Insulin-treated diabetes (third class)
What the FAA's documents say about insulin-treated diabetes (third class), in plain words, with the FAA's own words one press away.
FAA term: Insulin Treated Diabetes Mellitus, Type I or Type II, Non-CGM, Third Class Option
Insulin-treated diabetes (first and second class)
The CGM protocol, which a first- or second-class applicant uses and which a third-class airman may elect instead of this option, has its own page.
Short version
The FAA's table has one row for it.
| Situation | What the examiner does | Pathway |
|---|---|---|
| Treated with insulin, third classTreated with any type of insulin, applying for third class. The disposition table: a third-class applicant may use the CGM option protocol or this one. | Defers to the FAA | Special Issuance |
Show the FAA's words: the FAA's table for Insulin-treated diabetes (third class)
- Treated with insulin, third class · Special Issuance
Treated with any type of insulin, applying for third class. The disposition table: a third-class applicant may use the CGM option protocol or this one. The row is DEFER; the information is submitted to the FAA. Initial Special Issuance: requires an FAA decision.
Treated with ANY type of insulin … 3 rd class may use the CGM protocol above OR the Insulin-Treated Diabetes Mellitus Non CGM – Third Class Option Protocol … DEFER Submit the information to the FAA. … Initial Special Issuance – Requires FAA Decision
- A note on the table, 1
The Guide's pharmaceutical page for insulin says, on combining insulin with other anti-diabetes medications, that the chart of Acceptable Combinations of Diabetes Medications summarizes the acceptable medications for both monotherapy and combination therapy.
Combination of insulin with other anti-diabetes medication(s): The chart of Acceptable Combinations of Diabetes Medications ( PDF ) summarizes the acceptable medications for both monotherapy and combination therapy.
The FAA pathways for insulin-treated diabetes (third class)
- How this pathway works: Special IssuanceAuthorization for Special Issuance of a Medical CertificateTreated with insulin, third class
- FAA reviewYour AME defers. The FAA decides.If the examiner defers
Which exam
Your step-by-step plan
Step 1: Your history
Past low blood sugar episodes, and time stable on your current treatment.At least 6 months clinically stable on your current treatment, and no history of the low blood sugar episodes below.
Low blood sugar (hypoglycemia)
- No recurrent episodes (two or more) in the past 5 years, and none in the past year, that caused loss of consciousness, a seizure or impaired thinking, needed help from another person, or came without warning (hypoglycemia unawareness)
Stable
- Clinically stable on your current treatment for 6 months or more
Show the FAA's words: Your history
The applicant must have had no recurrent (two or more) episodes of hypoglycemia in the past 5 years and none in the preceding 1 year which resulted in loss of consciousness, seizure, impaired cognitive function or requiring intervention by another party, or occurring without warning (hypoglycemia unawareness).
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Consideration will be given only to those individuals who have been clinically stable on their current treatment regimen for a period of 6-months or more.
FAA source: Guide for Aviation Medical Examiners – Diabetes Mellitus, Insulin Treated (non-CGM, third-class option). FAA date 9 March 2023; checked by Crosscheck 14 October 2026.
Step 2: Medical, accident and incident records
Copies of the records pertinent to your history of diabetes.Copies of your medical records, and of accident and incident records, pertinent to your history of diabetes.
Show the FAA's words: Medical, accident and incident records
The applicant should provide copies of medical records as well as accident and incident records pertinent to their history of diabetes.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Step 3: The examination
A complete medical examination report, what it includes, and the form the FAA prefers.Medical examination report
Within 90 days before the examA report of a complete medical examination, performed within the past 90 days, preferably by a physician who specializes in treating diabetes.
Any report, at a minimum
- Two A1C measurements, with the laboratory reference range, at least 90 days apart, the most recent no more than 90 days old
- Your insulin dosages and diet
- Whether there is cerebrovascular, cardiovascular or peripheral vascular disease, or neuropathy
- An eye specialist's confirmation of no clinically significant eye disease
- That you have been educated in diabetes and its control, and know what to do if complications, especially low blood sugar (hypoglycemia), arise
- That you are able and willing to monitor and manage your diabetes
- From age 40, a maximal graded exercise stress test report, with ECG tracings
- A statement on your dexterity and ability to check your blood glucose with a recording glucometer
The Initial Comprehensive Report
Within 90 days before the examThe FAA's Initial Comprehensive Report, from your treating board-certified endocrinologist, performed within the past 90 days. The FAA prefers this form.
