FAA Special Issuance Medical Certificates: What Pilots and Student Pilots Need to Know

Last Updated on August 28, 2026 by pilotdiscovery

If you have a medical condition that does not meet the FAA’s normal medical standards, does that mean your dream of becoming a pilot is over?

Not necessarily.

Some pilots and aspiring pilots who do not qualify for an unrestricted FAA medical certificate may still be able to obtain medical certification through something known as a Special Issuance Medical Certificate.

The Special Issuance process can sound intimidating—especially if you are a student pilot who has never dealt with the FAA medical certification system before. You may have questions about whether you are medically disqualified, how long the process will take, whether you can continue flight training, whether you can still become a professional pilot, and what happens when it is time to renew your medical.

You may also encounter an entire alphabet soup of other FAA medical terms: AASI, CACI, SODA and BasicMed.

So what does all of this actually mean?

In this guide, we’ll walk through the Special Issuance process from the perspective of a pilot or prospective pilot trying to understand what may happen before, during and after an FAA medical examination.


What Is an FAA Special Issuance Medical Certificate?

Normally, an applicant seeking an FAA medical certificate must meet the medical standards established under 14 CFR Part 67.

However, not every pilot’s medical history fits neatly within those standards.

A pilot may have a diagnosis, medical history or other condition that prevents him or her from meeting the ordinary requirements for unrestricted medical certification. That does not necessarily mean that the FAA will permanently prohibit that person from flying.

Under 14 CFR § 67.401, the Federal Air Surgeon has discretion to authorize the issuance of a medical certificate when the FAA is satisfied that the applicant can safely perform the duties permitted by the class of medical certificate being sought.

This is what we generally refer to as Special Issuance.

Think of Special Issuance as an individualized pathway through the FAA medical certification system.

Rather than simply asking whether an applicant meets the normal medical standard, the FAA can examine the individual circumstances surrounding the applicant’s condition and determine whether medical certification can nevertheless be authorized.

That distinction is extremely important.

Having a medical condition that does not meet the FAA’s normal standards is not necessarily the same thing as being permanently unable to obtain an FAA medical certificate.

What Medical Conditions Can Require Special Issuance?

There is no single short list that describes every possible Special Issuance situation.

Potential cases can involve certain:

  • Cardiovascular conditions
  • Neurological conditions
  • Psychiatric conditions
  • Substance-related histories
  • Diabetes
  • Other medical diagnoses requiring additional FAA evaluation

However, simply knowing the name of a medical condition does not necessarily tell you whether you will receive a medical certificate—or what certification process will apply.

FAA medical certification can be highly condition-specific.

Two people may have medical histories that sound similar in casual conversation while having important differences in severity, stability, treatment or supporting medical documentation.

That is why it is dangerous to conclude that your situation will have a particular outcome simply because you found another pilot online with the same diagnosis.

Your Medications Can Matter Too

The FAA is not necessarily evaluating only your diagnosis.

The treatment of that condition can matter as well.

Some medications may be acceptable under particular circumstances, while others can require additional FAA review or prevent an Aviation Medical Examiner, or AME, from issuing a certificate at the time of the examination.

Side effects can also be relevant.

So when evaluating a potential FAA medical issue, you should not look exclusively at the name of the underlying diagnosis.

The FAA may need to consider the condition itself, its severity and stability, how it is being treated, what medications you are taking, whether you experience side effects, and what your medical records demonstrate.


What Should You Do Before Submitting MedXPress?

One of the most important parts of navigating a complicated FAA medical situation may occur before you ever begin the formal examination.

If you already know that you have a potentially complicated medical history, blindly completing MedXPress and walking into an AME’s office without understanding the possible requirements can create unnecessary problems and delays.

Instead, consider researching the FAA requirements applicable to your specific medical history before formally applying.

You may also want to discuss your circumstances with an AME.

In a complicated case, that could mean arranging a consultation with an AME before beginning the actual FAA medical examination process.

That distinction matters.

