Day One in Denver: HIMS’s Own Experts Made the Case for Reform

At the 2026 HIMS Basic Education Seminar, clinicians and FAA officials repeatedly called for individualized medicine, transparency, fair evaluations, reduced barriers, and removal of requirements that no longer serve a purpose. They also acknowledged a certification system still built upon 1996-era substance-use regulations, non-guaranteed step-down, and career-long abstinence. By the end of Day One, the case for modernization was coming from inside the room.

DENVER — September 9, 2026

Pilots for HIMS Reform came to Denver prepared to challenge parts of the HIMS system.

What we did not necessarily expect was to hear some of the strongest arguments for reform coming from the podium itself.

Day One of the 2026 HIMS Basic Education Seminar was not a story of villains and heroes. That would be an easy story to write, but it would not accurately reflect what happened in the room.

Speaker after speaker expressed genuine concern for pilots struggling with substance-use disorders. Peer volunteers described careers and lives saved. Clinicians emphasized compassionate treatment. FAA officials repeatedly spoke about reducing barriers, speeding certification decisions, increasing transparency, and getting healthy pilots back into the cockpit.

P4HR agrees with those objectives.

Addiction is real. Treatment can work. Peer support can save lives. Aviation safety matters.

But throughout the first day, another theme emerged just as clearly:

The science of recovery being taught inside HIMS has evolved considerably faster than parts of the regulatory architecture governing the pilots who enter it.

By the end of the day, clinicians had described recovery as individualized, dynamic, broader than abstinence, and deserving of fair and careful evaluation.

The FAA, meanwhile, described a system in which regulatory disqualification can exist even without a corresponding current clinical diagnosis, progression through monitoring is not guaranteed, the endpoint remains discretionary, and permanent abstinence continues for the duration of a pilot's flying career.

That tension deserves serious examination.

“As Soon As It Is Safe to Do So”

Deputy Federal Air Surgeon Dr. Brett Wyrick opened the seminar on behalf of Federal Air Surgeon Dr. Susan Northrup with a statement P4HR strongly supports.

The Office of Aerospace Medicine's job, he said, is to put pilots back into the cockpit “as soon as it is safe to do so.”

He also described significantly improved Special Issuance processing and an FAA medical organization handling an expanding certification workload.

Other FAA presentations throughout the day reinforced that progress. Officials reported turnaround times increasingly being measured in weeks rather than many months.

Those improvements matter.

But Wyrick's opening statement also frames the central question raised by everything that followed:

Once the FAA determines that a pilot is safe to return to the cockpit, what evidence determines how long extraordinary monitoring must continue?

And perhaps more importantly:

What evidence establishes when that pilot no longer requires extraordinary monitoring at all?

The current system has a process for reducing requirements.

It does not provide the same clarity about ending them.

“Recovery Is Not Abstinence”

One of the most consequential statements of the entire day came during the addiction-treatment presentation.

The speaker explained recovery as a process of cognitive and behavioral restructuring rather than merely the absence of substance use.

Then he said it plainly:

“Recovery is a state of mind. It is not absence of drugs.”

And:

“Recovery is not abstinence.”

Then came the point that should matter enormously to aeromedical policymakers:

“Recovery cannot be achieved by just drug testing.”

This was not an argument against abstinence.

It was a distinction between abstinence and recovery.

Testing can establish important objective information about substance use.

But a laboratory test does not, by itself, measure insight, judgment, coping mechanisms, behavioral change, relationships, accountability, self-awareness, or the other factors the seminar identified as markers of healthy recovery.

A person can be abstinent without being meaningfully recovered.

Conversely, a person can demonstrate years of profound recovery while continuing to be subjected to testing designed primarily to establish abstinence.

That distinction creates a legitimate policy question.

The FAA's HIMS Step Down Plan states that testing frequencies are minimums, can be increased at a HIMS AME's discretion, and that permanent abstinence from mind- and mood-altering substances is required for the duration of the flying career. FAA guidance also expressly states that progression through the Step Down Plan is not guaranteed.

None of that means testing has no safety value.

