman
Registry to SSA's Disability Databases:
Overview:
This appendix describes the methodology we used to match data from the
Federal Aviation Administration's (FAA) Civil Airman Registry to data
from two of Social Security Administration's (SSA) disability benefits
programs--the Old Age, Survivors, and Disability Insurance program,
also known as Title II and Disability Insurance program and
Supplemental Security Income program, also known as Title XVI.[Footnote
35] The two programs comprise SSA's disability benefits. The purpose of
the data match was to determine (1) whether U.S. pilots with current
medical certificates were receiving disability benefits for disabling
medical conditions, (2) how many pilots who did not supply their Social
Security number to FAA received disability benefits relative to the
pilots who did provide FAA with a number, and (3) what the most common
disabling medical conditions were for pilots receiving disability
benefits. The results of the data match are dated as of February 29,
2008. We determined that the data were sufficiently reliable for the
nationwide trend analyses used for this report:
FAA's Civil Airman Registry:
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.
Pilots Included in the Analysis:
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.
SSA Verification of FAA Pilot Records:
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.
Table 6: Breakdown of Pilot Records by Pilot-Provided and FAA-Provided
Social Security Numbers:
Records with either Social Security or other nine-digit numbers
provided by pilots:
Number of pilot records: 308,036 (78 percent).
Records with FAA provided nine-digit number:
Number of pilot records: 86,949 (22 percent).
Total:
Number of pilot records: 394,985 (100 percent).
Source: GAO analysis of FAA and SSA data.
[End of table]
Exclusion of Records:
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.
SSA Disability Benefits Programs:
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.
SSA Disability Benefits Match Results:
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.)
Table 7: Results of Matching Pilot Social Security Numbers to
Disability Benefits Program Data:
SSA disability benefits program: Title II;
Number of pilots receiving SSA disability benefits: 1,186.
SSA disability benefits program: Title XVI;
Number of pilots receiving SSA disability benefits: 60.
Total records with a disability match:
Number of pilots receiving SSA disability benefits: 1,246.
Source: GAO analysis of FAA and SSA data.
[End of table]
Table 8: Pilots Receiving Disability Benefits, Listed by Medical Class:
Medical certificate class: First-class;
Number of pilots receiving SSA disability benefits: 56.
Medical certificate class: Second-class;
Number of pilots receiving SSA disability benefits: 201.
Medical certificate class: Third-class;
Number of pilots receiving SSA disability benefits: 989.
Total:
Number of pilots receiving SSA disability benefits: 1,246.
Source: GAO analysis of FAA and SSA data.
[End of table]
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).[Footnote 36] 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.
Table 9: Breakdown of Pilots Receiving Disability Benefits by Pilot-
Provided and FAA-Provided Social Security or Other Nine-Digit Numbers:
Pilots who supplied FAA with a Social Security or other nine-digit
number:
Number receiving SSA disability benefits: 1,075.
Pilots for whom FAA provided a nine-digit number:
Number receiving SSA disability benefits: 171.
Total:
Number receiving SSA disability benefits: 1,246.
Source: GAO analysis of FAA and SSA data.
[End of table]
Table 10: The Most Common Disabling Medical Conditions for Pilots
Receiving Disability Benefits:
Medical conditions for which pilots are receiving disability benefits:
Musculoskeletal;
Number of pilots receiving SSA disability benefits: 495.
Medical conditions for which pilots are receiving disability benefits:
Psychotic and non-psychotic;
Number of pilots receiving SSA disability benefits: 237.
Medical conditions for which pilots are receiving disability benefits:
Injuries;
Number of pilots receiving SSA disability benefits: 138.
Medical conditions for which pilots are receiving disability benefits:
Other medical conditions[A];
Number of pilots receiving SSA disability benefits: 376.
Medical conditions for which pilots are receiving disability benefits:
Total:
Number of pilots receiving SSA disability benefits: 1,246.
Source: GAO analysis of FAA and SSA data.
[A] Other medical conditions include nervous conditions (80), cancer
(79 pilots), and circulatory (62), digestive (36), endocrine system
(30) impairments, and miscellaneous other conditions (89).
[End of table]
Data Reliability of FAA's Pilot Data:
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.
Comparing the DOT-SSA IG Operation Safe Pilot Results with GAO's Data
Match Findings:
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.
