Your AME finished the exam, and instead of handing you a certificate, they told you the application was being deferred to the FAA. If you searched for what that means within about ten minutes of leaving the office, you're in the right place, and you can start with this: a deferral is not a denial. It means the AME is not authorized to make the call on your case at the exam, so the decision moves to an FAA physician. Nothing has been taken away from you yet.
The FAA's own numbers say the wait is far shorter than it used to be, and that the biggest single variable is how completely you answer the records request. In the Federal Air Surgeon's Medical Bulletin for July 2026, Dr. Susan Northrup reported that the average age of a deferred case at disposition had fallen from nearly 200 days to under 80, and that 53 percent of all deferred cases were sitting waiting for the airman to return requested documentation. This post walks through each stage, what the FAA is doing during it, and where you can shorten the wait.
What a deferral actually means
When an AME completes your exam, they choose one of a few dispositions on the application. They can issue a certificate, defer to the FAA, or, rarely, deny. The FAA's airman-facing guidance puts it plainly: for some conditions, or if required documentation is missing, the AME "must defer the examination to the FAA for review and/or further investigation," and "in very rare cases, an AME can deny for a specifically disqualifying condition."
The AME Guide's instructions for Item 62 list when an examiner should defer:
- A disposition table or your Authorization letter tells the AME to defer
- More information or further evaluation is needed
- There is uncertainty about the significance of a finding
- You did not provide the required documents within 14 days of the exam
That last one is worth reading twice, because it is the deferral most pilots can still prevent.
The 14-day window nobody mentions at the exam
The AME Guide requires that all exams be transmitted to the FAA within 14 days, and it tells examiners not to delay transmitting beyond that while waiting on an applicant's records. If your AME is only missing a document or two, they can note in Block 60 that the records are coming and issue once they arrive, but the clock is 14 days, not indefinite.
So if you walked out being told "get me the cardiology note and I can probably issue," you have roughly two weeks to produce it, not two months. Miss that window and the exam goes to Oklahoma City as a deferral, which adds weeks or months to a decision your AME could have made at the desk. If you are in that position right now, the rest of this post matters less than making a phone call to your specialist's office today.
How long a deferral actually takes
Here are the current figures from the July 2026 bulletin. "General Review" cases are the ordinary ones, and they account for 61 percent of everything deferred to the FAA.
| Case type | You brought all documents to the AME | The FAA had to request records from you |
|---|---|---|
| General Review cases (61% of deferrals) | 14 days | 83 days |
| All deferred cases | 33 days | 85 days |
The gap between those two columns is the whole ballgame. Arriving with complete records, uploaded by your AME, is associated with a disposition in about two weeks. Making the FAA write to you and wait is associated with roughly three months.
For context on the trend: since January 2025 the FAA reports the total number of deferred unissued cases down 71 percent, and the number waiting on a physician to review them down 96 percent. Dr. Northrup noted the average case age figures are "real days including weekends and holidays." If you were told years ago that a deferral means six months in limbo, that was true once and is no longer the typical experience.
The FAA's internal clock
FAA Order 8500.1D sets the deadlines FAA staff work to after a deferral arrives. Knowing them tells you when silence is normal and when something may have gone astray.
| Stage | The FAA's deadline |
|---|---|
| Decide whether more information is needed | Within 30 days of receiving the deferral |
| Send you the letter requesting records | Within 15 days of that decision |
| Review what you send | Within 30 days of receiving it |
| Each further records request | Restarts the review cycle |
Read together, that means roughly six weeks can pass before the request letter even reaches you, and each round trip after that adds another month or more on the FAA's side alone. It also explains why a single incomplete submission is so costly: it doesn't pause the process, it starts a new cycle.
After reviewing your records, the reviewing official will issue a certificate if eligibility is established, issue a denial letter if it isn't, or request more information. Your documents may be read by an FAA physician with a background in aerospace, occupational, family, or internal medicine, or by a specialist in cardiology, ENT, ophthalmology, rheumatology, or another field, depending on your case.
The letter, and the deadline that actually applies
After a deferral you will receive a letter from the FAA. Most letters list the items you need to provide, and most of those items are medical records about your condition or medication.
Now the correction, because this is the most common piece of misinformation about deferrals on pilot forums: there is no universal 60-day deadline for a deferred applicant to send records. Order 8500.1D says the FAA's letter will request the required medical information "and a date that information must be received." The date printed on your letter is your deadline. Nothing else is.