There is a difference between approaching an AME to discuss your circumstances hypothetically—

“Here is my medical history. What documentation might I need?”

—and formally beginning an FAA medical examination.

The objective is absolutely not to conceal a medical condition or avoid reporting something that must be reported.

The objective is the opposite: to understand what information may be required so that you can approach the certification process prepared.

Gather the Right Medical Documentation

Depending on the medical condition involved, the FAA may require documentation such as:

  • Treatment records
  • Hospital records
  • Specialist evaluations
  • Laboratory results
  • Imaging
  • Medication information
  • Condition-specific testing
  • Other relevant medical reports

The exact documentation required can vary substantially depending on the medical issue.

A cardiac condition may require a very different set of records and testing than a neurological, psychiatric or metabolic condition.

The FAA publishes various disposition tables, certification worksheets, disease protocols and Special Issuance guidance for medical conditions.

If you already know that something in your medical history could raise an FAA certification issue, researching those requirements beforehand may allow you to begin gathering the appropriate documentation before your examination.

The larger lesson is simple:

Do your homework before the FAA medical exam—not after your application has already been deferred.


Issued vs. Deferred vs. Denied: What’s the Difference?

Once you have completed MedXPress and are sitting in the AME’s office, there are three terms you need to understand:

Issued. Deferred. Denied.

These outcomes do not mean the same thing.

Issued

If you satisfy the applicable FAA medical requirements—or otherwise qualify for issuance—the AME may be able to issue your medical certificate.

For many applicants, that is the end of the immediate certification process.

But when the AME encounters a medical issue that he or she cannot resolve through normal issuance procedures, a different outcome may occur.

Deferred

If additional information, medical evaluation or a decision from the FAA is necessary, your application may be deferred.

A deferral is not the same thing as a denial.

Instead, the AME is effectively sending the case to the FAA for additional review.

The FAA can then evaluate the medical information and potentially request additional records, testing or evaluations before making its certification decision.

If you receive such a request, pay close attention to exactly what the FAA is asking you to provide.

Submitting incomplete information can create additional delays.

If the FAA asks for a particular specialist evaluation containing specified information, for example, sending a generic physician’s note may not necessarily satisfy that request.

And failing to provide required medical information can ultimately result in the denial of the application.

Denied

A denial is obviously more serious than a deferral, but even a denial does not necessarily mean that your aviation career is permanently over.

A denial means that you did not qualify under the unrestricted Part 67 medical standards based on the application under review.

Depending upon the circumstances, an applicant may have reconsideration or appeal rights.

In addition, some applicants who cannot qualify for an unrestricted medical certificate may potentially qualify through the Special Issuance process.

So remember these two important distinctions:

Deferred does not mean denied.

And:

Denied does not automatically mean permanently grounded.


How Long Does FAA Special Issuance Take?

This may be one of the most frustrating questions for an aspiring pilot because there is no universal answer.

A Special Issuance case can depend on factors such as:

  • The medical condition involved
  • The complexity of the applicant’s history
  • Whether the FAA already has the necessary documentation
  • Whether additional testing is required
  • Whether additional specialist evaluations are required
  • The level of FAA review necessary for the particular case

Consequently, a complicated FAA medical certification issue can potentially interfere with your flight-training timeline.

That makes preparation especially important.

You may not be able to control how long the FAA takes to review your case, but you can try to avoid making the process unnecessarily longer because something the FAA specifically requested was missing.

A Generic Doctor’s Note May Not Be Enough

Suppose the FAA asks for a specialist report addressing particular medical criteria.

It may be tempting to obtain a short note from your doctor saying that you are doing well.

But that does not necessarily mean that the FAA has received the information it requires to make an aeromedical decision.

If the FAA specifies particular testing, records or information that must be included in an evaluation, make sure you understand those requirements.

This is another reason why researching your medical situation before the examination can be valuable.

The more you understand about the FAA’s condition-specific requirements, the better positioned you may be to assemble a complete package.


Can You Continue Flight Training While Waiting for Special Issuance?