[End of section]
Appendix III: List of Potentially Disqualifying Medical Conditions:
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.
* angina pectoris;
* bipolar disorder;
* cardiac valve replacement;
* 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 the cause;
* epilepsy;
* heart replacement;
* myocardial infarction;
* permanent cardiac pacemaker;
* personality disorder that is severe enough to have repeatedly
manifested itself by overt acts;
* psychosis;
* substance abuse and dependence; and:
* transient loss of control of nervous system function(s) without
satisfactory medical explanation of cause.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Susan Fleming (202) 512-2834 or flemings@gao.gov:
Acknowledgments:
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.
[End of section]
Footnotes:
[1] Active pilots are those pilots who hold a pilot certificate and a
valid medical certificate.
[2] Depending on their duties and the medical certificate for which
they are applying, pilots must apply for medical certification
periodically from every 6 months to every 5 years. (See table 1.)
[3] U.S. Department of Transportation Office of Inspector General,
Falsification of FAA Airman Medical Certificate Applications by
Disability Recipients (July 22, 2005).
[4] See GAO, Transportation Safety: Medical Certification ad Background
Check Requirements for Pilots, Vessel Masters, and Commercial Drivers
Vary, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-421R]
(Washington, D.C.: Feb. 27, 2008).
[5] The National Driver Register is a computerized database of
information about drivers who have had their licenses revoked or
suspended. The Register also shows driver conviction for serious
traffic violations such as driving while impaired by alcohol or drugs.
State motor vehicle agencies provide the National Driver Register with
information.
[6] Aviation medical examiners are physicians whom FAA has delegated
the authority to perform physical examinations to determine if
applicants are qualified to receive airman medical certificates and
student pilot certificates. They may or may not be the pilot's personal
physician.
[7] See GAO, Aviation Safety: FAA Needs to Strengthen the Management of
Its Designee Program, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-
05-40] (Washington, D.C.: Oct. 8, 2004) for additional information
about FAA's designee programs, including the aviation medical examiner
program.
[8] A pilot filed a lawsuit against the FAA, Social Security
Administration, and the U.S. Department of Transportation alleging his
rights were violated under the Privacy Act of 1974. 5 U.S.C. §552a.
[9] Pilot certificates are issued for airline transport, commercial,
air traffic control specialist, flight engineer, flight navigator,
flight instructor, private, student, and recreational.
[10] Sport, glider, and balloon pilots are not required to have a
medical certificate.
[11] Pilot applicants are required to certify that the information they
provide on the application is correct and are made aware that pursuant
to 18 U.S. Code Secs. 1001 and 3571, any person that makes any false,
fictitious or fraudulent statements on the FAA medical certification
application form may be fined up to $250,000 or imprisoned not more
than 5 years, or both.
[12] The application also requires that pilots report any attendance at
educational or rehabilitation programs as well as disclose non-traffic
misdemeanors or felonies. FAA is planning to implement a revised form
in September 2008 to require that pilots report arrests as well.
[13] If the AME has examined the pilot in the past, he or she may have
historical information on the pilot.
[14] FAA grants an authorization for special issuance when a pilot has
a medical condition that falls outside the range of the medical
standards but can still perform the duties authorized by the class of
the medical certificate without endangering public safety.
[15] FAA grants a statement of demonstrated ability in lieu of an
authorization to pilots with medical defects that are static or non-
progressive in nature.
[16] According to FAA officials, AMEs may choose to send applications
that they defer or deny to their FAA regional flight surgeon for review
and final determination. Although this does not occur very often, it
may occur in instances where the pilot was applying for a special
issuance and had been directed by the region to send his or her medical
information to the regional flight surgeon.
[17] FAA application examiners may send a pilot's application to one of
seven FAA physicians for help in making a final determination. In
addition, all priority applications where the pilot has some type of
heart-related medical issue are sent to a panel of physicians with
expertise in cardiac conditions.
[18] AMEs can issue a medical certificate to a pilot that has a
disqualifying medical condition, if he or she receives prior FAA
approval. In these cases, DIWS will identify the disqualifying medical
condition and route the application to an application examiner even
though the AME issued the medical certificate.
[19] FAA requires that physicians attend a 1-week training session and
periodic refresher courses at the Civil Aerospace Medical Institute in
Oklahoma City, Okla.
