Asked to Surrender Your Medical from FAA Fast Track Reversal? Consider your Options.

TL;DR: If the FAA issued your medical and then, months later, sent a letter asking you to voluntarily surrender it and complete a Standard Track evaluation, three things are true and almost nobody tells pilots any of them. First, 14 CFR 67.407 gives the FAA a 60-day window to reverse an AME's issuance. After that the certificate is affirmed, and the FAA's own position is that an affirmed certificate cannot simply be denied. Second, the words "voluntarily surrender" carry consequences very different from letting a certificate lapse, and the guidance on exactly how different is genuinely contested. Third, the most common reason these letters go out has nothing to do with your medication history. It is usually a second psychiatric diagnosis sitting in your record that made Fast Track unavailable from the start. This post explains the mechanics. It is not legal advice, and this is a situation where you should have an aviation attorney.

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The letter nobody prepares you for

Picture a pilot who did everything the long way. He had an ADHD diagnosis as a kid. He has been off stimulant medication for years, well past the FAA's four-year threshold. He found an AME who knew the pathway, wrote the personal statement, tracked down the physician who made the original diagnosis, assembled the Fast Track documentation, and submitted a complete package. In mid-2025 he was issued a first-class medical.

Eleven months later a letter arrives. It says he does not meet the medical standards. It gives him 14 days to voluntarily surrender his medical certificate. It tells him he needs to be off medication to complete Standard Track, medication he has not taken in years. It requests no additional documentation, offers no specific explanation, and the phone number provided routes him in circles.

That is not a hypothetical composed for a blog post. It is the fact pattern in a public forum thread from May 2026, and variations of it come up often enough that I want to write the explanation down in one place.

If you are holding a letter like this, the instinct is to comply immediately. Fourteen days is not much time and the letterhead is intimidating. Slow down. The response you give in those fourteen days can determine whether you fly again under any set of rules, and some of the options that look like cooperation are the ones that close the most doors.

Four different events, four different futures

Most of the confusion in this situation comes from treating four distinct events as if they were the same thing. They are not. They differ in what they do to your ability to fly under BasicMed and Sport Pilot, the fallbacks a pilot losing a medical would otherwise rely on, and in who carries the burden of proof if you fight it.

Event	BasicMed / Sport Pilot after?	Who must prove the case?
Lapse (you let it expire)	Preserved	N/A (no adverse action)
Voluntary surrender	Contested (see below)	N/A
Denial	Blocked	You, to show you qualify
Suspension / revocation	Blocked	The FAA, to show you do not

Two rows deserve their own sections, because they are where pilots lose ground unnecessarily.

The 60-day rule: 14 CFR 67.407

When an AME issues you a medical certificate, that issuance is not instantly final, but the window in which the FAA can undo it is short and specific.

Under 14 CFR 67.407(c), a certificate issued by an aviation medical examiner is considered to be affirmed as issued unless an authorized FAA official reverses that issuance within 60 days of the date of issuance. There is one extension. If, within those 60 days, an authorized official requests that you submit additional medical information, the official may then reverse the issuance within 60 days after receiving what was requested.

That is the entire window. Sixty days, or sixty days from the receipt of information they asked for inside the first sixty.

AOPA put precisely this scenario to the FAA (a pilot receiving a denial letter months after an AME's issuance should have been affirmed) and reported the agency's response: "a medical certificate cannot be denied after the medical certificate is affirmed," and "the FAA uses enforcement action to revoke or suspend a medical certificate that is issued by the FAA."

Why this matters so much: it changes who has to prove what. Both a denial appeal and an enforcement action are heard by an NTSB administrative law judge, but under the Board's rules the burden runs in opposite directions. Appealing a denial, the pilot carries the burden of showing he or she qualifies for the certificate. In an enforcement action to suspend or revoke, the FAA carries the burden of showing the pilot is not qualified.

That is not a technicality. It is the difference between proving a negative about your own cognition and making the government prove its case.

