How to write an FAA medical reconsideration letter that actually works

TL;DR: An FAA medical reconsideration letter is not a complaint. It is a structured evidentiary submission. The pilots who succeed treat it that way: organized exhibits, a chronological narrative, point-by-point responses to FAA concerns, and strong supporting documentation from a HIMS AME. The ones who fail argue, omit records, or miss the deadline.

What you're actually writing
The January 2025 process change you need to know about
Before you write anything: gather these documents
Letter structure: what to include and what to cut
Mistakes that kill reconsideration requests
How to submit
What happens after you submit
When to involve an aviation attorney
If your case involves CogScreen-AE concerns

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

The FAA received your application. Their physicians reviewed it. They decided, based on what they had at that moment, that they could not issue your medical certificate.

A reconsideration letter asks them to look again. That's it.

It is not a formal legal appeal. It is not an argument about whether their decision was fair. Under 14 CFR 67.409, you are asking the Aerospace Medical Certification Division (AMCD) or Regional Flight Surgeon (RFS) to review your file with new or additional information. The framing matters enormously: you are presenting evidence, not making a case for why they were wrong.

The FAA has two types of denials, and understanding the difference determines your options:

Initial denial is issued for conditions not specifically listed as disqualifying under Part 67. This is where reconsideration lives. You typically have 30 days from the denial date to request it. If the denial letter includes a list of additional items the FAA needs, you can submit those at any time while your application remains open, without being bound strictly to that 30-day window.

Final denial is issued for specifically disqualifying conditions under Part 67. Your primary path here is a petition to the NTSB within 60 days. However, and this surprises many pilots: you can still request reconsideration informally even with a final denial, and in practice the FAA often considers it. An aviation attorney can help you navigate this.

If you are unsure which type of denial you received, read the letter carefully. The language will indicate whether reconsideration or NTSB appeal is the stated pathway. When in doubt, contact an aviation attorney before acting.

The January 2025 process change you need to know about {#the-january-2025-process-change}

Starting January 2025, the FAA changed how it handles deferred applications. Previously, when an AME deferred your application to the AMCD for review, you would typically receive an informational request letter (essentially a records request) before any denial was issued.

Now, the FAA sends an initial denial letter first, along with a list of items required for reconsideration. The functional outcome for many applicants is similar: submit the requested records and the FAA will reconsider. But the framing is different. You are no longer responding to an information request. You are formally requesting reconsideration of a denial.

This matters because the documentation you submit is evidence in your file. The FAA's physicians use it to support either a denial or issuance. Every record you submit can cut in your favor or against you, depending on its content and how it is presented. This is why working with a HIMS AME before you submit anything is critical.

Before you write anything: gather these documents {#before-you-write-anything}

Do not write the letter until you have your evidence assembled. A strong reconsideration request is not a persuasive cover letter. It is an organized submission. Here is what you need:

Your FAA medical file

Request a copy of your file from the AMCD before you write anything. You need to know exactly what the FAA already has. Submitting records they already possess wastes time. Submitting records that contradict your narrative creates problems.

The FAA's denial letter

Read it closely. The letter will identify the specific concerns driving the denial. Your response addresses those concerns directly: not tangentially, not generally, but point by point.

Medical records

Gather all records related to the condition at issue. This includes treatment records from your treating physician, psychiatrist, or specialist; hospital records, if any; lab results relevant to the condition; medication history covering name, dose, duration, and stability period; and records showing the condition is well-controlled or resolved.

Note: all submitted reports must be current within the last 90 days for FAA purposes. If your records are older, you may need updated evaluations before submitting.

HIMS AME support letter

For most conditions that trigger a Special Issuance pathway, a letter from a HIMS-trained Aviation Medical Examiner is not optional. It is the spine of your submission. The HIMS AME has reviewed your records, conducted a face-to-face evaluation, and can speak to your current aeromedical status in language the FAA's physicians recognize and weight heavily.

Do not submit a reconsideration request for a HIMS-relevant condition without first having a HIMS AME in your corner. This is the single most common factor separating successful requests from unsuccessful ones.

Treating physician statements

Your treating physician should address the FAA's specific concerns, not provide a generic "patient is doing well" letter. The FAA needs statements about current functional status, prognosis, medication stability, and the absence of aeromedically significant symptoms. A report that does not specifically address what the FAA asked about is effectively useless.

Functional evidence

This category is often underused. If you have been flying on BasicMed, include those flight hours. If you hold a professional position requiring alertness and judgment, include documentation. If you have completed relevant training since the condition was diagnosed, include records. The FAA is evaluating whether you can safely exercise the privileges of a medical certificate. Evidence that you have been doing so, or that people who observe you professionally see no concerns, matters.