Suppose your medical application has been deferred and you are waiting for the FAA.

Does your flight training have to stop completely?

Not necessarily.

You generally do not need an FAA medical certificate simply to begin receiving dual flight instruction.

That means a student pilot may potentially continue training with a flight instructor while waiting for the medical certification process to be resolved.

However, there is an important limitation.

For a student pilot flying an airplane, helicopter, gyroplane or airship, the required medical certification must be obtained before flying solo.

So there is an important difference between:

Taking flight lessons with an instructor

and

Exercising pilot privileges that require you to hold the appropriate medical certification.

You cannot simply ignore the unresolved medical issue and exercise privileges for which a medical certificate is required.

Why Student Pilots Should Think About This Early

This distinction can have a real financial impact.

Imagine spending a significant amount of money on flight training and reaching the point where your instructor believes you are otherwise ready to solo—but your FAA medical certification is still unresolved.

You may be able to continue learning, but your progression through the normal training sequence could be affected.

Therefore, if you already suspect that you have a significant medical certification issue, consider addressing it early.

The sooner you understand what the FAA may require, the better you can evaluate how the medical process could affect your training timeline and when you may become eligible to solo.


Can You Become a Commercial or Airline Pilot With Special Issuance?

What if your goal is not simply to earn a Private Pilot Certificate?

What if you want to become a commercial pilot—or eventually fly professionally for an airline?

Does needing Special Issuance automatically eliminate those possibilities?

Not automatically.

Special Issuance is not limited exclusively to third-class medical certificates.

Depending on the condition and the FAA’s determination, a Special Issuance Authorization can specify the class of medical certificate the FAA permits to be issued.

Special Issuance pathways exist for numerous conditions across different medical classes.

However, this is where your long-term aviation goals become extremely important.

The medical standards and level of acceptable risk are not necessarily identical across private, commercial and airline operations.

Therefore, asking whether you can obtain some kind of FAA medical certificate may not answer the question that actually matters to your career.

If your objective is professional aviation, the better question is:

Can my specific medical condition and circumstances support the class of FAA medical certificate required for the flying career I intend to pursue?

Your Authorization may also contain a limited validity period, requirements for follow-up testing or evaluation, and potentially operational limitations.

In other words, “Can I get a medical?” and “Can I obtain and maintain the medical certification necessary for my intended aviation career?” are not always the same question.


What Happens After the FAA Approves Your Special Issuance?

After potentially gathering records, undergoing testing, waiting for FAA review and finally receiving approval, you might understandably assume that the difficult part is permanently behind you.

Not necessarily.

A Special Issuance Authorization is generally issued for a specified validity period.

The FAA may require ongoing reports, medical testing or evaluations before another certificate or Authorization can be issued.

In addition, your Special Issuance medical certificate cannot remain valid beyond the expiration of the underlying Authorization.

This means that receiving Special Issuance may not be a one-and-done event.

Depending on your condition and Authorization, maintaining medical certification may require continued compliance with FAA follow-up requirements.

What Is AASI?

This brings us to another important FAA acronym:

AASI — AME Assisted Special Issuance.

The initial Special Issuance determination comes from the FAA.

However, for certain qualifying conditions, after the FAA has granted the Special Issuance Authorization, an AME may subsequently be permitted to re-issue the medical certificate if the airman satisfies the requirements established in the Authorization and provides the necessary medical documentation.

That can make subsequent certification substantially different from the initial FAA Special Issuance review.

But that does not mean you should assume that renewal is automatic.

Your Authorization should tell you what follow-up information, medical reports and testing are required.

What If Your Medical Situation Changes?

Your responsibility also does not end merely because you currently possess a valid medical certificate.

Suppose you:

  • Develop new symptoms
  • Receive another medical diagnosis
  • Begin taking a new medication
  • Experience a meaningful change in an existing condition

Any of those developments could change the aeromedical picture.

Holding a valid medical certificate does not mean that a pilot can simply disregard a significant medical change until the next scheduled AME appointment.