But if recovery—not merely abstinence—is the actual clinical objective, there must be evidence establishing how much additional safety value extraordinary testing produces after many years of demonstrated recovery.

That evidence should be measurable, transparent, and available for scrutiny.

Fairness Before Treatment

The morning treatment presentation also addressed something P4HR considers fundamental: what happens when a pilot disputes the diagnosis that places him or her into this system.

Evaluations involving safety-sensitive professionals, the speaker emphasized, have enormous downstream consequences involving employment, licensure, medical certification, treatment, and monitoring.

Therefore, they should not be conducted casually.

They should be performed:

“respectfully and with intent and with deliberation and with fairness.”

The presentation then addressed pilots who remain uncertain about or disagree with a substance-use diagnosis.

Rather than automatically moving that individual directly from assessment into treatment, the speaker advocated completing the assessment, explaining the evidence and giving the individual an opportunity to understand the conclusion.

And if disagreement remains:

“This is a great point to say, let's get a second opinion.”

That principle should not be controversial.

A diagnosis capable of triggering years of expensive treatment, psychiatric evaluation, neuropsychological testing, employment involvement and regulatory monitoring should be accurate before the extraordinary consequences begin.

Diagnosis first. Treatment second. Meaningful review when the diagnosis is disputed.

Those are not anti-HIMS principles.

They were being taught at HIMS.

Then the FAA Explained the Clinical-Regulatory Divide

Later, FAA Drug and Alcohol Division personnel explained something many pilots probably do not appreciate.

A clinical diagnosis under DSM-5 and an FAA regulatory determination under Part 67 are not necessarily the same thing.

Modern DSM-5 substance-use-disorder criteria examine multiple manifestations of a disorder.

Part 67 uses a different construct.

For substance dependence, the FAA regulation identifies increased tolerance, withdrawal, impaired control, or continued use despite harm as alternative indicators. A single regulatory criterion can therefore create consequences even where a contemporary clinician may not diagnose a substance-use disorder under DSM-5.

FAA's current AME guidance itself uses the term “regulatory diagnosis.”

The presenter candidly explained that an individual may fail to receive a clinical DSM diagnosis but still be disqualified under the FAA regulatory framework.

That distinction is not something P4HR invented.

More importantly, it has already been examined by one of the nation's most authoritative scientific bodies.

The National Academies Already Identified the Problem

In 2023, the National Academies of Sciences, Engineering, and Medicine reviewed substance-misuse programs in commercial aviation.

Its conclusion was remarkably direct.

The National Academies found that FAA definitions in Part 67 do not always align with modern science-based diagnostic approaches and specifically observed that the FAA framework can result in a pilot meeting the FAA definition of abuse or dependence while not meeting DSM-5 clinical criteria for substance-use disorder.

Its recommendation?

The FAA should revise Part 67 to align, to the extent appropriate for aviation, with current evidence-based diagnostic approaches that account for severity and allow more personalized treatment.

Day One in Denver brought that recommendation to life.

One afternoon psychiatric presentation expressly noted that the relevant Part 67 framework traces to 1996.

That is correct. The current substance-dependence language in §67.107 originated in the FAA's March 19, 1996 Part 67 rulemaking.

The presenter then explained a modern clinical distinction that is highly relevant.

Tolerance and withdrawal should not automatically be confused with addiction itself. Physiologic dependence, he explained, is not synonymous with addiction. The pathological process fundamentally involves impaired control and continued behavior despite consequences, while tolerance and withdrawal may develop later.

Yet the FAA regulation still permits increased tolerance standing alone to serve as one of the alternative regulatory markers of “substance dependence.”

That does not automatically make the regulation invalid.

It does make the question of modernization unavoidable.

If our scientific understanding has evolved since 1996, why shouldn't the regulation evolve with it?

The National Academies has already recommended that it should.

“Not a One-Size-Fits-All”

The afternoon psychiatric session repeatedly returned to individualization.

Every pilot, attendees were told, possesses a different constellation of risk factors and protective factors.

Trauma may function differently in different individuals.

Recovery programs may look different.

Risk changes over time.

