Category Archives: Pilots

FAQ’s provided by the FAA on Sleep Apnea Guidelines

FAQ provided by the FAA to AME’s regarding the new sleep apnea guidelines. (click on hyperlink for full version off the FAA website)

Edited version below.

The airman was assessed 5 years ago for OSA but did not have a polysomnogram. The evaluation was negative. Is he required to have an updated sleep evaluation or a sleep study?                               No. If there has been NO CHANGE in his/her risk factors, follow Group/Box 2 of the flow chart and submit a copy of the previous assessment. However, if there has been a change in risk factors (e.g. elevated BMI, new atrial fibrillation, refractory hypertension, etc.), triage using the flow chart to determine if the airman needs a repeat assessment.

Does the FAA require a specific type of sleep study if one is warranted?                                                                                                                       Yes. The FAA requires that the test be either a Type I laboratory polysomnography or a Type II (7 channel) unattended home sleep test (HST) that provides comparable data and standards to laboratory diagnostic testing. It does not have to be a chain of custody study.

I evaluated the airman and triaged him into Group/ Box 5. He had a sleep study and is doing well on CPAP treatment. Does he have to wait for a time-limited certificate before he can return to flight duties?                                                                                                                                  No. Once the airman is compliant with and doing well on treatment, he has met the requirements for 14 CFR 61.53. The airman may return to flight status with the current certificate issued by the AME, PROVIDED that ALL the required information regarding OSA evaluation and treatment has been submitted to the FAA for review.

If I give the airman Specification Sheet A or B and he does not submit the required evaluation within 90 days and after the 30 day extension (if requested), what will happen?                                                   The airman will receive a failure to provide (FTP) denial.

How long does an airman have to be on CPAP with a new diagnosis of OSA before they can return to flying?                                                               The airman may submit the completed compliance statement and required documents to the FAA for review as soon as they are tolerating the therapy without difficulty and have no symptoms of OSA.

 The airman has mild or moderate sleep apnea. Is he required to use CPAP?                                                                                                                                  In most cases an AHI of 15 or more will require CPAP.

If the airman has a sleep study and is diagnosed with OSA does he/she get a new certificate?                                                                                        Yes. Once a diagnosis of OSA is established, a Special Issuance is required. When the airman submits the required supporting documents to the FAA, he/she will be evaluated for a Special Issuance.

 If an airman has a previously unreported history of OSA being treated with CPAP, can the AME issue?                                                                Yes. Issue a regular certificate (Group/Box 2), if the airman is otherwise qualified, and submit the required information for FAA decision.

What if the airman is high risk and has had a previous sleep study that was positive, but not one of the approved tests?                                  He is currently on CPAP and doing well. Does he have to get a new sleep study?  Submit the required information for FAA decision.

The airman had a sleep study in the past and did not have sleep apnea. It was not an approved test type. Will he have to get another sleep study?                                                                                                  The AME should follow the triage flow chart. If the airman is determined to be Group/Box 5 or 6, he/she will need a sleep evaluation. If a sleep study is warranted, it will need to be an approved test type (see FAQ #8). Submit the required information for FAA decision.

The airman has OSA and was on CPAP in the past. He has now lost weight and is only on a dental device?                                                                    Submit the required information for FAA decision.



The AME has been instructed to identify those Airmen who are at high risk of having obstructive sleep apnea (OSA). Information  has been provided to the AME by the FAA to help with this process. But no defined  system to determine risk for  OSA was provided.  Populations targeted for screening include a category called ‘high risk driving populations’. It can be safely assumed that Airmen fall into this group.  Another risk factor targets those individuals with a BMI of over 35.  Other factors that increase risk that are recommended for evaluation include high blood pressure.  The AME is also provided with risk assessment tools that include the STOP BANG questionnaire, that defines high risk of OSA as having 3 positive findings, that include: Age > 50, BMI > 35, Male, Neck Circumference of 16 inches or greater, High Blood Pressure, Snoring, Sleepiness and Breathing Pauses
Some confusion exists as to whether the Airman must admit to symptoms like daytime sleepiness, snoring and breathing pauses to qualify as high risk . The FAA guidelines do however clearly allow the AME to use his or her own clinical judgement in determining final risk for OSA. Examiners are aware that airman may not willingly admit to specific symptoms that may suggest increased risk of OSA.  Objective factors may be relied on to determine OSA risk.

If the airman believes that the chances of falling into the high risk OSA category at the time of the AME evaluation is increased then a decision should be made prior to the AME visit.

Decision A – Take a chance present for the AME evaluation and hope that the examiner does not determine the airman is at high risk for OSA. If this strategy succeeds then a certificate will be granted with no further requirements.  If however the examiner determines that the risk of OSA  is high, then the Airman will be provided with Spec Sheet B, that allows for 90 days in which a formal evaluation and possible treatment must occur. A medical certificate will be issued. But if the sleep study shows moderate to severe sleep apnea the airman may not exercise the privilege of the medical certificate until treatment compliance has been demonstrated.  The gap between diagnosis and treatment compliance may be weeks if not months. However programs like the Fly in Fly out program provided by Zeeba Sleep Center can expedite these situations and assure  very limited if any medical certificate lapses.
Decision B- Decide to be evaluated and possibly treated for OSA prior to the AME exam. Spec Sheet A will be issued and in this case as long as the sleep study has been performed prior to presenting to the AME , a medical certificate will be issues with the condition that all appropriate information pertaining to the diagnosis and treatment be provided within 90 days of the AME evaluation.  Thus the course of action is predetermined, no risk exists of having lapses in medical certificate validity.
Either way The Fly-in  Fly-out  program, takes the uncertainty out of the entire process. From start to completion of the SI, you will be handled by experts in the process of SI for pilots with sleep apnea. In most cases no time off work will be required .   The process of diagnosis, treatment and documentation of  effective compliance is consolidated in a very short time span, making the risk and uncertainty of successful special issuance very low.
The process involves, flying into Las Vegas, sleeping overnight in the sleep facility, meeting with the physician the following morning. You will then be setup with the sleep equipment, educated on its usage. Return home with the equipment which will have data monitoring ability. Sleep will be remotely monitored for a short period,  until criteria are met that will meet SI criteria.  Support documentation  for SI will be submitted  to the RFS or AMCD. Once the appropriate documentation is submitted the airman may continue to exercise his medical certificate. Annual recertification will be required.

FAA – Sleep Apnea Guidelines for AME’s

Contact us at 702 242-1562 for more information or to setup an appointment.

Or contact us at