An important honest caveat: none of this means an FAA letter can be ignored, and it does not mean a reversal is always improper. 14 CFR 67.409(c) provides that an action under 67.407(c) reversing an AME's issuance is a denial of a medical certificate, and 67.409(d) provides that where issuance is reversed by the Federal Air Surgeon, the Manager of the Aeromedical Certification Division, or a Regional Flight Surgeon, the holder shall surrender the certificate upon FAA request. The FAA also holds separate authority under 49 U.S.C. 44709 to re-examine an airman.

So the question is never "can I disregard this?" The question is which process is actually being used, whether the timeline supports it, and what that means for your response. That is a question for an aviation attorney, holding your letter and your issuance date.

Why "voluntarily surrender" is the phrase to stop at

Here is the part that troubles me most about these letters. They instruct the pilot to voluntarily surrender the certificate, and voluntary surrender is not the neutral, cooperative act it sounds like.

EAA has warned pilots directly that the FAA "generally treats a voluntary surrender of a medical certificate as a revocation." That would make a pilot ineligible to fly under BasicMed and under the sport pilot rules. EAA's advice in that advisory is blunt and worth repeating: pilots are always free to simply let a medical lapse, which preserves eligibility, and the decision to surrender should never be made without consulting an aviation attorney.

The picture is genuinely contested, and I am not going to pretend otherwise. Aviation law commentary has taken the position that surrender is preferable to suspension or revocation, precisely because the BasicMed and sport pilot rules are written around applications denied and certificates suspended or revoked, categories a surrender arguably does not fall into. I have seen the argument made carefully by attorneys, and it is not frivolous.

What I can tell you is that these two positions point in different directions on the single most consequential decision in front of you, and that alone is reason enough not to sign anything in the first week.

There is a further wrinkle that cuts against surrendering in this specific scenario. Under FAA Order 2150.3C, the Compliance and Enforcement Program order, the FAA will refuse a surrender where it appears the certificate is being surrendered to avoid certificate action. AOPA has reported the FAA's position that an airman may not surrender a medical certificate where the FAA has determined the airman does not meet Part 67 requirements after the period in which the FAA could issue a denial.

Read that against the letter. The letter says the pilot does not meet the standards, and asks for a surrender. If the FAA has made that determination outside the denial window, its own policy may not permit it to accept the surrender it is requesting. Whether that is what is happening in any individual case is exactly the sort of thing counsel needs to untangle.

The practical takeaway: letting a medical lapse and voluntarily surrendering it are not synonyms, the difference is measured in years of flying privileges, and this is the decision to spend money on an attorney for.

Why these letters go out at all

Setting aside procedure, there is usually a substantive reason, and it is often not the one the pilot expects.

Fast Track is narrow by design. The FAA's own Fast Track general information for pilots is explicit. If you have taken ADHD medication in the past four years, had symptoms in the past four years, or have a history of any other psychiatric condition, stop and go to Standard Track.

That third condition is the one that catches people. A pilot can be scrupulously honest, genuinely years past any medication, and still be ineligible for Fast Track because a second diagnosis sits somewhere in the record. In the forum case, the letter referenced ADHD and unspecified anxiety. If a second psychiatric diagnosis is documented anywhere in the reviewed records, Fast Track eligibility can evaporate no matter how clean the medication history is, and the pilot may have had no idea the disqualifier was even in play.

The second mechanism is documentation. An experienced HIMS AME made the point in that thread: the AME's obligation is to substantiate every item that makes the airman eligible for Fast Track, and submit it. If the record does not affirmatively establish each element, including the absence of recurrence, the agency can reject the package later, when a reviewer reads the file more closely than the initial issuance did.

Both mechanisms produce the same experience for the pilot: an issuance that felt final, and a reversal that feels arbitrary. It generally is not arbitrary. It is a records problem, and records problems are addressable, which is why your first substantive move is to find out what is actually in your file.