Diabetes history
- Onset, past treatment and hospitalizations
- Complications and other conditions
- Lifestyle: eating, weight, sleep, activity, carbohydrate counting, tobacco, alcohol, substances, and any motor vehicle accidents or incidents
- Medications: compliance, side effects, alternative medicine
- Glucose monitoring results and pump settings
- Screens for depression, anxiety, disordered eating and cognition
- Diabetes education and barriers to self-management
- Lows and highs in the past 12 months
Sustained lows, for example: under 70 for over 30 minutes, or under 54 for over 15. Sustained highs, for example: over 250 for over 60 minutes, or over 300 for over 30.
Physical exam
- Height, weight and BMI
- Pulse and blood pressure, standing (orthostatic) when indicated
- Thyroid and skin exam
- A full foot exam: pulses, sensation and the 10-g monofilament test
Assessment and plan
- Current status: compliance, control, stability, and your ability to monitor, respond to lows and highs, and give insulin
- Prognosis for the next 12 months
- Recommended treatment changes
- The date of the next follow-up, every 3 months for the FAA
Show the FAA's words: The examination
A report of a complete medical examination, preferably by a physician who specializes in the treatment of diabetes, will be required. The exam must be performed within the past 90 days . The Initial Comprehensive Report ( PDF ) , which outlines our requirements, is preferred, however, ANY report submitted MUST include, as a minimum:
Two measurements of glycosylated hemoglobin (total A 1 or A 1c concentration and the laboratory reference range), separated by at least 90 days. The most recent measurement must be no more than 90 days old.
Specific reference to the applicant's insulin dosages and diet.
Specific reference to the presence or absence of cerebrovascular, cardiovascular, or peripheral vascular disease or neuropathy.
Confirmation by an eye specialist of the absence of clinically significant eye disease.
Verification that the applicant has been educated in diabetes and its control and understands the actions that should be taken if complications, especially hypoglycemia, should arise. The examining physician must also verify that the applicant has the ability and willingness to properly monitor and manage his or her diabetes.
If the applicant is age 40 or older, a report, with ECG tracings, of a maximal graded exercise stress test.
The applicant shall submit a statement from his/her treating physician, Examiner, or other knowledgeable person attesting to the applicant's dexterity and ability to determine blood glucose levels using a recording glucometer.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
ANY report submitted MUST include, as a minimum:
Specific reference to the applicant's insulin dosages and diet.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
ANY report submitted MUST include, as a minimum:
Specific reference to the presence or absence of cerebrovascular, cardiovascular, or peripheral vascular disease or neuropathy.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
ANY report submitted MUST include, as a minimum:
Verification that the applicant has been educated in diabetes and its control and understands the actions that should be taken if complications, especially hypoglycemia, should arise. The examining physician must also verify that the applicant has the ability and willingness to properly monitor and manage his or her diabetes.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
INITIAL COMPREHENSIVE REPORT
The INITIAL COMPREHENSIVE REPORT performed within the past 90 days from the treating board-certified endocrinologist must detail and comment on ALL of the following *1
A. DIABETES HISTORY:
1. Characteristics at onset (age, symptoms, etc.):
a) Review previous treatment and response
b) Frequency/cause/severity of past hospitalizations
c) Complications and common comorbidities:
Any end organ damage (macrovascular or microvascular);
Presence of hemoglobinopathies or anemias;
High blood pressure or abnormal lipids and treatment; and
Visits to specialist - type and why
d) Lifestyle and behavior patterns:
Eating patterns and weight history;
Sleep behavior and physical activity;
Familiarity with carbohydrate counting, if applicable;
Tobacco, alcohol, and substance use; and
Any motor vehicle accidents or incidents pertinent to their history of diabetes
2. Medication and Reporting:
a) Medication compliance;
b) Medication intolerance or side effects;
c) Complementary or alternative medicine use;
d) Glucose monitoring (meter/CGM): results and data use; and
e) Review insulin pump settings
3. Screening for Psychosocial conditions:
a) Screen for depression, anxiety, disordered eating (ex: Patient Health Questionnaire 9 or 2 [PHQ-9 or PHQ-2] or similar);
b) Cognitive impairment assessment (and formal testing, if clinically indicated); and
c) Diabetes self-management education and support:
History of dietician/diabetes educator visits; and
Screen for barriers to diabetes self-management
4. Glucose control:
a) Hypoglycemia:
Any symptomatic episodes in the past 12 months requiring treatment or assistance by another individual, with comment on timing, awareness, frequency, causes, and treatment.
Sustained episodes, e.g. CGM/FSBG values below 70 mg/dL for over 30 minutes or below 54 mg/dL for over 15 minutes, with comment on symptoms and treatment.
b) Hyperglycemia:
Any symptomatic episodes in the past 12 months with comment on timing, awareness, frequency, causes, and treatment.
