Who Was Actually at the Table?

When the Federal Aviation Administration formed the Mental Health and Aviation Medical Clearances Aviation Rulemaking Committee, it promised a forum in which the aviation community could examine the barriers that prevent pilots and air traffic controllers from reporting mental-health concerns and seeking appropriate care.

The committee’s work produced important recommendations. It recognized that fear, cost, career disruption, lengthy certification delays, excessive testing, and mistrust of the aeromedical system can discourage aviation professionals from seeking help. Those findings deserve serious consideration.

But before treating the committee as a genuine roundtable representing everyone affected by FAA mental-health policy, a more fundamental question must be asked:

The answer revealed by the FAA’s own charter, participant roster, recommendations, and voting records is more complicated than the agency’s description of broad stakeholder representation suggests.

The ARC included many respected people and major aviation organizations. It included pilot unions, trade associations, airline interests, universities, peer-support organizations, physicians, regulators, and representatives of foreign aviation authorities.

What it did not clearly include were designated representatives of the pilots living under the most burdensome parts of the aeromedical system—or voting representatives from several medical disciplines whose work the committee directly evaluated.

The ARC was institutionally broad. It was not necessarily representative of the full range of affected stakeholders or viewpoints.

First, This Was Not Actually a “HIMS ARC”

The committee’s formal name was the Mental Health and Aviation Medical Clearances Aviation Rulemaking Committee. The FAA chartered it on December 4, 2023, following a Department of Transportation Office of Inspector General recommendation that the agency work with airlines, pilot unions, and the aerospace-medical community to identify barriers discouraging pilots from disclosing and seeking treatment for mental-health conditions.

Its stated purpose was to address reporting, treatment, mental-health diagnoses, certification delays, education, stigma, and related barriers. The charter did not establish a comprehensive review of the Human Intervention Motivation Study program, indefinite HIMS monitoring, standards for release from Special Issuance, or the pathway to unrestricted medical certification. View the FAA ARC Charter.

That distinction matters.

HIMS practices and HIMS-associated professionals appeared throughout the committee’s work, and the ARC made recommendations affecting HIMS AMEs, HIMS-trained neuropsychologists, peer-support systems, testing requirements, and aeromedical certification. But it was not designed from the outset as a balanced assembly of every stakeholder affected by the HIMS program.

As a result, the committee could discuss HIMS-adjacent policy without formally giving HIMS participants themselves a defined voice.

The FAA Controlled the Selection Process

The ARC charter stated that membership would be balanced in “viewpoints, interests, and knowledge.” It also placed the appointment power squarely within the FAA.

The FAA co-chair was authorized to select and appoint the industry members and FAA participants and to select the industry co-chair from among the committee’s members. The charter also expressly limited membership to promote discussion. It allowed specialized working groups and invited subject-matter experts, but the core membership remained selected through the FAA-controlled appointment process.

The publicly released materials do not describe an open nomination process through which an individual HIMS participant, former participant, independent clinician, patient-rights advocate, or reform organization could apply for a seat.

That does not mean the ARC was improperly created. Aviation Rulemaking Committees are advisory bodies, and agencies routinely select their participants.

But it does mean that the ARC should not be portrayed as though all interested stakeholders naturally gathered around an open table. The FAA decided which organizations and perspectives would be formally included.

That makes the composition of the committee critically important.

The Voting Membership Was Primarily Institutional

The final report identifies 20 voting members. The organizations represented included:

• Air Line Pilots Association;
• Airlines for America;
• Aircraft Owners and Pilots Association;
• Coalition of Airline Pilots Associations;
• International Brotherhood of Teamsters;
• National Air Traffic Controllers Association;
• Professional Aviation Safety Specialists;
• Experimental Aircraft Association;
• Regional Airline Association;
• National Business Aviation Association;
• National Air Carrier Association;
• National Air Transportation Association;
• National Flight Training Alliance;
• United Aviate Academy;
• Embry-Riddle Aeronautical University;
• University of North Dakota;
• University of Michigan;
• Aviation Medicine Advisory Service;
• Mayo Clinic emeritus representation; and
• The International Pilot Peer Assist Coalition and Center for Aviation Mental Health.

The committee also included nonvoting observers and contributors from the National Transportation Safety Board, the United States Air Force, Transport Canada, the European Union Aviation Safety Agency, foreign civil aviation authorities, Northwestern Medicine, and a Senior HIMS AME. View the FAA’s final ARC report.

