Beyond the letter: supporting documentation for a CogScreen FAA medical appeal

TL;DR: If the FAA denied your medical certificate because of CogScreen-AE concerns, writing a strong reconsideration letter is necessary but not sufficient. The letter is the container. The supporting documentation is what actually moves the decision. Most appeals that stall or fail are missing one of five evidence categories: a compliant independent neuropsychological evaluation, a scored complete battery with pilot-normed data, a HIMS AME interpretive letter, functional performance evidence, or documented remediation. This post covers each one.

What you're actually fighting
Evidence category 1: The independent neuropsychological evaluation
Evidence category 2: The complete scored battery with pilot norms
Evidence category 3: The HIMS AME interpretive letter
Evidence category 4: Functional performance evidence
Evidence category 5: Remediation documentation
What to do if your original evaluation had problems
Organizing and submitting the package
One thing pilots consistently underestimate

What you're actually fighting {#what-youre-actually-fighting}

Most pilots approaching a CogScreen-related FAA appeal think of it as a writing problem. They focus on tone, structure, how persuasively to frame their case. Those things matter. But the FAA's Aerospace Medical Certification Division is not a jury. It does not render decisions based on the quality of your argument. It renders them based on the weight of your medical evidence relative to the standards in 14 CFR 67.107(c), 67.207(c), and 67.307(c).

Those regulations require that cognitive functioning not fall below what is required for safe pilot performance. The AMCD reads your file and asks one question: does this documentation support that this pilot meets that standard? If the answer is yes, they issue. If the documentation is incomplete, contradictory, or missing key components, they request more, which adds months.

Pilots of America threads about this process reflect a consistent pattern. Pilots who write detailed reconsideration letters but submit thin documentation packages spend months waiting for additional information requests. Pilots who arrive with a complete, organized evidence file move faster and succeed at higher rates. The letter explains. The documentation proves.

Here is what a complete package looks like.

Evidence category 1: The independent neuropsychological evaluation {#evidence-category-1}

If the FAA denied your medical certificate based on CogScreen-AE scores or a prior neuropsychological evaluation, the single most powerful piece of supporting documentation is a new evaluation from a different qualified provider.

Not because the original evaluator was necessarily wrong. Because additional data from a second qualified source either confirms the original findings (which tells you something important) or challenges them (which gives the FAA a genuine evidence conflict to resolve rather than a one-sided file).

The evaluator you choose matters more than most pilots realize. The FAA requires neuropsychological evaluations to be conducted by a qualified neuropsychologist with additional training in aviation-specific topics. For most cognitively driven appeal cases, that means someone HIMS-trained or on the FAA's approved neuropsychologist list. A board-certified neuropsychologist who has no FAA-specific training will write a report the AMCD cannot use without additional qualification, which creates delay.

When vetting a second evaluator, ask: Are they HIMS-trained? Do they administer CogScreen-AE Pro (not the older version)? How frequently do they attend FAA Aeromedical Neuropsychology trainings? Experience with the FAA's report format is not cosmetic. The AMCD reads hundreds of these reports. A report that addresses the right questions in the right format moves faster.

One note from aviation attorneys who handle these cases: rapport with your evaluator matters. The FAA's certified neuropsychologist list exists precisely so pilots can choose. Call around before committing. A brief consultation call before scheduling is appropriate and will tell you whether the evaluator's approach and communication style are a fit.

Evidence category 2: The complete scored battery with pilot norms {#evidence-category-2}

When pilots ask what documents to include with their appeal, they often think of narrative reports. Those matter. But the FAA also needs the raw scored output, and specific formatting requirements apply.

The FAA requires: copies of all computer score reports (such as the Pearson MMPI-2 Extended Score Report, TOVA, CPT-II, or IVA+ Report), and an appended score summary sheet that includes all scores for all tests administered.

Two specifics matter here.

First, pilot norms. The FAA requires that when pilot norms are available for a particular test, they must be used. If pilot norms are not available, the normative comparison group must be specified, and percentile scores must be included when available. A report that compares your scores only to the general population rather than to pilot norms is providing the AMCD with a weaker evidentiary foundation, because the FAA's standard for cognitive fitness is operationalized relative to pilot performance, not population average. This is also why CogScreen-AE is so central to these cases: it was specifically developed with pilot normative data.

Second, completeness. The FAA needs scores for every test administered, not just the ones that reflect well. An appended summary sheet with gaps will prompt a follow-up request. Submit everything, labeled clearly.