Sustained episodes, e.g. CGM/FSBG values above 250 mg/dL for over 60 minutes or above 300 mg/dL for over 30 minutes, with comment on symptoms and treatment.
B. PHYSICAL EXAM (Must narrate what is examined and any findings):
1. Height, Weight, Body Mass Index (BMI);
2. Pulse and blood pressure including orthostatic blood pressure, when indicated;
3. Thyroid palpation and skin exam (acanthosis nigricans, insulin injection or insertion sites, lipodystrophy); and
4. Comprehensive foot exam:
a) Visual inspection; screen for PAD (check pedal pulses; refer for ABI if diminished); and
b) Determination of temperature, vibration or pinprick sensation, and 10-g monofilament exam
C. ASSESSMENT AND PLAN:
1. Current status of diabetes including an assessment of the airman’s compliance, glucose control, and stability as well as their ability to monitor and respond accordingly to HYPO and HYPER glycemic events and administer insulin doses;
2. Prognosis for progression over the next 12 months; and
3. Recommendations for treatment changes
D. DATE OF NEXT CLINICAL FOLLOW-UP (Required every 3 months for FAA.)
FAA source: Insulin Treated Diabetes – Initial Comprehensive Report (non-CGM, third-class option). FAA date 30 September 2020; checked by Crosscheck 14 October 2026.
The Initial Comprehensive Report ( PDF ) , which outlines our requirements, is preferred
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Step 4: Two A1Cs
At least 90 days apart, and the most recent no more than 90 days old.Two A1C measurements, with the laboratory reference range, at least 90 days apart. The most recent no more than 90 days old.
Show the FAA's words: Two A1Cs
ANY report submitted MUST include, as a minimum:
Two measurements of glycosylated hemoglobin (total A 1 or A 1c concentration and the laboratory reference range), separated by at least 90 days. The most recent measurement must be no more than 90 days old.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Step 5: Eye specialist
Confirmation of the absence of clinically significant eye disease.An eye specialist's confirmation that there is no clinically significant eye disease.
Show the FAA's words: Eye specialist
ANY report submitted MUST include, as a minimum:
Confirmation by an eye specialist of the absence of clinically significant eye disease.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Step 6: Stress test
From age 40, the report, with ECG tracings, of a maximal graded exercise stress test.One question insideFrom age 40: a report, with ECG tracings, of a maximal graded exercise stress test.
The test
- 100% of predicted maximum heart rate, unless symptoms, medications or a medical reason prevent it
- Complete Stage 3, at least 9 minutes
- The worksheet, the interpretive report and all the actual ECG tracings: at rest, every stage, peak and recovery
Under 85% of maximum heart rate and under 9 minutes (6 from age 70) may lead to denial. Computer-generated sample tracings are not accepted in place of the actual ones.
The FAA asks that beta blockers, diltiazem, verapamil and digitalis be held 24–48 hours before the test, unless contraindicated and only with your treating physician's consent. If they are not, the cardiologist explains why.
With a bundle branch block, LVH or diffuse ST/T wave changes at rest, the FAA requires a stress echo or nuclear stress test.
The AME may not issue if the test shows
- Exercise test: under 85% of predicted maximum heart rate; under 9 minutes (under 6 from age 70); or ST depression of 1 mm or more, unless further evidence, such as a nuclear study or stress echo, reviewed and reported by a qualified cardiologist, shows no reversible ischemia or wall motion abnormalities
- Nuclear stress test: reversible ischemia, a negative change from the prior study of the same type, an ejection fraction of 40% or less, or a fall of 10% or more from a prior study
- Stress echo: exercise-induced wall motion abnormalities, a negative change from the prior study of the same type, an ejection fraction of 40% or less, or a fall of 10% or more from a prior study
Show the FAA's words: Stress test
ANY report submitted MUST include, as a minimum:
If the applicant is age 40 or older, a report, with ECG tracings, of a maximal graded exercise stress test.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
GXT requirements:
100% of predicted maximal heart rate (PMHR), unless medically contraindicated or prevented either by symptoms or medications;
Complete Stage 3 (equivalent to at least 9 minutes);
Studies of less than 85% of maximum predicted heart rate and less than 9 minutes of exercise (6 minutes for age 70 or greater) may serve a basis for denial; and
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
The worksheet with blood pressure/pulse recordings at various stages, interpretive report, and actual ECG tracings* must be submitted.