Pilots have an ongoing responsibility to determine whether they remain medically fit to exercise the privileges of their certificates.


Special Issuance vs. AASI vs. CACI vs. SODA vs. BasicMed

Special Issuance is only one part of the FAA medical certification landscape.

As you research FAA medical requirements, you are likely to encounter several other terms that sound similar but refer to different processes.

Here is the basic distinction.

Special Issuance

Special Issuance is the individualized FAA pathway we have been discussing throughout this article.

It can allow an applicant who does not meet the normal medical standards to nevertheless receive medical certification when the FAA determines that the applicant can safely exercise the authorized privileges.

AASI — AME Assisted Special Issuance

AASI generally comes into the picture after the FAA has already made the initial Special Issuance determination for a qualifying condition.

If the applicant satisfies the FAA’s specified follow-up requirements, the AME may be authorized to re-issue the medical certificate during a subsequent examination.

So AASI should not be confused with the FAA’s initial Special Issuance decision.

CACI — Conditions AMEs Can Issue

CACI stands for Conditions AMEs Can Issue.

For medical conditions covered by a CACI worksheet, an applicant who satisfies all of the FAA’s specified criteria and is otherwise medically qualified may be issued a regular medical certificate by the AME without the case first being sent to the FAA for Special Issuance.

That makes CACI fundamentally different from the initial Special Issuance process.

SODA — Statement of Demonstrated Ability

A Statement of Demonstrated Ability, or SODA, generally applies to certain static or nonprogressive medical deficiencies.

In these circumstances, the FAA can determine that the individual is able to safely perform the relevant airman duties despite the medical deficiency.

Unlike a time-limited Special Issuance Authorization, a SODA does not normally expire, although it can be withdrawn if circumstances change.

BasicMed

Finally, there is BasicMed.

For qualifying pilots whose operations fall within the privileges permitted under BasicMed, BasicMed can eliminate the need to maintain a current FAA medical certificate.

However, BasicMed should not be viewed as a universal way to bypass Special Issuance.

Certain cardiovascular, neurological and mental-health conditions specifically require a pilot to complete the FAA Special Issuance process before operating under BasicMed.

And if the flying you intend to do requires a first- or second-class FAA medical certificate, BasicMed does not replace that requirement.

The appropriate pathway therefore depends on two major factors:

Your individual medical history and the type of flying you intend to do.


How to Approach a Complicated FAA Medical History

If there is one principle to take away from all of this, it is that having a complicated medical history does not automatically mean that you cannot become a pilot.

At the same time, you should not assume that every medical condition will be straightforward—or that another pilot’s experience predicts what the FAA will decide in your case.

Special Issuance is inherently individualized.

Your diagnosis is only part of the picture. The FAA may also need to consider the severity and stability of your condition, treatment, medication, side effects, specialist findings, testing and supporting documentation.

If you know that your medical history may create a certification issue, consider taking the following approach:

  1. Research your specific condition before beginning the FAA medical examination. Look for the FAA guidance, disposition tables, certification worksheets, disease protocols and Special Issuance requirements applicable to your circumstances.
  2. Consider speaking with an AME before formally beginning the examination process. For complicated medical histories, a consultation can help you better understand what information may be required.
  3. Gather the documentation the FAA actually requires. Depending on the condition, this may include medical records, specialist reports, imaging, laboratory results, medication information or condition-specific testing.
  4. Do not confuse a deferral with a denial. A deferred application has been sent to the FAA for additional review and may require additional documentation before a decision can be made.
  5. Respond carefully to FAA requests for additional information. A generic report that does not address the information the FAA requested may not resolve the case and could create additional delays.
  6. Think about your long-term flying goals. If you want to fly professionally, investigate whether your circumstances may support the particular class of medical certificate your career path will require—not merely whether some form of medical certification may be available.
  7. Understand the ongoing requirements after approval. Special Issuance may require periodic medical reports, testing and evaluations, and your Authorization may have its own validity period.

