Psychiatric and Neuropsychological Evaluations: Substance Abuse and Dependence

Requirement for both a Psychiatric and a Neuropsychological Evaluation

Substance use disorders, including abuse and dependence, not in satisfactory recovery make an airman unsafe to perform pilot duties. These evaluations are required to assess the disorder, quality of recovery, and potential other psychiatric conditions or neurocognitive deficits. Due to the differences in training and areas of expertise, separate evaluations and reports are required from both a qualified psychiatrist and a qualified clinical psychologist for determining an airman's medical qualifications. This guideline outlines the requirements for these evaluations.

• Copies of all records regarding prior psychiatric/substance-related hospitalizations, observations or treatment not previously submitted to the FAA.
• A complete copy of your agency medical records. You should request a copy of your agency records be sent directly to the psychiatrist and psychologist by the Aerospace Medical Certification Division (AMCD) in Oklahoma City, OK. For further information regarding this process, please call (405) 954-4821, select option '4' (for duplicate medical certificate or copies of medical records), then '3' (for certified copies of medical records).

Psychiatric Evaluation

Who may perform a psychiatric evaluation? Psychiatric evaluations must be conducted by a qualified psychiatrist who is board-certified by the American Board of Psychiatry and Neurology or the American Board of Osteopathic Neurology and Psychiatry, and must either be board certified in Addiction Psychiatry or have received training in the Human Intervention Motivation Study (HIMS) program. Preference is given for those who have completed HIMS training. Using a psychiatrist without this background may limit the usefulness of the report.

Components of an FAA Psychiatric Evaluation Report

At a minimum:

• A review of all available records, including academic records, records of prior psychiatric hospitalizations, and records of periods of observation or treatment (e.g., psychiatrist, psychologist, social worker, counselor, or neuropsychologist treatment notes). Records must be in sufficient detail to permit a clear evaluation of the nature and extent of any previous mental disorders.
• A thorough clinical interview to include a detailed history regarding: psychosocial or developmental problems; academic and employment performance; legal issues; substance use/abuse (including treatment and quality of recovery); aviation background and experience; medical conditions, and all medication use; and behavioral observations during the interview.
• A mental status examination.
• An integrated summary of findings with an explicit diagnostic statement, and the psychiatrist's opinion(s) and recommendation(s) for treatment, medication, therapy, counseling, rehabilitation, or monitoring should be explicitly stated. Opinions regarding clinically or aeromedically significant findings and the potential impact on aviation safety must be consistent with the Federal Aviation Regulations.

Portions that must be submitted by the psychiatrist

The psychiatrist's comprehensive and detailed report, as noted above, plus copies of supporting documentation. Recommendations should be strictly limited to the psychiatrist's area of expertise. Psychiatrists with questions are encouraged to call Charles Chesanow, D.O., FAA Chief Psychiatrist, at (202) 267-3767.

Neuropsychological Evaluation

Who performs the FAA Neuropsychological Evaluation? Neuropsychological evaluations must be conducted by a licensed clinical psychologist who is either board certified or 'board eligible' in clinical neuropsychology. 'Board eligible' means that the clinical neuropsychologist has the education, training, and clinical practice experience that would qualify him or her to sit for board certification with the American Board of Clinical Neuropsychology, the American Board of Professional Neuropsychology, and/or the American Board of Pediatric Neuropsychology. The clinical neuropsychologist also must have completed HIMS training.

Components of the FAA Neuropsychological Evaluation Report

At a minimum:

• A review of all available records, including academic records, records of prior psychiatric hospitalizations, and records of periods of observation or treatment (e.g., psychiatrist, psychologist, or pediatric neuropsychiatrist treatment notes). Records must be in sufficient detail to permit a clear evaluation of the nature and extent of any previous mental disorders.
• A thorough clinical interview to include a detailed history regarding: psychosocial or developmental problems; academic and employment performance; legal issues; substance use/abuse (including treatment and quality of recovery); aviation background and experience; medical conditions, and all medication use; and behavioral observations during the interview and testing.
• A mental status examination.
• Interpretation of a full battery of neuropsychological and psychological tests including but not limited to the core test battery (specified below).
• An integrated summary of findings with an explicit diagnostic statement, and the neuropsychologist's opinion(s) and recommendation(s) regarding clinically or aeromedically significant findings and the potential impact on aviation safety consistent with the Federal Aviation Regulations.

Core Test Battery

The core test battery listed below provides a standardized basis for the FAA's review of cases, and must include:

• CogScreen-Aeromedical Edition (CogScreen-AE)
• The complete Wechsler Adult Intelligence Scales (Processing Speed and Working Memory Indexes must be scored)
• Trail Making Test, Parts A and B (Reitan Trails A & B should be used since aviation norms are available for the original Reitan Trails A & B, but not for similar tests [e.g., Color Trails; Trails from Kaplan-Delis Executive Function, etc.])
• Executive function tests to include:
  1. Category Test or Wisconsin Card Sorting Test, and
  2. Stroop Color-Word Test
• Paced Auditory Serial Addition Test (PASAT)
• A continuous performance test (i.e., Test of Variables of Attention [TOVA], or Conners' Continuous Performance Test [CPT-II], or Integrated Visual and Auditory Continuous Performance Test [IVA+]), or Gordon Diagnostic System [GDS].
• Test of verbal memory (WMS-IV subtests, Rey Auditory Verbal Learning Test, or California Verbal Learning Test-II)
• Test of visual memory (WMS-IV subtests, Brief Visuospatial Memory Test-Revised, or Rey Complex Figure Test)
• Tests of Language including Boston Naming Test and Verbal Fluency (COWAT and a semantic fluency task)
• Psychomotor testing including Finger Tapping and Grooved Pegboard or Purdue Pegboard
• Personality testing, to include the Minnesota Multiphasic Personality Inventory (MMPI-2)

(The MMPI-2-RF is not an approved substitute. All scales, subscales, content, and supplementary scales must be scored and provided. Computer scoring is required. Abbreviated administrations are not acceptable.)

FAA NOTES: (1) All tests administered must be the most current edition of the test unless specified otherwise; (2) At the discretion of the examiner, additional tests may be clinically necessary to assure a complete assessment.

Submission Requirements for the Neuropsychological Evaluation

The neuropsychologist's report as noted above, plus the supporting documentation below:

• Copies of all computer score reports (e.g., CogScreen-AE score report, Pearson MMPI-2 Extended Score Report, TOVA, CPT-II or IVA+ Report).
• An appended score summary sheet that includes all scores for all tests administered. When available, pilot norms must be used. If pilot norms are not available for a particular test, then the normative comparison group (e.g., general population, age/education-corrected) must be specified. Also, when available, percentile scores must be included.

Recommendations should be strictly limited to the psychologist's area of expertise. Psychologists with questions are encouraged to call Chris Front, Psy.D, FAA Psychologist, at (202) 267-3767.

Additional Information for the Psychologist

• The FAA will not proceed with a review of the test findings without the above data.
• The data and clinical findings will be carefully safeguarded in accordance with the APA Ethical Principles of Psychologists and Code of Conduct (2002) as well as applicable federal law.
• Raw psychological testing data may be required at a future date for expert review by one of the FAA's consulting clinical psychologists. In that event, authorization for release of the data by the airman to the expert reviewer will need to be provided.

Future Testing Requirements

If eligible for unrestricted medical certification, no additional evaluations would be required. However, pilots found eligible for special issuance will be required to undergo periodic re-evaluations. The letter authorizing special issuance will outline the specific evaluations or testing required.