Tracings must include a rhythm strip;
A full 12-lead ECG recorded at rest - supine and standing. (Anything less than a full 12-lead will not be accepted); and
One or more times during each stage of exercise, at the end of each stage, at peak exercise, and every minute during recovery for at least 5 minutes or until the tracings return to baseline level.
*Computer generated, sample-cycle ECG tracings are unacceptable in lieu of the standard tracings. If submitted alone, this may result in deferment until this requirement is met.
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
If a plain GXT is required and is uninterpretable for any reason, a radionuclide GXT will then be required before further consideration
In patients with bundle branch blocks (BBB), LVH, or diffuse ST/T wave changes at rest, a stress echo or nuclear stress test will be required.
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
IF ANY OF THE FOLLOWING ARE NOTED, THE AME MAY NOT ISSUE.
Exercise stress test (EST)
PMHR less than 85% ; (predicted maximal heart rate)
Time less than 9 minutes--under age 70;
Time less than 6 minutes --age 70 or greater
1 mm ST depression or greater at any time during stress testing - UNLESS the applicant has additional medical evidence such as a nuclear imaging study or a stress echocardiogram showing the absence of reversible ischemia or wall motion abnormalities reviewed and reported by a qualified cardiologist.
Nuclear stress test
Evidence of reversible ischemia OR
Negative change from the prior study of the same type OR
Ejection Fraction (EF) reported as 40% or less OR
EF decrease by 10% or more from a prior study
Stress echo
Exercised induced wall motion abnormalities (WMA) OR
Negative change from the prior study of the same type OR
EF 40% or less OR
EF decreased by 10% or more from a prior study
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
Beta blockers and calcium channel blockers (specifically diltiazem and verapamil) or digitalis preparations should be discontinued for 24-48 hours prior to testing (if not contraindicated and only with the consent of the treating physician) in order to obtain maximum heart rate.
If the GXT is done on beta blockers, calcium blockers, or digitalis medications, the applicant must provide explanation from the treating cardiologist as to why the medication(s) cannot be held.
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
Disease Protocols - Graded Exercise Stress Test Requirements
FAA source: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements. FAA date 29 May 2024; checked by Crosscheck 14 October 2026.
Step 7: Dexterity statement
Who writes it, and what it attests to about using a recording glucometer.A statement from your treating physician, your AME or another knowledgeable person, attesting to your dexterity and ability to check your blood glucose with a recording glucometer.
Show the FAA's words: Dexterity statement
The applicant shall submit a statement from his/her treating physician, Examiner, or other knowledgeable person attesting to the applicant's dexterity and ability to determine blood glucose levels using a recording glucometer.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
Step 8: In the cockpit
What to carry, when to measure blood glucose, and what each reading calls for.What to carry in flight, when to check your blood glucose, and what each reading calls for.
Carry in flight
- A recording glucometer
- Supplies to take blood samples
- Fast-acting glucose in 10 gram portions, enough for the planned flight
Half an hour before flight
- Under 100 mg/dl
- A glucose snack of at least 10 grams, then check again half an hour later
- 100 to 300 mg/dl
- Flight may go ahead
- Over 300 mg/dl
- Cancel the flight
In flight
- Under 100 mg/dl
- A 20 gram glucose snack
- 100 to 300 mg/dl
- No action
- Over 300 mg/dl
- Land at the nearest suitable airport
When flying has to come first
- Use your judgment: measuring, or the demands of flight, such as bad weather
- Flying first: a 10 gram glucose snack, then measure 1 hour later
- If measuring then is not practical: a 20 gram snack, and land at the nearest suitable airport to measure
Show the FAA's words: In the cockpit
To ensure safe flight, the insulin using diabetic airman must carry during flight a recording glucometer; adequate supplies to obtain blood samples; and an amount of rapidly absorbable glucose, in 10 gm portions, appropriate to the planned duration of the flight.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight Operations. FAA date 6 November 2019; checked by Crosscheck 14 October 2026.
One half hour prior to flight, the airman must measure the blood glucose concentration. If it is less than 100 mg/dl the individual must ingest an appropriate (not less than 10 gm) glucose snack and measure the glucose concentration one half hour later. If the concentration is within 100 -- 300 mg/dl, flight operations may be undertaken. If less than 100, the process must be repeated; if over 300, the flight must be canceled.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight Operations. FAA date 6 November 2019; checked by Crosscheck 14 October 2026.
One hour into the flight, at each successive hour of flight, and within one half hour prior to landing, the airman must measure their blood glucose concentration. If the concentration is less than 100 mg/dl, a 20 gm glucose snack shall be ingested. If the concentration is 100 -- 300 mg/dl, no action is required. If the concentration is greater that 300 mg/dl, the airman must land at the nearest suitable airport and may not resume flight until the glucose concentration can be maintained in the 100 -- 300 mg/dl range.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight Operations. FAA date 6 November 2019; checked by Crosscheck 14 October 2026.