This was unquestionably a substantial collection of aviation organizations.

But an organization representing pilots generally is not necessarily the same as representation specifically chosen to convey the lived experience of the HIMS and Special Issuance systems.

Pilots Were Present—but Where Were the HIMS Participants?

Several pilots and pilot organizations participated in the ARC. ALPA held one of the industry co-chair positions, and organizations such as AOPA, CAPA, the Teamsters, EAA, and others had voting representation.

It would therefore be inaccurate to say that pilots were absent.

But the published roster does not identify any voting position specifically designated for:

• A current HIMS participant;
• A former HIMS participant;
• A pilot who completed treatment but remains under Special Issuance;
• A pilot seeking release to unrestricted medical certification;
• A pilot who experienced prolonged grounding during the certification process;
• A pilot required to undergo years of monitoring or repeated evaluations;
• A pilot who unsuccessfully challenged an aeromedical determination;
• An independent HIMS-reform organization; or
• A family bearing the financial and emotional costs of prolonged monitoring.

Some ARC members may have had personal aeromedical or HIMS experiences that were not disclosed in the report. The public record cannot establish that no participant possessed such experience.

The affected pilots whose careers, finances, medical privacy, and certificates are controlled by these policies were not visibly given their own seat. Instead, their interests were expected to be conveyed through large membership organizations, unions, peer-support structures, and other institutional representatives.

Those organizations may advocate sincerely for pilots. But institutional representation is not automatically a substitute for firsthand representation.

A pilot-union official may understand the system from a policy or assistance perspective. A pilot who has spent years complying with testing, psychiatric evaluations, HIMS AME appointments, Special Issuance restrictions, and unclear release standards understands it from an entirely different position.

A genuine roundtable requires both.

Medical Professionals Were Present—but Medicine Was Not Fully Represented

The same distinction applies to medical representation.

The ARC included physicians and people associated with medical institutions. The report also states that psychiatric and psychological experts from the FAA Office of Aerospace Medicine participated in the broader process.

But the voting roster reveals a much narrower picture than the general phrase “medical experts” might suggest.

Most significantly, Dr. Steven Altchuler stated in his own written concurrence:

“I am the only psychiatrist who is an official member of the ARC.”

He explained that he was the voting member contributing in-depth knowledge of psychiatric illness and its symptoms. This was not an accusation made by an outside critic. It was a limitation identified by the committee’s sole official psychiatrist in the final report itself.

The publicly released voting roster also does not identify any member as a:

• Clinical psychologist;
• Aviation psychologist;
• Neuropsychologist; or
• HIMS-trained neuropsychologist.

Psychological professionals may have provided information behind the scenes, participated through the FAA, or advised working groups. The report refers generally to psychological expertise within the Office of Aerospace Medicine.

But consultation is not the same as formal representation.

An expert who supplies information without a vote does not possess the same authority as a committee member who shapes language, negotiates recommendations, participates in final deliberations, and signs the report.

The Neuropsychology Omission Is Especially Significant

The absence of an identified voting neuropsychologist is particularly notable because the ARC made a direct recommendation about neurocognitive and neuropsychological testing.

Recommendation 5 called upon the FAA to minimize neurocognitive testing and use neuropsychological screening or full-battery testing only when clinically indicated. The ARC discussed the expense of evaluations, certification delays, the availability of HIMS-trained neuropsychologists, and whether the testing influenced FAA decisions.

The recommendation may be sensible. Pilots for HIMS Reform has repeatedly questioned unnecessary, repetitive, and expensive testing that is not supported by an individualized clinical need.

But the governance problem remains:

Neuropsychology is not interchangeable with psychiatry, aerospace medicine, occupational medicine, counseling, or aviation safety.

The FAA’s own medical guidance recognizes meaningful differences among these professions. In some aeromedical cases, the agency requires separate psychiatric and psychological evaluations because the clinicians possess different training and areas of expertise. FAA guidance likewise states that neuropsychological evaluations should be conducted by qualified neuropsychologists with aviation-specific training. View the FAA’s psychiatric and psychological evaluation guidance.

A committee can contain physicians and still fail to represent the full medical community relevant to its assignment.

That appears to be the concern raised by independent medical professionals who have spoken with P4HR: not that medicine was completely absent, but that the diversity of relevant clinical disciplines and independent medical viewpoints was insufficient.

The Comparison With the 2015 ARC Is Striking

The FAA’s earlier 2015 Pilot Fitness ARC provides an instructive comparison.