Timeline documentation

Build a clear chronology: when the condition was first diagnosed or occurred, when treatment began, key milestones in treatment (medication stable for X months, symptom-free for Y months, evaluation completed on Z date). The FAA's review of your file benefits enormously from a clear, factual timeline that they do not have to construct themselves.

Letter structure: what to include and what to cut {#letter-structure}

Your letter should be professional, organized, and brief in its framing while thorough in its substance. Here is what to include:

Header block

Include your full name, date of birth, airman certificate number, FAA file or control number (from the denial letter), and the date of the denial letter. Reference the denial specifically. This tells the reviewer immediately what case they are looking at.

Opening paragraph

Acknowledge receipt of the denial letter. State that you are requesting reconsideration. Give a single sentence describing your current medical status. This is not the place for your full narrative. Just a clean, professional opening that signals the purpose of the letter.

Chronological narrative

This is the core of your letter. Walk the FAA through what happened, from the beginning, in order. What was the medical event or diagnosis? What happened next? What treatment did you receive? Where are you now?

The narrative should be factual, calm, and chronological. It should not be defensive or argumentative. If your treating physicians disagree with each other, do not pretend they don't. Explain the discrepancy and how it was resolved. The FAA will find inconsistencies in your records regardless. Better to address them directly than to appear to be concealing something.

Point-by-point response to the FAA's concerns

Go back to the denial letter. If the FAA identified specific concerns, address each one explicitly. Quote their language. Respond to it. Attach the evidence that addresses each concern as labeled exhibits.

"The FAA identified concern X. Exhibit A, a letter from my treating physician dated [date], addresses this directly. It states [paraphrase]. Exhibit B, my CogScreen-AE results from [date], are also attached and reviewed in Exhibit A."

This structure makes the reviewer's job easier. It signals that you read the letter, understood the concerns, and are providing responsive evidence. That professionalism matters.

Regulatory compliance section

If your condition falls under a known Special Issuance pathway, state that you have met the requirements. Reference the applicable regulation or FAA guidance. List the evaluations you have completed. The FAA's AMCD physicians want to know: has this applicant done what is required under the applicable authorization pathway?

For cognitively relevant conditions, this may include documentation of CogScreen-AE results and any full neuropsychological battery that was requested. If your case involves cognitive concerns, see the final section of this post.

Closing

Summarize your key points in two or three sentences. State explicitly what you are asking for: reconsideration and issuance of your medical certificate, or Special Issuance if that is the appropriate pathway. Provide your contact information. Say that you are available to provide additional information if needed.

Mistakes that kill reconsideration requests {#mistakes-that-kill-reconsideration-requests}

After watching pilots navigate this process, the failure patterns are consistent.

Being defensive or argumentative. The FAA denied you based on what they had. Telling them they were wrong will not help. Giving them better information might.

Submitting incomplete records. If the FAA has to send another information request, the clock resets and your case drags on for months longer than necessary. Submit everything, organized.

Using a generic letter. A form letter that does not reference the FAA's specific concerns, does not address your specific medical history, and does not attach responsive documentation will be treated accordingly. The FAA's physicians review many files. A submission that makes their job harder gets less benefit of the doubt.

Missing the deadline. The 30-day window for initial denial reconsideration is real. In practice, the FAA often accepts late submissions while your application is still open, but do not rely on this. Get your materials submitted promptly. If you cannot gather everything within 30 days, submit a letter requesting reconsideration by the deadline and note that supporting documentation is being compiled.

Skipping HIMS AME involvement. For any condition that touches the HIMS program (substance use history, psychiatric conditions, SSRI use, neurocognitive concerns), submitting a reconsideration request without HIMS AME input is working against yourself. The AMCD physicians speak the same language as HIMS AMEs. A well-written HIMS AME letter carries weight that a treating physician letter cannot.

Submitting conflicting evidence. If one record says you have been symptom-free for two years and another implies ongoing treatment concerns, the FAA will notice. Review everything you submit before it goes in. If there are inconsistencies, address them in your narrative.

Relying on "I feel fine." Your self-assessment is not medical evidence. The FAA's physicians need documentation from qualified providers using language and formats they recognize. What you experience subjectively is context. What your records document is evidence.

How to submit {#how-to-submit}

For initial denial reconsideration, submit your request in writing to:

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

Send via certified mail with return receipt. Keep everything: the mailing confirmation, the return receipt, copies of every page you submitted.

If your specific RFS office is handling your case, the denial letter will indicate that. Submit to whichever office issued the denial.