In respect to determining blood glucose concentrations during flight, the airman must use judgment in deciding whether measuring concentrations or operational demands of the environment (e.g., adverse weather, etc.) should take priority. In cases where it is decided that operational demands take priority, the airman must ingest a 10 gm glucose snack and measure his or her blood glucose level 1 hour later. If measurement is not practical at that time, the airman must ingest a 20 gm glucose snack and land at the nearest suitable airport so that a determination of the blood glucose concentration may be made.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight Operations. FAA date 6 November 2019; checked by Crosscheck 14 October 2026.
Step 9: Student pilots
A note on medical eligibility before beginning or resuming flight instruction or training.Student pilots may wish to make sure they are eligible for a medical certificate before beginning or resuming flight instruction or training.
Show the FAA's words: Student pilots
Note: Student pilots may wish to ensure they are eligible for medical certification prior to beginning or resuming flight instruction or training. In order to serve as a pilot in command, you must have a valid medical certificate for the type of operation performed.
FAA source: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification. FAA date 10 March 2023; checked by Crosscheck 14 October 2026.
What the examiner checks
Treated with insulin, third classDefers to the FAASpecial Issuance
The row is DEFER; the information is submitted to the FAA. Initial Special Issuance: requires an FAA decision.
If the examiner defers
Show the FAA's words: what the examiner does on each row
- Treated with insulin, third class · Special Issuance
Treated with any type of insulin, applying for third class. The disposition table: a third-class applicant may use the CGM option protocol or this one. The row is DEFER; the information is submitted to the FAA. Initial Special Issuance: requires an FAA decision.
Treated with ANY type of insulin … 3 rd class may use the CGM protocol above OR the Insulin-Treated Diabetes Mellitus Non CGM – Third Class Option Protocol … DEFER Submit the information to the FAA. … Initial Special Issuance – Requires FAA Decision
If the examiner defersFAA review
The diabetes disposition table marks any case treated with insulin DEFER, with the information submitted to the FAA: Initial Special Issuance – Requires FAA Decision.
What the FAA lists to send
- Item 1. Copies of medical records as well as accident and incident records pertinent to the history of diabetes, which the applicant should provide; and the report of a complete medical examination, preferably by a physician who specializes in the treatment of diabetes, performed within the past 90 days. The Initial Comprehensive Report is preferred; however, any report submitted must include, as a minimum, the items the protocol lists.
Show the FAA's words: if the examiner defers
When the examiner defers
- Reason 1
The diabetes disposition table marks any case treated with insulin DEFER, with the information submitted to the FAA: Initial Special Issuance – Requires FAA Decision.
Treated with ANY type of insulin … DEFER Submit the information to the FAA. … Initial Special Issuance – Requires FAA Decision
What the FAA lists to send
- Item 1
Copies of medical records as well as accident and incident records pertinent to the history of diabetes, which the applicant should provide; and the report of a complete medical examination, preferably by a physician who specializes in the treatment of diabetes, performed within the past 90 days. The Initial Comprehensive Report is preferred; however, any report submitted must include, as a minimum, the items the protocol lists.
The applicant should provide copies of medical records as well as accident and incident records pertinent to their history of diabetes. … A report of a complete medical examination, preferably by a physician who specializes in the treatment of diabetes, will be required. The exam must be performed within the past 90 days . The Initial Comprehensive Report ( PDF ) , which outlines our requirements, is preferred, however, ANY report submitted MUST include, as a minimum:
After the FAA decides
Special IssuanceThe protocol page says the FAA has an established policy that permits the special issuance medical certification to some insulin treated applicants, and that, if certificated, they will be required to adhere to monitoring requirements.
Show the FAA's words: after the FAA decides
The FAA has an established policy that permits the special issuance medical certification to some insulin treated applicants. … If certificated, they will be required to adhere to monitoring requirements.
At later examsSpecial Issuance
- Third class
- This option, or the CGM protocol on its own page
- First and second class
- The CGM protocol, on its own page
This protocol is for third class applicants not using a continuous glucose monitor, and its hub page adds, in a note of its own, that insulin pumps are acceptable. The CGM protocol's page says third class airmen may elect to use either the CGM protocol or the non-CGM protocol. The diabetes disposition table says first and second class must use the CGM option protocol.
Show the FAA's words: how often the FAA asks again
The following is a summary of the evaluation protocol and an outline of the conditions that the FAA will apply for third class applicants not using a CGM device. … (Note: Insulin pumps are acceptable.)