The speaker described the correct approach as:

“Not a one-size-fits-all; a very tailored, bespoke, unique approach.”

He specifically cautioned against equating recovery exclusively with AA.

SMART Recovery may work for one individual. Faith-based recovery may be meaningful to another. Other structured programs may work for someone else.

The critical issue is whether the person is genuinely engaged and whether the recovery is real.

And then came another remarkable line:

“It's not the FAA's recovery. It's your recovery.”

That is precisely the principle of individualized medicine.

It raises an obvious follow-up question.

If recovery itself belongs to the individual, and if risk factors and protective factors differ from person to person, why should the regulatory endpoint be determined principally by a nominal calendar applicable to nearly everyone?

Individualized treatment should ultimately lead to individualized risk assessment.

And individualized risk assessment should permit an individualized endpoint.

The FAA Chief Psychiatrist Described the Direction Reform Should Take

The afternoon dual-diagnosis presentation may have contained some of the most encouraging material of the day.

FAA psychiatry leadership described a goal of focusing more on a person's remission status rather than merely on the existence of a diagnostic label.

That is significant.

One person carrying a particular diagnosis, the presentation emphasized, may be very different from another person carrying the same label.

FAA officials repeatedly spoke about growth, insight and transparency.

One particularly important observation was that those characteristics can help distinguish among someone who requires monitoring, someone who requires close monitoring, and someone who has progressed to the point that close monitoring may no longer be necessary.

That is essentially a risk-stratified model.

P4HR's question is simple:

Why shouldn't that principle extend all the way to unrestricted certification when the evidence supports it?

If an individual's demonstrated recovery can justify progressively less monitoring, then there should be scientifically defined criteria capable of establishing when extraordinary monitoring is no longer medically necessary.

“Transparency Without Fear of Repercussions”

The same FAA presentation spoke about creating a system in which aviators can demonstrate transparency without fear of repercussions.

That phrase deserves attention.

For decades, aviation medicine has struggled with a fundamental safety problem: pilots may avoid seeking care when they believe doing so will threaten their careers.

FAA's own newly published psychotherapy guidance now expressly encourages pilots to seek help early before problems become severe. It also clarifies that therapy itself does not automatically require immediate reporting or grounding in every situation.

That is progress.

The FAA's developing OneGuide reflects the same philosophy.

The FAA says the OneGuide is intended to make internal medical-certification processes more consistent, understandable and publicly accessible. Remarkably, its project statement also says individualized assessments must use up-to-date medical practices and identifies due process for pilots and air traffic controllers as one of its purposes.

Those are exactly the principles reform advocates have been requesting.

Transparency.

Current medicine.

Individualized assessment.

Consistency.

Due process.

The challenge now is applying them completely to HIMS substance-use certification.

The FAA Demonstrated That Requirements Can Be Removed

Another afternoon statement deserves attention because it proves that aeromedical requirements are not immutable.

Discussing the FAA antidepressant program, the presenter noted that Chief Pilot reports are no longer required for ordinary antidepressant cases.

His explanation was strikingly simple:

“Let's remove things that we don't need.”

The FAA's August 26, 2026 AME Guide update confirms that the Chief Pilot requirement was removed from the antidepressant pages.

That is exactly what evidence-based modernization should look like.

A requirement once existed.

Experience accumulated.

FAA determined the requirement was no longer necessary.

FAA removed it.

Safety did not require preserving a requirement simply because it had historically been part of the process.

That creates an important precedent in philosophy, even if the programs are medically different.

P4HR is asking the FAA to apply the same question throughout HIMS:

What requirements continue because current evidence establishes their necessity—and what requirements continue primarily because they have always been there?

If something genuinely improves aviation safety, preserve it.

If something no longer produces measurable benefit, change it.

“There Is No Absolute Timeline”

Earlier in the day, the certification presentation had provided a remarkably straightforward description of the HIMS timeline:

“There's no timeline for the initial certification process, and there is no absolute timeline for the step-down process.”

The current Step Down Plan describes nominal progression through four phases.

The Initial Phase generally begins with the first Special Issuance.

The Early Phase follows.

The Advanced Phase generally begins after several additional years.