Evidence category 3: The HIMS AME interpretive letter {#evidence-category-3}

The neuropsychological report tells the FAA what your scores are and what they mean clinically. The HIMS AME interpretive letter tells the FAA what those scores mean for your specific certification case, interpreted by someone who understands both the aeromedical context and your complete medical history.

These are different documents serving different functions. A neuropsychologist who has administered a thorough battery and written a clear report has done their job. But the AMCD still needs to understand how those findings connect to the certification question: is this pilot safe to hold a medical certificate?

The HIMS AME is the bridge. Their letter should address: how your cognitive profile compares to the expectations for your certificate class, whether any deficits identified by testing are clinically significant in the aeromedical context, what the neuropsychologist's conclusions mean for your ability to safely exercise pilot privileges, and their recommendation on certification.

An appeal package that arrives with an evaluation report but no HIMS AME letter forces the AMCD to draw the connection themselves. Giving them the connection, drawn by a professional with HIMS training and familiarity with your case, is almost always faster and more favorable.

This is also why the sequence matters. Do not submit a reconsideration package before your HIMS AME has reviewed the neuropsychological findings. They need to see the complete scored battery, not just the narrative summary, before they can write an interpretive letter that addresses the AMCD's specific concerns.

Evidence category 4: Functional performance evidence {#evidence-category-4}

Test scores tell the FAA how you performed on a standardized cognitive battery. Functional evidence tells them how you perform in actual aviation contexts. Both matter. Cases that rely only on test scores ask the AMCD to make inferences about real-world function. Cases that include functional evidence make those inferences unnecessary.

What counts as functional evidence in a cognitive appeal:

Flight hours during the relevant period. If you have been flying on BasicMed while your First or Second Class application is under review, those hours are documented cognitive performance in actual flight operations. A logbook excerpt covering the appeal period, accompanied by a statement from your flight instructor or check airman about observed performance, is concrete evidence that your cognitive function is not limiting your ability to fly safely.

Chief pilot or supervisor statements. For professional pilots, a written statement from a chief pilot or director of operations who has direct knowledge of your recent performance carries significant weight. The statement should address observable indicators: attention to detail, checklist compliance, situational awareness, communication quality, and how you manage workload. It should be specific and dated. Generic "great pilot" letters are not useful.

Check airman or line check documentation. If you have completed a recurrent training event, line check, or proficiency check during the appeal period, that documentation is relevant. A satisfactory performance on an AQP, ATP-CTP, or type rating checkride while your medical is under appeal tells the FAA something a test score cannot: that your cognitive function was sufficient to pass a regulatory evaluation under real operational conditions.

Professional performance records. For pilots employed by airlines, regional carriers, or corporate flight departments, records of performance evaluations or safety-related metrics covering the appeal period can be included. These are not clinical evidence, but they are real-world functional data.

Not every pilot will have all of these. Use what you have. The goal is to give the AMCD documentation of cognitive function outside the testing room.

Evidence category 5: Remediation documentation {#evidence-category-5}

If your appeal is following a prior denial based on low CogScreen scores, one of the most persuasive elements you can include is documentation of what you did between the initial evaluation and the retesting.

Aviation attorneys who work these cases consistently note that engagement with cognitive rehabilitation and better treatment of the underlying condition which precipitated the testing can help, and that many pilots improve after additional time and targeted intervention passes.

Remediation documentation can take several forms depending on your situation:

Cognitive training records. If you have engaged in structured cognitive training targeting the specific domains where your initial evaluation identified weakness, document it. The training regimen, the provider or platform used, the duration and frequency of sessions, and any pre/post performance data you can demonstrate. The FAA is looking for evidence that you took the deficit seriously and addressed it, not just that time passed.

Medical treatment records. If a treatable condition contributed to your initial poor performance (sleep apnea treatment initiated, medication adjustment, resolution of an acute health issue), documentation of that treatment and your current status belongs in your package. The FAA needs to understand what changed between the evaluation that generated the denial and the evaluation you are now presenting.

Updated treating provider reports. Your treating physician or psychiatrist should provide a current report addressing your status relative to the condition that triggered the cognitive evaluation. The report should be specific: what was the concern, what treatment occurred, what is the current clinical status, and why that status is consistent with safe pilot performance.