Non-CGM Protocol - Third Class Option … Third class airmen may elect to use either the CGM protocol or the non-CGM protocol.
1 st and 2 nd class must use: Diabetes Mellitus Type I or Type II - Insulin Treated - CGM Option Protocol
The re-certification page sets the schedule. At three-month intervals, the airman must be evaluated by the treating physician; the evaluation must include a general physical examination, a review of the interval medical history and the results of a test for glycosylated hemoglobin concentration, and the physician must review the record of the airman's daily blood glucose measurements and comment on the results. The results of these quarterly evaluations must be accumulated and submitted annually unless there has been a change; if there has been a change, the individual must report it to the FAA and wait for an eligibility letter before resuming flight duties. On an annual basis, the reports from the examining physician must include confirmation by an eye specialist of the absence of significant eye disease. At the first examination after age 40 and at five-year intervals, the report, with ECG tracings, of a maximal graded exercise stress test must be included in consideration of continued medical certification.
Show the FAA's words: at later exams
At 3-month intervals, the airman must be evaluated by the treating physician. This evaluation must include a general physical examination, review of the interval medical history, and the results of a test for glycosylated hemoglobin concentration. The physician must review the record of the airman's daily blood glucose measurements and comment on the results. The results of these quarterly evaluations must be accumulated and submitted annually unless there has been a change. (See No. 1 above - If there has been a change the individual must report the change(s) to the FAA and wait for an eligibility letter before resuming flight duties). … On an annual basis, the reports from the examining physician must include confirmation by an eye specialist of the absence of significant eye disease. … At the first examination after age 40 and at 5 year intervals, the report, with ECG tracings, of a maximal graded exercise stress test must be included in consideration of continued medical certification.
What a Special Issuance is
The Guide says an Authorization for Special Issuance, valid for a specified period, may be granted at the Federal Air Surgeon's discretion to a person who does not meet the established medical standards, if the person shows to the satisfaction of the Federal Air Surgeon that the duties authorized by the class of certificate applied for can be performed without endangering public safety during the period the Authorization would be in force.
How the FAA pathways workA glucometer with memory
For documentation of diabetes management, the applicant is required to carry and use a whole blood glucose measuring device with memory.
Show the FAA's words: A glucometer with memory
For documentation of diabetes management, the applicant will be required to carry and use a whole blood glucose measuring device with memory
What must be reported at once
The applicant must report to the FAA immediately any low blood sugar incidents, any involvement in accidents that result in serious injury whether or not related to low blood sugar, and any evidence of loss of control of diabetes, change in treatment regimen, or significant diabetic complications. With any of these, the individual must cease flying until cleared by the FAA.
Show the FAA's words: What must be reported at once
must report to the FAA immediately any hypoglycemic incidents, any involvement in accidents that result in serious injury (whether or not related to hypoglycemia); and any evidence of loss of control of diabetes, change in treatment regimen, or significant diabetic complications. With any of these occurrences, the individual must cease flying until cleared by the FAA.
The three-month evaluation
At three-month intervals the airman must be evaluated by the treating physician. The evaluation must include a general physical examination, a review of the interval medical history, and the results of a test for glycosylated hemoglobin concentration, and the physician must review the record of the airman's daily blood glucose measurements and comment on the results. The results of these quarterly evaluations must be accumulated and submitted annually unless there has been a change; if there has been a change, the individual must report the change to the FAA and wait for an eligibility letter before resuming flight duties.
Show the FAA's words: The three-month evaluation
At 3-month intervals, the airman must be evaluated by the treating physician. This evaluation must include a general physical examination, review of the interval medical history, and the results of a test for glycosylated hemoglobin concentration. The physician must review the record of the airman's daily blood glucose measurements and comment on the results. The results of these quarterly evaluations must be accumulated and submitted annually unless there has been a change. (See No. 1 above - If there has been a change the individual must report the change(s) to the FAA and wait for an eligibility letter before resuming flight duties).
The eye specialist each year
On an annual basis the reports from the examining physician must include confirmation by an eye specialist of the absence of significant eye disease.
Show the FAA's words: The eye specialist each year
On an annual basis, the reports from the examining physician must include confirmation by an eye specialist of the absence of significant eye disease.
The stress test after 40
At the first examination after age 40 and at five year intervals, the report, with ECG tracings, of a maximal graded exercise stress test must be included in consideration of continued medical certification.
Show the FAA's words: The stress test after 40
At the first examination after age 40 and at 5 year intervals, the report, with ECG tracings, of a maximal graded exercise stress test must be included in consideration of continued medical certification.