Some submissions can be made through MedXPress or via HIMS Huddle depending on your case and AME involvement. Your HIMS AME can advise on the correct submission pathway for your specific situation.

Organize your submission with a cover letter, table of contents, and labeled exhibits. A thick packet with clear organization signals professionalism and gets reviewed efficiently. A thick packet with no organization signals chaos.

What happens after you submit {#what-happens-after-you-submit}

The FAA will acknowledge receipt. Do not expect an immediate response.

Simple cases (a single stable condition with clear supporting documentation and a completed Special Issuance pathway) may resolve in four to eight weeks. Complex cases with multiple conditions, incomplete documentation, or conditions outside established protocols take considerably longer. Three to six months is not unusual for complex situations.

Silence is not denial. The FAA's AMCD handles a significant volume of cases. Follow up professionally after eight weeks if you have heard nothing.

Possible outcomes:

Issuance: your medical certificate is issued, possibly with restrictions or a Special Issuance authorization
Additional information requested: the FAA needs more documentation before they can make a decision
Continued denial: your request for reconsideration was not successful; you may then appeal to the Federal Air Surgeon and potentially the NTSB

If you receive another denial, do not simply resubmit. Understand what the FAA found insufficient, address it, and then resubmit with the missing evidence.

While your case is under review, continue submitting any periodic reports required by your authorization letter. Chief Pilot reports, treating psychiatrist reports, and other time-sensitive documentation should continue on schedule. A gap in required submissions while your reconsideration is pending can complicate your file.

When to involve an aviation attorney {#when-to-involve-an-aviation-attorney}

For straightforward cases with a single condition, completed documentation, and a clear Special Issuance pathway, a well-organized self-submission with strong HIMS AME support often succeeds.

Consider an aviation attorney if:

Your case involves multiple conditions
Your previous reconsideration was denied
The denial involves a specifically disqualifying condition
There are prior FAA actions in your record (violations, enforcement history)
You have conflicting records that require careful presentation
You are considering an NTSB appeal
You are unsure how to characterize your history in a way that is accurate and favorable

Aviation medical attorneys know how the FAA's physicians read these files. They know what language to use, what to include, what to leave out, and how to frame evidence to be maximally responsive to FAA concerns. For complex cases, the investment often pays for itself many times over in time saved and outcomes achieved.

General attorneys, even good ones, are not a substitute. This is a specialized area. Find someone with specific FAA medical certification experience.

If your case involves CogScreen-AE concerns {#if-your-case-involves-cogscreen-ae-concerns}

Some denials or additional information requests are driven by cognitive concerns: either a CogScreen-AE that produced low scores on one or more subtests, or a full neuropsychological evaluation that identified areas of concern.

In these cases, the reconsideration pathway often includes a requirement for updated CogScreen-AE testing and possibly a full neuropsychological evaluation. How you perform on that retesting, and how those results are presented, will significantly affect the outcome of your request.

If you have time before a scheduled CogScreen-AE retest, preparation matters. The research on cognitive training transfer to standardized testing is clear: familiarization with test mechanics, adaptive practice with pilot-normed feedback, and targeted work on areas of weakness improve performance. This is not gaming the test. It is performing at your actual cognitive level rather than below it due to test anxiety, format unfamiliarity, or insufficient practice.

PilotPrep provides adaptive practice modules across all 13 CogScreen-AE subtests with pilot-normed scoring. If your reconsideration involves cognitive testing, arriving at that evaluation prepared (knowing what each subtest measures, how the adaptive difficulty progression works, and where your genuine strengths and weaknesses lie) gives you the best chance of results that accurately reflect your capabilities.

The bottom line

An FAA medical reconsideration letter is not about winning an argument. It is about giving the FAA's physicians enough high-quality, responsive, organized evidence that their second look at your file reaches a different conclusion than their first.

That means understanding what type of denial you received and what options it creates. It means gathering complete, current, organized documentation before you write anything. It means getting HIMS AME involvement for any condition that falls under HIMS protocols. It means writing a structured letter that responds to the FAA's stated concerns point by point. It means submitting on time, via certified mail, with everything labeled and organized. And it means knowing when the situation calls for professional legal help.

The process is administrative, not adversarial. Treat it accordingly.

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 letter from the FAA, consult a qualified aviation attorney before taking action.

Disclaimer: This content is for general informational purposes only. The FAA medical certification process involves complex regulatory and legal considerations. Always consult a qualified aviation attorney and HIMS AME for guidance specific to your case.

How to Write an FAA Medical Reconsideration Letter That Actually Works