AOPA comments on renewed FAA information collection for medicals

Because pilots are legally accountable for providing the correct information to the FAA when completing Form 8500-8 through MedXPress, AOPA believes that it should be as clear and easy to understand as possible. Pilots could face FAA enforcement action or even criminal penalties for any incorrect or false statements on the form, which is outlined and reinforced by the Pilot's Bill of Rights notification on the first page of Form 8500-8:

The Administrator is providing you with the applicable written notifications related to this investigation of your qualifications for an airman medical certificate:

• The nature of the Administrator's investigation, which is precipitated by your submission of this application, is to determine whether you meet the medical standards for airman medical certification under Title 14, Code of Federal Regulations (CFR) part 67.
• Any response to an inquiry by a representative of the Administrator by you in connection with this investigation of your qualifications for an airman medical certificate may be used as evidence against you.

On August 13, the FAA posted a notice to obtain approval from the Office of Management and Budget to continue using Form 8500-8 with the recent changes. To ensure that AOPA’s concerns about the changes have been documented and added to the official record, AOPA commented on the notice in October. Chief among the concerns are “additional instruction” drop-down menus, identified by a small "+" next to the question number. The drop-downs are easy to miss and difficult to understand.

Under the drop-down menus, there are now additional instructions that expand the scope of the question, or contradict the words used in the question. For example, under diabetes, the expanded language lists pre-diabetes in addition to actual types of diabetes.

In each of these expanded areas, the language and instructions are lengthy, confusing, and more likely to make a pilot check a box that might cause significant delays in the pilot receiving an airman medical certificate as well as opening the possibility of the pilot having to undergo invasive testing at his or her own expense.

In the past, both the Government Accountability Office and the NTSB have expressed their concerns on several areas of Form 8500-8; however, the FAA has continued to make ad hoc updates instead of complete revisions. AOPA urges the FAA to immediately undertake the process to make full revisions to the form and ensure the public and aviation community are included in the process.