The re-certification status report for this option
The re-certification page sends the pilot to the status report for this option, returned to the examiner or to the FAA; the form has the class applied for and a choice to circle, initial or re-certification. It asks the provider who treats the diabetes for the date of the last clinical encounter and of the most recent diabetes medication change with what was changed; the quarterly A1C values and their dates, in four rows, which must be done at least 30 days after a medication change and within 90 days of recertification (the form prints underlined > and < signs); a review of the blood glucose self-monitoring logbook, recording device download, or continuous glucose monitoring (CGM) data, if used, with comment on stability, variance (highs and lows) and any other concerns, and, if control is good and there are no concerns, a statement saying so too; the insulin treatment schedule and all other current medications (for any condition) and why they are used (dosage is not required), or an attached current medication list, which should note for what condition the medications are used; and yes-or-no answers, each with a narrative and tests attached if yes, on side effects, any episode of low blood sugar in the past year requiring assistance from another person, evidence of progressive diabetes-induced end organ disease under cardiac, neurological, ophthalmological, neuropathy and renal headings, and any clinical concerns or other comments.
Show the FAA's words: The re-certification status report for this option
DIABETES ON INSULIN Re-Certification STATUS REPORT … NON CGM - Third Class Option (Page 1 of 2) … Class applied … Circle one: INITIAL / Re-Certification … Please have the provider who treats your diabetes enter the information in the space below. … Return the completed status report to your AME or to the FAA at: … 2. Date of last clinical encounter for Diabetes … 3. Date of most recent DIABETES MEDICATION CHANGE … And describe what was changed: … 4. Quarterly hemoglobin A1c … (A1c’s must be done > 30 days after meds change and < 90 days of recertification.) … Quarterly A1Cs Value Date #1 #2 #3 #4 … 5. Review the blood glucose self-monitoring logbook, recording device download, or continuous glucose monitoring (CGM) data, if used. Comment on stability, variance (highs and lows), and any other concerns you have. If control is good and there are no concerns, state that also. … In lieu of #6 and #7, the physician’s office may attach a current medication list. The list should note for what condition the medications are used. … 6. List Insulin treatment schedule: … 7. List ALL other current medications* (for any condition) and why they are used/diagnosis treated. Dosage is not required. … IF YES on any of the questions below, please attach narrative, tests, etc. … 8. Any side effects from medications … 9. ANY episode of hypoglycemia in the past year … REQUIRING ASSISTANCE from another person … 10. Any evidence of progressive diabetes induced end organ disease: … Cardiac … Neurological … Ophthalmological … Neuropathy … Renal disease … 11. Any clinical concerns or other comments?
See Diabetes on Insulin Re-Certification Status Report Non CGM - Third Class Option ( PDF ) .
Good to know
Points from the FAA's own documents that are easy to miss.
Standard ECG tracings are needed
The Guide's stress-test page says computer generated, sample-cycle ECG tracings are unacceptable in lieu of the standard tracings. Submitted alone, they may result in deferment until this requirement is met.
Show the FAA's words: good to know, 1
Computer generated, sample-cycle ECG tracings are unacceptable in lieu of the standard tracings. If submitted alone, this may result in deferment until this requirement is met.
What a progress note must include
In most cases it should come from a visit with the treating physician no more than 90 days ago, and cover the history, medications with dosages and side effects, exam findings, test results, diagnosis, assessment and plan, prognosis and follow-up. The FAA's sheet says to make sure the physician adds the prognosis. A portal note or an After Visit Summary that does not meet these criteria is not enough, and neither is a simple "ok to fly" letter. The FAA's documents also call it a status report.
Show the FAA's words: good to know, 2
your patient portal to print out “notes” or an “After Visit Summary (AVS).” … Patient Portal notes or an AVS that do not meet the criteria listed below for a detailed Clinical Progress Note are NOT sufficient for FAA purposes. … To be “current,” in MOST CASES, the detailed Clinical Progress Note should be from an evaluation in which you saw your treating physician no more than 90 days ago. … It Must include the following items: … A summary of the history of the condition, … Current medications, dosages, and side effects (if any); … Clinical exam findings; … Results of any testing performed; … Diagnosis; … Assessment and Plan; … Prognosis (This item may not be on a standard progress note, make sure your physician adds this information.); and … Follow-up … Please note: A letter stating, “Mr. Smith is ok to fly” (or any other simple note), is NOT a current, detailed Clinical Progress Note and is NOT acceptable. … Any reference to a “status report” equals the criteria listed on this sheet.