Four genuinely different 60-day rules get mashed together into a mythical "60-day letter." They are:
| The 60 days you may have heard about | What it actually governs |
|---|---|
| Reversal window | The FAA may reverse a certificate your AME issued, within 60 calendar days of issuance. A reversal counts as a denial. |
| Response deadline for certificate holders | If you already hold an affirmed certificate and the FAA requests information, you have 60 days from service of that letter, and failure to respond leads to suspension or revocation under 14 CFR 67.413. This is not the deferred-applicant rule. |
| MedXPress validity | Your submitted application stays active for 60 days and disappears if your AME doesn't upload it in time. |
| NTSB petition | You have 60 days after a final denial of an unrestricted certificate to petition the NTSB. |
If your requested records don't arrive by the date in your letter, Order 8500.1D directs the reviewing official to issue a denial letter for failure to provide. The FAA's airman guidance states the same outcome more bluntly: failing to provide required or requested information "will result in a delay of your medical certificate issuance or a denial of your medical application." A denial on those grounds is an avoidable, self-inflicted one, and it is worth an extension request or a phone call rather than a missed date.
Clinical Progress Notes, not your After Visit Summary
This is the single most common reason a pilot gets a second records request, and the FAA has become emphatic about it.
What the FAA wants is a current, detailed Clinical Progress Note generated from an actual clinic visit with your treating physician or specialist, dated no more than 90 days before your exam. What pilots usually send is what the front desk gives them when they ask for their records: a patient-portal printout or an After Visit Summary.
In the FAA's words, the patient After Visit Summary or downloadable notes "is not sufficient as it may only contain SOME of the necessary information but not ALL the information the FAA needs." In most cases the FAA does not want a letter written by your doctor either. It wants a copy of the actual progress note, the document physicians write to track your condition and communicate with other physicians.
Practically:
- Ask the records department specifically for the clinical progress note from your most recent relevant visit, not a summary, not a portal export, and not a letter
- Check the date. A note older than 90 days at the time of your exam may not count
- If you have no recent visit, you may need to book one before the records will satisfy the request
- Read the note before you send it. It should describe your diagnosis, current treatment, dosages, and stability
Send documents through your AME
Once you have the records, do not mail them yourself if you can avoid it. The FAA's guidance is explicit: take the documents to your AME so they can add them electronically to your record, and "this is the fastest way to get documents to the FAA."
The disposition figures above are the evidence. The pilots with 14-day dispositions are the ones whose records went in through the AME's system rather than through the mail.
How to see where your case stands
Most pilots don't know this exists. Since April 2022, MedXPress shows the status of your application as it moves through the FAA's review, and it appears in your profile as soon as you submit. Announcing it, then Federal Air Surgeon Dr. Susan Northrup said that if pilots "can track where your ridesharing car is or the status of a company delivering your package, pilots should be able to see online the real-time status of their application."
Two caveats. The tracker shows status, not reasoning, and if your case is deferred or denied the detailed information still arrives by mail. And the underlying process didn't change when tracking was added, so a status that sits still for a few weeks is usually the FAA's normal review clock rather than a lost file.
The four ways this ends
| Outcome | What it means |
|---|---|
| Certificate issued | Eligibility was established on the records you sent. The certificate arrives as normal. |
| Special Issuance Authorization | You don't meet the unrestricted standards, but the FAA will certify you under 14 CFR 67.401 with extra documentation and usually a shorter duration. |
| SODA | A Statement of Demonstrated Ability, used for a static, non-progressive condition demonstrated to be compatible with safe operation. |
| Denial | You did not meet the unrestricted standards of 14 CFR part 67, with appeal instructions included. |
A Special Issuance is worth understanding before you fear it. The FAA's own description is that it requires more rigorous medical information and testing, and that its duration is usually more restrictive, but that an airman holding a Special Issuance medical certificate "may usually operate an aircraft in the same manner as an airman with an unrestricted medical certificate." For most pilots it is a paperwork burden, not a career change. Many of the conditions ClearedMed covers are certified this way routinely, including antidepressant use, ADHD, cardiac events, and substance use history.
If you're denied
Two things are true at once here: a denial is serious, and a first denial is frequently not the end.
A denial by your AME is not a final FAA action
Order 8500.1D states that an AME denial "is not a final FAA denial action" and is subject to reconsideration by the Manager of AAM-300, a Regional Flight Surgeon, or the Federal Air Surgeon. For many conditions that aren't named specifically in part 67, a denial by anyone other than the Federal Air Surgeon is likewise a non-final denial subject to reconsideration.