The Maintenance Phase generally arrives around Year Eight.

But the FAA's own written guidance expressly warns:

“Progression is NOT guaranteed.”

FAA guidance explains that the timeline is nominal, may be modified case by case, and depends upon compliance, professional evaluation and FAA review. Testing requirements are minimums and may be increased.

That distinction matters tremendously.

The Step Down Plan is not an eight-year entitlement to unrestricted certification.

It is an approximately eight-year pathway toward progressively reduced requirements while continuing under the larger substance-dependence framework.

And FAA guidance continues to require permanent abstinence for the duration of the flying career.

This is why the question of an objective endpoint matters so much.

How “Lifetime” Entered HIMS

The historical presentation also walked attendees through the evolution of monitoring.

HIMS monitoring was not always effectively career-long.

Earlier versions involved finite monitoring periods. Alcohol cases historically involved shorter periods. Drug cases and relapse cases generally received longer monitoring based on perceived risk.

The major change ultimately traces to NTSB Safety Recommendation A-07-43.

That recommendation called for continued Special Issuance follow-up of airmen clinically diagnosed with substance dependence.

The FAA subsequently implemented the modern HIMS Step Down Plan in response to that recommendation. FAA's own AME Guide says so.

Yet the seminar also confirmed that the current FAA regulatory determination of dependence is not necessarily equivalent to a contemporary clinical DSM diagnosis.

That distinction deserves further study.

If extraordinary career-long consequences originated in a safety recommendation concerning clinically diagnosed substance dependence, policymakers should examine whether every regulatory pathway currently producing those consequences rests upon the same scientific foundation.

That is not a conclusion.

It is a question that the FAA should be able to answer.

Even HIMS Recognized the Danger of Deterring Pilots

The historical presentation included another crucial point.

When extended monitoring was developed, the designers recognized the possibility that overly onerous requirements could discourage pilots from coming forward.

That concern resurfaced much more explicitly during the afternoon airline breakout.

Representatives compared airline HIMS programs across carriers: who pays for treatment, who pays for testing, what disability protection exists, what happens after relapse, what protections are actually written into collective-bargaining agreements or company policy, and how pilots return to work.

The variation was substantial.

At one point, a participant summarized the incentive problem plainly.

A pilot confronting a system that may remove him from work, provide no income and impose tens of thousands of dollars in personal expenses has a powerful incentive to attempt to “fix this myself.”

The participant suggested that carriers providing meaningful company and union support likely experience more self-referrals than programs that leave pilots carrying the financial burden themselves.

That proposition deserves empirical study.

But as a matter of human behavior, the concern is obvious.

A program intended to encourage early intervention cannot ignore the cost of entering the program.

If raising your hand may mean losing income, paying enormous treatment and evaluation costs, surrendering control of your medical certification and entering years of uncertain monitoring, some pilots will inevitably wait.

Waiting is not a safety improvement.

The safest system is one that makes pilots willing to seek help before a problem reaches the cockpit.

There Is No Single Airline “HIMS Program”

The afternoon breakout also reinforced an important distinction that is frequently lost in public discussion.

“HIMS” is not one completely uniform employment program.

Airline structures vary.

Some have detailed contractual protections.

Some rely heavily on longstanding practices or agreements distributed across multiple documents.

Some carriers pay significant treatment and monitoring costs.

Others provide less protection.

Relapse policies vary.

Disability benefits vary.

Return-to-work pathways vary.

One participant even acknowledged that much of one carrier's program had historically operated through understandings and “handshakes” rather than a single comprehensive written policy and expressed a desire to consolidate those protections.

That matters because FAA medical monitoring and employer HIMS participation are not the same thing.

FAA guidance distinguishes its medical monitoring requirements from the industry's HIMS structure. An airman may work through an FAA monitoring process with a HIMS-trained AME even outside a particular airline HIMS structure.

That distinction should be transparent to every pilot.

A regulatory medical requirement is one thing.

An employer's internal program is another.

They frequently interact, but they should not be represented as interchangeable.

Neuropsychology: Another Area Where Individual Context Matters

The afternoon neuropsychology presentation also offered useful balance.