Insulin pumps are acceptable
The third-class protocol says insulin pumps are acceptable. Three conditions on a pump are the CGM protocol's, set by that protocol's Certification Aid: the pump must be able to suspend insulin for a predictive low glucose or predicted pressure changes, its insulin must be FDA approved for that use, and the pump must be FDA approved as compatible with the CGM device.
Show the FAA's words: good to know, 3
(Note: Insulin pumps are acceptable.)
C. INSULIN PUMP REQUIREMENTS: … 1. If using an insulin pump, it must have the ability to suspend insulin for a predictive low glucose or predicted pressure changes; … 2. Insulin used in the pumps must be FDA approved for that use; and … 3. Insulin pumps must also be FDA approved as compatible with the CGM device.
Third class may choose either protocol
Third class airmen may elect to use either the CGM protocol or the non-CGM protocol, so the first- and second-class page, which follows the CGM protocol, is open to a third-class pilot who elects it.
Show the FAA's words: good to know, 4
Non-CGM Protocol - Third Class Option … Third class airmen may elect to use either the CGM protocol or the non-CGM protocol.
The two protocols name the doctors differently
This protocol prefers the exam by a physician who specializes in treating diabetes, prefers the Initial Comprehensive Report from the treating board-certified endocrinologist, and asks an eye specialist to confirm. The CGM protocol names a board-certified endocrinologist and a board-certified ophthalmologist; with no retinopathy, an optometrist may be acceptable.
Show the FAA's words: good to know, 5
A report of a complete medical examination, preferably by a physician who specializes in the treatment of diabetes, will be required. … The Initial Comprehensive Report ( PDF ) , which outlines our requirements, is preferred … Confirmation by an eye specialist of the absence of clinically significant eye disease.
The INITIAL COMPREHENSIVE REPORT performed within the past 90 days from the treating board-certified endocrinologist must detail and comment on ALL of the following
ITEM # 1 Initial Comprehensive clinical consultation from your treating board-certified endocrinologist (M.D. or D.O.), not a mid-level practitioner.
ITEM # 4 Eye evaluation from a board-certified ophthalmologist (M.D. or D.O.). … If no retinopathy, an exam by an optometrist (O.D.) may be acceptable; AND
Flying outside the United States
The protocol page says there are no restrictions regarding flight outside of the United States air space.
Show the FAA's words: good to know, 6
There are no restrictions regarding flight outside of the United States air space.
FAA sources
Every FAA document this page relies on, with the FAA's own date and the date Crosscheck last read it. The documents to print open at the FAA, so they are always the FAA's current ones.
- Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial CertificationOpen to print: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Initial Certification, a page at the FAA, in a new tab
Special Issuance
- Insulin Treated Diabetes – Initial Comprehensive Report (non-CGM, third-class option)Open to print: Insulin Treated Diabetes – Initial Comprehensive Report (non-CGM, third-class option), a PDF at the FAA, in a new tab
Special Issuance
- Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight OperationsOpen to print: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Monitoring and Actions Required During Flight Operations, a page at the FAA, in a new tab
Special Issuance
- Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Re-CertificationOpen to print: Guide for Aviation Medical Examiners – Insulin Treated, non-CGM third class – Re-Certification, a page at the FAA, in a new tab
Special Issuance
- Open to print: Diabetes on Insulin Re-Certification Status Report (non-CGM, third-class option), a PDF at the FAA, in a new tab
- Diabetes Mellitus Disposition TableOpen to print: Diabetes Mellitus Disposition Table, a PDF at the FAA, in a new tab
FAA review
- Open at the FAA: Guide for Aviation Medical Examiners – Diabetes Mellitus, Insulin Treated (non-CGM, third-class option), a page at the FAA, in a new tab
- Open at the FAA: Guide for Aviation Medical Examiners – Diabetes Mellitus Type I or Type II, Insulin Treated (CGM option, all classes), a page at the FAA, in a new tab
- Open at the FAA: ITDM – Initial Certificate Consideration Requirements, a PDF at the FAA, in a new tab
- Open at the FAA: ITDM – Certification Aid (CGM), a PDF at the FAA, in a new tab
- Open at the FAA: Guide for Aviation Medical Examiners – Graded Exercise Stress Test Requirements, a page at the FAA, in a new tab
- Open at the FAA: Pilot Information – What a Detailed Clinical Progress Note must contain, a PDF at the FAA, in a new tab
- Open at the FAA: Diabetes Mellitus – Insulin Treated, a page at the FAA, in a new tab
Related conditions
Each has its own page, with what the FAA's documents say about it.
This reports what the FAA has published. It is not medical advice, and it does not say how the FAA or an examiner will decide a case.