Its published medical working group expressly identified a neuropsychologist, an FAA clinical psychologist, physicians specializing in aerospace medicine, aviation medical examiners, and other medical representatives. The disciplines were clearly named in the report. View the 2015 Pilot Fitness ARC report.

The 2024 Mental Health ARC’s voting roster was less clinically diverse on its face. It identified one official psychiatrist and no voting member specifically described as a clinical psychologist or neuropsychologist.

This is not a minor matter of job titles.

The committee examined mental-health diagnoses, treatment, testing, certification, fitness determinations, peer-support intervention, and the conditions under which pilots should be grounded or returned to service. Those subjects call for independent representation from the full range of professionals who evaluate and treat pilots—not merely representatives connected to aviation institutions or the existing aeromedical framework.

Established HIMS Institutions Had Greater Access Than HIMS Participants

The formal participant list included several people and organizations closely connected to the existing aeromedical or peer-support structure.

ALPA and Airlines for America held industry co-chair positions. Aviation Medicine Advisory Service held a voting seat. A Senior HIMS AME participated as a contributor. A peer-assistance coalition and aviation mental-health center held an industry co-chair position. The FAA itself selected the committee’s membership.

None of this proves misconduct, bad faith, or improper financial motivation. The people involved may have brought substantial experience and a genuine desire to improve the system.

The issue is imbalance.

Organizations that operate within, advise, administer, or regularly interact with the existing aeromedical structure had formal access to the process. The pilots challenging that structure did not have an identified voting constituency of their own.

Independent clinicians who might question prevailing assumptions were also not visibly represented across the full range of relevant specialties.

The committee therefore risked hearing extensively from the system about the people subjected to it—without hearing directly and independently from enough of those people themselves.

A Compressed Process Produced Near-Total Agreement

The ARC held three in-person plenary sessions and numerous virtual meetings. One co-chair noted that the final report was produced in just 57 working days, from the first plenary session on January 9 to the final vote on March 28, 2024.

All 20 voting members ultimately supported the report:

• 17 concurred as written;
• 3 concurred with comments;
• None concurred with exceptions; and
• None dissented.

Speed does not prove that the work was superficial. Consensus does not prove that competing views were excluded. The report contains many recommendations that may materially improve the lives of pilots and controllers.

But speed and unanimity make the initial selection of viewpoints even more consequential.

When nearly everyone reaches agreement in a compressed process, the public must be able to trust that the people chosen at the beginning genuinely represented the full range of affected interests.

The published roster leaves legitimate reason to question whether that occurred.

What a Genuine Stakeholder Roundtable Would Include

Future FAA committees examining HIMS, Special Issuance, mental-health certification, or unrestricted medical certification should include designated seats for:

• Current HIMS participants;
• Former HIMS participants;
• Pilots who obtained unrestricted certification after completing HIMS;
• Pilots who remain restricted despite long-term compliance and recovery;
• General aviation pilots without union or airline representation;
• Independent pilot advocacy and reform organizations;
• HIMS AMEs and non-HIMS AMEs;
• Addiction-medicine physicians;
• Independent psychiatrists;
• Clinical and aviation psychologists;
• HIMS-trained and independent neuropsychologists;
• Treating mental-health professionals;
• Medical ethicists;
• Administrative-law and due-process experts;
• Airline and union representatives;
• Peer-support organizations; and
• Family members affected by prolonged grounding and monitoring.

No single constituency should control the discussion.

The FAA should also publish how members were nominated, what constituency each member was selected to represent, whether applicants were rejected, what conflicts were disclosed, and how testimony from people outside the committee was considered.

Transparency would not weaken the process. It would strengthen public confidence in it.

Representation Is More Than Filling Seats

The Mental Health ARC should not be dismissed. Its report identified real barriers and proposed reforms that deserve implementation. Its members devoted substantial time and effort to an urgent aviation-safety issue.

But appreciation for that work does not require pretending the committee represented everyone equally.

It did not.

The committee broadly represented established aviation institutions. It did not visibly provide formal representation to the pilots most deeply affected by long-term HIMS and Special Issuance requirements. It contained medical expertise, but its own sole official psychiatrist highlighted the limits of that representation, and the published voting roster did not identify a clinical psychologist or neuropsychologist.

That is not a true roundtable of all stakeholders.

It is a selected committee of institutional representatives whose conclusions may be valuable—but whose composition must be understood honestly.