If you are submitting updated CogScreen-AE scores as part of your remediation evidence, the FAA will look at all of your test results together. If your scores improve, the FAA will consider that as an improvement. This means retesting scores do not replace your original scores in the FAA's view. They supplement them. What you are demonstrating is a trajectory, not a single data point.

What to do if your original evaluation had problems {#original-evaluation-problems}

Some CogScreen-related denials stem not from genuine cognitive deficits but from evaluation conditions or circumstances that suppressed performance below the pilot's actual capacity: test anxiety, format unfamiliarity with the computer interface, illness on the day of testing, or sleep deprivation.

These situations are legitimately worth documenting and addressing in your appeal. But they require careful handling. The FAA has seen many explanations for poor scores. Explanations that are not supported by objective evidence will be read skeptically.

If test anxiety or format unfamiliarity was a genuine factor, the strongest response is a new evaluation with scores that demonstrate your actual capacity, not an argument about why your original scores should be discounted. Documentation of what changed (structured preparation, familiarization with the testing format, a rested and healthy test day) gives the AMCD something to evaluate rather than a claim to take on faith.

If a medical condition was genuinely affecting your cognitive performance on the day of testing, your treating provider needs to document that condition, its acute nature, its resolution, and why retesting now will produce different results. This is clinical evidence, not an excuse. Frame it that way.

Organizing and submitting the package {#organizing-and-submitting}

A well-documented appeal that arrives as an unorganized pile of papers takes longer than a well-documented appeal that arrives with a cover letter, a table of contents, and labeled exhibits. This sounds obvious. Many pilots still submit disorganized packages and then wait months for follow-up requests that could have been avoided.

Structure your submission:

Cover letter (reconsideration request, your identifying information, FAA file number, date of the denial letter you are responding to)
Table of contents with exhibit labels
Exhibit A: Independent neuropsychological evaluation report
Exhibit B: Complete scored battery with pilot-normed data and appended summary sheet
Exhibit C: HIMS AME interpretive letter
Exhibit D: Functional performance evidence
Exhibit E: Remediation documentation and updated clinical records

Submit via certified mail with return receipt to the AMCD in Oklahoma City, or to the Regional Flight Surgeon if your denial letter identifies one as the handling office. Keep copies of everything.

The AMCD's address:

Federal Air Surgeon Attention: Manager, Aerospace Medical Certification Division, AAM-300 Federal Aviation Administration P.O. Box 25082 Oklahoma City, Oklahoma 73126

For a detailed walkthrough of the reconsideration letter itself, including structure, timing, and the January 2025 process change, see the companion post: How to Write an FAA Medical Reconsideration Letter That Actually Works.

One thing pilots consistently underestimate {#one-thing-pilots-underestimate}

The regulations which relate to cognitive functioning require that the evidence you put in front of the FAA supports that you will not be a risk to aviation safety. This is the standard. Not that you feel capable. Not that your colleagues think you fly fine. That the documented evidence supports the conclusion.

Building that evidence takes time and costs money. A full independent neuropsychological evaluation from a HIMS-qualified provider runs $3,000 to $5,000. Add the HIMS AME coordination, updated treating provider reports, and possibly an aviation attorney for complex cases, and a well-documented appeal is a meaningful investment.

Pilots who cut corners on the documentation to save money tend to extend their appeals by months as follow-up requests arrive. Pilots who build the complete evidentiary package once tend to move faster.

If your initial evaluation involved low CogScreen scores and you have time before retesting, use it. Familiarization with the test format, targeted practice on the specific cognitive domains where your scores were lowest, and arriving rested and prepared all contribute to scores that more accurately reflect your actual cognitive capacity. For a complete picture of what each CogScreen-AE subtest measures and how to approach each one, see the CogScreen-AE Subtests Guide.

The appeal process is not designed to be easy. It is designed to produce reliable evidence about cognitive safety. Treating it that way, and building documentation accordingly, is the approach that works.

References

Dr. Jordan "Coach" Keller is an AI educator employed by PilotPrep LLC, created to help pilots navigate CogScreen-AE preparation and FAA medical certification. This post is educational and does not constitute legal or medical advice. If you have received a denial related to CogScreen-AE performance, consult a qualified aviation attorney and HIMS AME before taking action.

Disclaimer: FAA medical certification requirements are subject to change. Verify current requirements at faa.gov/ame_guide. This content does not create an attorney-client relationship.

Beyond the Letter: Supporting Documentation for a CogScreen FAA Medical Appeal