[20] The Privacy Act of 1974 places limitations on the ability of
agencies, like FAA, to enforce a Social Security number disclosure
requirement by denying a license to an applicant for refusing to
disclose his or her Social Security number. The Privacy Act states that
an agency cannot "deny to any individual any right, benefit or
privilege provided by law because of such individual's refusal to
disclose his Social Security number" unless authorized by statute.
[21] 14 CFR Part 61.15(e) requires pilots to report to FAA drug-or
alcohol-related driving convictions within 60 days of conviction or
administrative action.
[22] The NCIC is a computerized index of criminal justice information
(i.e., criminal record history information, fugitives, missing
persons). It is available to federal, state, and local law enforcement
and other criminal justice agencies.
[23] FAA requested reinstatement of electronic access to state
databases which contain criminal history information (e.g., arrests,
convictions, warrants, etc.) in its reauthorization proposal.
[24] There are currently about 34 people that review applications.
Application examiners, on average, have 700 applications in their
workload queues and are required to review at least 30 applications a
day.
[25] This information on FAA's review of non-priority applications is
based on sample data. The data with confidence intervals would be 93.8%
(91% to 96.6%), 2.4% (0.6% to 4.2%) and 3.8% (1.6% to 6.0%). The 202
medical certificates that would have been issued inappropriately could
actually range from 85 to 318.
[26] According to FAA, application examiners avoid making critical
errors that would result in inappropriately issued or denied medical
certificates because they are encouraged to seek assistance if they
have doubt in making a determination.
[27] U.S. Department of Transportation Office of Inspector General,
Falsification of FAA Airman Medical Certificate Applications by
Disability Recipients (July 22, 2005).
[28] Of the remaining three pilots, two died before they were brought
to trial, one stemming from complications from his previously
undisclosed illness. Prosecutors declined to move forward in the case
of the third pilot, citing the pilot's severe mental incapacity.
[29] A pilot who was identified in Operation Safe Pilot as giving false
medical history to FAA on his medical certification application, and
who was subsequently convicted, filed a lawsuit against FAA, SSA, and
the U.S. Department of Transportation (DOT), claiming his rights were
violated under the Privacy Act of 1974 when SSA, DOT, and FAA exchanged
his personal identifying information. In August 2008, the United Stated
District Court for the Northern District of California ruled that this
particular case did not comply with the Privacy Act of 1974 because DOT
and SSA had not provided sufficient notice that it intended to conduct
such matches under its "routine use" exception and the sharing of
information did not comply with the agencies' definition of actions
constituting a routine use. Cooper v. FAA, No. C07-1393VRW(N.D.C.A.
2008).
[30] Our data excluded 7,889 pilot records for which SSA was unable to
verify Social Security numbers (see app. II for additional
information).
[31] Under the Privacy Act of 1974, GAO is exempt from the prohibition
on agencies disclosing records contained in a system of records, which
enabled authorized GAO personnel to conduct this database match. 5
U.S.C. §552a(b)(10).
[32] Our review also did not determine whether pilots receiving
disability benefits had a qualifying disability.
[33] As indicated previously, FAA does not require that pilot
applicants provide a Social Security number and, in the instances where
the pilot does not provide a number, FAA provides a nine-digit number
that does not conflict with numbers assigned by SSA. Our data match
analysis found that SSA was unable to verify some of the nine-digit
numbers provided by pilots as Social Security numbers. We did not
evaluate these cases further to determine whether they resulted from
intentional or unintentional causes (see app. II for more information).
[34] The National Driver Register is a computerized database of
information about drivers who have had their licenses revoked or
suspended. The Register also shows driver convictions for serious
traffic violations such as driving while impaired by alcohol or drugs.
State motor vehicle agencies provide the National Driver Register with
information.
[35] As previously noted, under the Privacy Act, GAO is exempt from the
prohibition on agencies disclosing records contained in a system of
records, which enabled authorized GAO personnel to conduct this
database match. 5 U.S.C. §552a(b)(10).
[36] The rate of disability benefits is slightly higher in the group of
pilots who provided FAA with a Social Security or other nine-digit
number than in the group of pilots whom FAA provided a nine-digit
number. However, the rates were low in both groups--less than one-half
of 1 percent. It is unclear whether differences in disability benefits
rates between the two groups are meaningful or simply a function of the
two benefits groups being very small.
[End of section]
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