You have 30 days to ask for reconsideration
Under 14 CFR 67.409, a person denied a certificate has 30 days from the date of the denial to apply in writing to the Federal Air Surgeon for reconsideration. Miss it and you are considered to have withdrawn your application. Once a request reaches the Federal Air Surgeon through an authorized official, the Order gives the Federal Air Surgeon 60 days to act.
The NTSB is the next step after a final denial, with one large exception
The FAA's own appeals guidance says you may petition the National Transportation Safety Board within 60 days after a final FAA denial of an unrestricted medical certificate, and that an Administrative Law Judge may hold a hearing where the FAA presents medical testimony and you present yours, with the judge's decision reviewable by the full Board. But the same guidance states that the NTSB has no jurisdiction to review the denial of a SODA or a Special Issuance certificate. Order 8500.1D goes further and instructs FAA staff that correspondence referencing only 67.401 must not provide NTSB appeal rights. If your dispute is about Special Issuance terms rather than the unrestricted standards, your route is reconsideration by the Federal Air Surgeon, not an appeal to the NTSB. This distinction catches people out, and it is the point at which an aviation attorney stops being optional.
Can I fly while my application is deferred?
This is the question almost everyone reaching this page wants answered, and it is the one that cannot be answered responsibly in a blog post, because it turns on your certificate, your dates, and your specific condition. What we can do is name the two rules that govern it, so you can have an informed conversation rather than a guess.
First, a deferral is a decision about the application you just filed. Separately, 14 CFR 61.53 prohibits acting as pilot in command, or in any other capacity as a required pilot flight crewmember, while you know of a medical condition that would make you unable to meet the requirements for your medical certificate, or while taking medication or receiving treatment that has that effect. For operations that don't require a medical certificate, it prohibits flying while you know of any condition that would make you unable to operate safely.
That second rule applies independently of what any certificate in your pocket says, and applying it to your situation is a judgement about your health, not about paperwork. Ask your AME. If the deferral involves a condition where the answer has legal weight, ask an aviation attorney. Do not take the answer from a forum, and do not take it from this page.
Why pilots get deferred, by condition
If your deferral relates to one of these, the condition guide explains what the FAA requires and what documentation satisfies it:
- Antidepressants and mental health and the anxiety and depression fast track, which exists specifically to let AMEs issue at the exam in milder cases
- ADHD, where the evaluation requirements are extensive and worth reading before your exam
- Cardiac events and hypertension
- Type 2 diabetes
- Sleep apnea, where compliance data is usually the missing document
- Vision deficiencies
- Substance use history, where the path usually runs through a HIMS-trained AME
What not to do
- Don't send documents in dribbles. Each partial response restarts a review cycle rather than continuing one
- Don't let the date in the letter pass. That is how a deferral becomes a denial for failure to provide
- Don't send an After Visit Summary and hope it counts. It is the most common cause of a second request
- Don't stop treatment to look better on paper. Documented, stable treatment is what most FAA pathways are built around
- Don't assume silence is bad news. Six weeks before a letter arrives is inside the FAA's own timeline
The one-paragraph version
A deferral moves your decision from your AME to an FAA physician. The FAA will write to you listing the records it needs and the date it needs them by, and that date, not any rumored 60-day rule, is your deadline. Send a genuine clinical progress note dated within 90 days, not a portal summary, and hand it to your AME for electronic upload rather than mailing it. Do that and the FAA's own figures put an ordinary case at about two weeks; make them chase you and the same case averages closer to three months. If you're denied, you have 30 days to request reconsideration from the Federal Air Surgeon, and a first denial is often not the end of the road.
Before your next exam, run every medication through the medication checker, use the MedXPress prep tool to get your Item 18 answers and documentation right the first time, and if you need an examiner who handles your condition regularly, start with the AME directory. The best deferral is the one that never happens, and our post on common MedXPress mistakes covers the errors that cause the avoidable ones.
Sources
- FAA: How do I get a Medical Certificate and what to expect during the AME examination, last updated May 14, 2026
- FAA Order 8500.1D with Change 1: Airman Medical Certification — Disqualification Procedures, Change 1 effective June 12, 2013
- FAA Guide for Aviation Medical Examiners: Application Review, Item 62, last updated March 8, 2023
- FAA Guide for Aviation Medical Examiners: Airman Appeals, National Transportation Safety Board, last updated June 20, 2014
- Federal Air Surgeon's Medical Bulletin, Volume 60, Number 1, July 2026
- FAA press release: Pilots Now Able to Track Medical Applications in Real-Time, April 20, 2022
- 14 CFR 67.409: Denial of medical certificate
- 14 CFR 67.413: Medical records
- 14 CFR 61.53: Prohibition on operations during medical deficiency