The evaluator emphasized that neuropsychological testing is not designed to make pilots fail.

The objective is to determine whether cognitive functioning has recovered into a normal range and whether clinically meaningful impairment remains.

More importantly, the presenter emphasized context.

Sleep deprivation matters.

Acute anxiety matters.

A recent bereavement matters.

Learning disabilities matter.

Age matters.

Previous conditions matter.

A pilot arriving after only three hours of sleep might not be tested that day at all.

Again, the underlying principle was individualized assessment rather than mechanical box-checking.

That is good medicine.

P4HR believes the same individualized reasoning should follow the pilot throughout the certification process—not disappear once the evaluation phase is complete.

What Day One Actually Showed

The easiest article for P4HR to write from Denver would be one declaring that HIMS is fundamentally broken and everyone inside the system is defending it.

That is not what we observed.

We saw clinicians who care deeply about recovery.

We heard peer volunteers who credit HIMS with saving lives.

We saw FAA officials acknowledging old barriers and describing concrete efforts to reduce them.

We heard about dramatically improved processing times.

We heard the FAA encouraging psychotherapy and mental-health treatment.

We heard a commitment to make internal guidance public.

We heard a promise to focus increasingly on remission rather than labels.

We heard a desire for pilots to demonstrate transparency without fear.

We heard an FAA official celebrate the removal of a requirement that was no longer considered necessary.

And we heard clinicians repeatedly emphasize fairness, second opinions, individualized treatment and individualized risk.

Those developments should be recognized.

But they make the remaining contradictions harder—not easier—to ignore.

The Principles Are Already in the Room

By the end of Day One, a remarkably coherent set of principles had emerged.

Recovery is not simply abstinence.

Testing alone cannot establish recovery.

Diagnosis should be careful and fair.

A disputed diagnosis may warrant a second opinion.

Treatment should be individualized.

Different recovery pathways can work.

Risk factors and protective factors differ among individuals.

A diagnostic label does not tell us everything about the person carrying it.

Transparency should not be punished.

Medical guidance should be publicly accessible.

Current science should inform certification.

Requirements that no longer serve a purpose should be removed.

And individuals who demonstrate increasing stability may appropriately require less monitoring.

P4HR agrees with every one of those propositions.

Our position is straightforward:

Apply them all the way through the system.

If recovery is individualized, measure it individually.

If diagnosis must be fair, provide meaningful independent review.

If science changes, update the regulation.

If risk decreases, allow monitoring to decrease accordingly.

If a requirement is no longer necessary, remove it.

If transparency improves safety, eliminate unnecessary reasons for pilots to fear transparency.

And if a recovered pilot can demonstrate through objective evidence that extraordinary monitoring is no longer medically necessary, provide a defined pathway to unrestricted certification.

When Has a Recovered Pilot Done Enough?

Perhaps that is the most important question emerging from Day One in Denver.

The FAA can tell a pilot when extraordinary monitoring begins.

It can describe the nominal stages through which monitoring may decrease.

It can identify circumstances in which monitoring may be extended.

It can require permanent abstinence.

What remains far less clear is the objective answer to this:

When has a recovered pilot done enough?

Five years?

Eight years?

Ten?

Twenty?

What measurable difference in relapse risk justifies one answer rather than another?

What objective criteria distinguish the pilot who still needs extraordinary regulatory surveillance from one who does not?

What scientific evidence determines when that threshold has been crossed?

And why should a pilot who has demonstrated years of stable recovery remain indefinitely different from every other medically qualified pilot?

Those questions do not attack recovery.

They take recovery seriously.

They do not weaken HIMS.

Answered correctly, they could make HIMS more credible, more transparent and more likely to be trusted by the very pilots it is intended to help.

P4HR came to Denver believing that HIMS can preserve what works while reforming what does not.

After Day One, something unexpected happened.

Many of the principles supporting that reform were articulated by the clinicians, peer leaders and FAA officials standing at the HIMS podium themselves.

The science is moving.

Parts of the FAA are moving with it.

Now the regulatory structure must catch up.