Preparation cannot guarantee that the FAA will approve a particular medical application.

It also cannot guarantee how quickly the FAA will make its decision.

But understanding the process before you formally enter it can help you avoid creating preventable complications of your own.


Frequently Asked Questions About FAA Special Issuance

Does needing Special Issuance mean I am permanently disqualified from flying?

No. Special Issuance exists specifically as a potential pathway for applicants who do not meet the normal unrestricted FAA medical standards but whom the FAA determines can safely exercise the privileges authorized.

Can my medication affect my FAA medical even if my underlying condition seems minor?

Yes. The FAA considers both medical conditions and their treatment. Medication use, potential side effects and the stability of the underlying condition can all be relevant to medical certification.

Should I speak with an AME before submitting MedXPress?

If you already know that you have a complicated medical history, you may want to consider an AME consultation before formally beginning the examination process. This can help you understand what documentation or testing may be required.

Is a deferred FAA medical the same as a denied medical?

No. A deferral means the AME cannot issue the certificate and is sending the application to the FAA for additional review. The FAA may request additional medical records, testing or evaluations before making a decision.

How long does Special Issuance take?

There is no single universal timeline. The process depends on factors such as the condition involved, complexity of the medical history, completeness of the submitted documentation, additional testing requirements and the level of FAA review involved.

Can I take flight lessons while waiting for Special Issuance?

Generally, you do not need an FAA medical certificate simply to receive dual flight instruction. However, student pilots flying airplanes, helicopters, gyroplanes or airships need the required medical certification before flying solo.

Can I become a commercial or airline pilot with Special Issuance?

Potentially. Special Issuance is not limited to third-class medical certificates. However, professional pilots should investigate whether their individual circumstances can support the particular class of medical certificate required for their intended aviation career.

Do I have to repeat the entire Special Issuance process every time I renew?

Not necessarily. For certain qualifying conditions, AME Assisted Special Issuance (AASI) may allow an AME to re-issue a medical certificate after the FAA has made the initial Special Issuance determination, provided the pilot satisfies the FAA’s specified follow-up requirements.

Is CACI the same as Special Issuance?

No. Under Conditions AMEs Can Issue (CACI), an AME can issue a regular medical certificate for certain covered conditions when the applicant meets the FAA’s specified criteria and is otherwise qualified, without first referring the case to the FAA for Special Issuance.

Is SODA the same as Special Issuance?

No. A Statement of Demonstrated Ability (SODA) generally addresses certain static or nonprogressive medical deficiencies where the FAA determines that the person can safely perform airman duties. Unlike a time-limited Special Issuance Authorization, a SODA does not normally expire, although circumstances can change.

Can I just use BasicMed instead of getting Special Issuance?

Not necessarily. BasicMed may allow some eligible pilots to operate without maintaining a current FAA medical certificate, but it is not a universal workaround for medical certification problems. Certain cardiovascular, neurological and mental-health conditions require completion of the FAA Special Issuance process before the pilot can operate under BasicMed.

BasicMed also cannot substitute for a first- or second-class medical when the operation being conducted requires one.


Final Thoughts

A complicated medical history can make the FAA medical certification process more complicated—but it does not automatically mean that your flying ambitions are finished.

Special Issuance provides a pathway through which the FAA can evaluate an applicant individually and, when appropriate, authorize medical certification despite the applicant not meeting the normal unrestricted medical standards.

The key is to approach the process intelligently.

Research your particular medical condition.

Understand what documentation the FAA may require.

If your medical history is complicated, consider discussing your situation with an Aviation Medical Examiner before formally beginning the examination process.

And most importantly, do not assume that words such as deferred, denied, Special Issuance, AASI, CACI, SODA or BasicMed all mean the same thing.

They represent different parts of the FAA medical certification system, and which pathway applies can depend on both your individual medical circumstances and the kind of flying you ultimately intend to do.

The better you understand that system before you begin, the better prepared you will be to navigate your own path through FAA medical certification.

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