What Standard Track actually asks of you

If the outcome is that you complete Standard Track, it is worth knowing what that means, because the anxiety about the unknown is usually worse than the thing itself.

Standard Track requires a full neuropsychological evaluation by an FAA-recognized psychologist or neuropsychologist. That evaluation typically includes a records review, a clinical interview, a standard neuropsychological battery, and computerized testing: the CogScreen-AE. The CogScreen portion runs roughly 60 to 75 minutes inside an evaluation that often runs four to eight hours in total.

The CogScreen-AE is 13 computerized subtests scored against pilot norms rather than general population norms. Most pilots have never seen anything like it. The tasks are unusual, the instructions come fast, and the difficulty adapts to your performance, which means a correct answer is frequently followed by something harder. Pilots who have not seen that pattern before often read it as failure in real time, and test anxiety does measurable damage to scores that have nothing to do with cognitive ability.

You cannot practice the actual CogScreen-AE items; they are proprietary and administration-controlled. Familiarization with the task formats is a different thing, and it is both permitted and sensible. The goal is not to inflate a score. It is to make sure the score reflects your cognition rather than your surprise.

What to do next

In order. The first three matter most.

1. Do not sign or return anything yet. A 14-day deadline is real, and it is also short enough that a rushed answer is the main risk. Acknowledging the letter and stating that you are obtaining counsel is not non-compliance.
2. Get an aviation attorney. Not a general practitioner. AOPA Legal Services and EAA's Legal Advisory Council are both starting points for members. Bring the letter and your exact date of issuance. Under 67.407 that date is the hinge the whole procedural question turns on.
3. Request your complete FAA medical file. Submit FAA Form 8065-2 to the Aerospace Medical Certification Division. You cannot evaluate a records-based reversal without seeing the records. This routinely takes the longest of any step, so start it the same week. We walk through the request in our guide to deferrals and records requests.
4. Establish the timeline in writing. Date of AME issuance. Date of any FAA request for additional information. Date you supplied it. Date of the letter. That sequence is what determines whether 67.407's window was ever open.
5. Loop in your AME. A good AME will call the FAA and find out what actually drove the letter. That answer, whether a second diagnosis, an unsubstantiated eligibility item, or something else, determines everything downstream.
6. Do not fly on a certificate whose status is in question. 14 CFR 61.53 is independent of all of this.
7. If Standard Track is the outcome, start preparing early. Between assembling records and scheduling with an FAA-recognized neuropsychologist, you will likely have weeks. Use them.

Where to read more

Within the FAA ADHD pathway, the two posts that explain the eligibility rules being applied to you are the ADHD disposition table, explained line by line and Standard Track vs Fast Track: which one applies to you. If you are budgeting for a Standard Track evaluation, what a CogScreen-AE evaluation costs in 2026 has current figures.

If your letter has moved you into appeals territory, how to write an FAA medical reconsideration letter and the CogScreen denial appeal, step by step cover what comes next.

Primary sources, because you should check my work and because your attorney will want them:

• 14 CFR 67.407: Delegation of authority (the 60-day affirmation rule)
• 14 CFR 67.409: Denial of medical certificate
• FAA Order 2150.3C: Compliance and Enforcement Program
• FAA Guide for Aviation Medical Examiners: ADHD disposition table and Fast Track general information
• AOPA, "For the record: They get you coming and going"
• EAA, "Pilots: Do Not Voluntarily Surrender Your Medical"

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One more time, because it matters: I am an aviation neuropsychology educator, not an attorney, and nothing here is legal advice or a prediction about your case. What I can tell you with confidence is that the date on your issuance letter is more important than most pilots realize, that "voluntarily surrender" is not a neutral phrase, and that fourteen days is enough time to make a phone call before you make a decision you cannot reverse.

If Standard Track is where this lands, the cognitive testing is the part you can actually prepare for. See how CogScreen-AE familiarization works. The goal is a score that reflects you, not your first encounter with an unfamiliar test.