Liver transplant
What the FAA's documents say about liver transplant, in plain words, with the FAA's own words one press away.
FAA term: Liver Transplant (recipient, donor, and in combination with other organs)Covers: All classes
- A kidney transplant on its own has a page of its own, written from the Guide's renal transplant protocol. The table's Row C names liver + kidney and does not say where each organ's items are listed.
Short version
The disposition table has three rows, for a donor, a recipient and combined transplants.
| Situation | What the examiner does | Pathway |
|---|---|---|
| Row AA donor, with surgery one year ago or longer, or within the last year | Examiner issues | Examiner can issue |
| Row BA recipient | Defers to the FAA | Special Issuance |
| Row CCombined transplants: liver + kidney, liver + heart, liver + other | Defers to the FAA | Special Issuance |
Show the FAA's words: the FAA's table for Liver transplant
- Row A · Examiner can issue
A donor. The row has two parts, surgery one year ago or longer and surgery within the last year. Where the surgery was one year ago or longer, the table says ISSUE if the examiner can determine the condition has fully resolved with no issues affecting flight duties. Where the surgery was within the last year, the examiner must review a detailed clinical progress note from the transplant team physician, and the table says ISSUE if there are no complications or issues affecting flight duties. The examiner annotates this information in Block 60. The row also says that if there are any complications or concerns, DEFER.
A. Donor Surgery One year ago or longer If the AME can determine the condition has fully resolved with no issues affecting flight duties: Surgery Within the Last Year AME must review a detailed clinical progress note from the transplant team physician. If no complications or issues affecting flight duties: ISSUE Annotate this information in Block 60. If any complications or concerns, DEFER.
- Row B · Special Issuance
A recipient. The row's list is for after a six (6) month post-transplant recovery period with documented stability for the last three (3) months. The table lists what to submit for FAA review. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Item 60.
B. Recipient After a six (6) month post-transplant recovery period with documented stability for the last three (3) months: Submit the following for FAA review: … DEFER Submit the information to the FAA for a possible Special Issuance Annotate (elements or findings) in Item 60.
- Row C · Special Issuance
Combined transplants -- liver + kidney, liver + heart, or liver + other. The table says to submit the required items for each individual organ transplanted. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Block 60.
C. Combined Transplants Liver + kidney Liver + heart Liver + other Submit the required items for each individual organ transplanted. DEFER Submit the information to the FAA for a possible Special Issuance Annotate (elements or findings) in Block 60.
The FAA pathways for liver transplant
Which exam
Which one describes yours?
The FAA's table sorts it these ways. Choose yours to see its plan.
Your step-by-step plan
Step 1: Row A: a donor
Surgery one year ago or longer, or within the last year, and what the examiner determines.Surgery within the last year.
Surgery within the last year.
Where the surgery was within the last year, a detailed clinical progress note from the transplant team physician. Your AME must review it.
Surgery one year ago or longer: if the AME can determine
- The condition has fully resolved with no issues affecting flight duties
Surgery within the last year
- Your AME must review a detailed clinical progress note from the transplant team physician
- No complications or issues affecting flight duties
At the exam
- Your AME annotates this information in Block 60
- If there are any complications or concerns, the table says DEFER
Show the FAA's words: Row A: a donor
Surgery Within the Last Year AME must review a detailed clinical progress note from the transplant team physician.
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
A. Donor Surgery One year ago or longer If the AME can determine the condition has fully resolved with no issues affecting flight duties:
ISSUE
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
Surgery Within the Last Year
If no complications or issues affecting flight duties:
ISSUE
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
ISSUE Annotate this information in Block 60.
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
ISSUE Annotate this information in Block 60. If any complications or concerns, DEFER.
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
Step 2: See your AME
Where the surgery was one year ago or longer, the table says ISSUE if the examiner can determine the condition has fully resolved with no issues affecting flight duties. Where the surgery was within the last year, the examiner must review a detailed clinical progress note from the transplant team physician, and the table says ISSUE if there are no complications or issues affecting flight duties. The examiner annotates this information in Block 60. The row also says that if there are any complications or concerns, DEFER.Exam day- Where the surgery was one year ago or longer, the table says ISSUE if the examiner can determine the condition has fully resolved with no issues affecting flight duties. Where the surgery was within the last year, the examiner must review a detailed clinical progress note from the transplant team physician, and the table says ISSUE if there are no complications or issues affecting flight duties. The examiner annotates this information in Block 60. The row also says that if there are any complications or concerns, DEFER.
Show the FAA's words: See your AME
A. Donor Surgery One year ago or longer If the AME can determine the condition has fully resolved with no issues affecting flight duties: Surgery Within the Last Year AME must review a detailed clinical progress note from the transplant team physician. If no complications or issues affecting flight duties: ISSUE Annotate this information in Block 60. If any complications or concerns, DEFER.
FAA source: Liver Transplant(recipient, donor, and in combination with other organs). FAA date 25 February 2026; checked by Crosscheck 14 October 2026.
What the examiner checks
It depends on which row of the FAA's table describes the case.
Row AExaminer issuesExaminer can issue
Where the surgery was one year ago or longer, the table says ISSUE if the examiner can determine the condition has fully resolved with no issues affecting flight duties. Where the surgery was within the last year, the examiner must review a detailed clinical progress note from the transplant team physician, and the table says ISSUE if there are no complications or issues affecting flight duties. The examiner annotates this information in Block 60. The row also says that if there are any complications or concerns, DEFER.
Row BDefers to the FAASpecial Issuance
The table lists what to submit for FAA review. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Item 60.
If the examiner defersRow CDefers to the FAASpecial Issuance
The table says to submit the required items for each individual organ transplanted. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Block 60.
If the examiner defers
Show the FAA's words: what the examiner does on each row
- Row A · Examiner can issue
A donor. The row has two parts, surgery one year ago or longer and surgery within the last year. Where the surgery was one year ago or longer, the table says ISSUE if the examiner can determine the condition has fully resolved with no issues affecting flight duties. Where the surgery was within the last year, the examiner must review a detailed clinical progress note from the transplant team physician, and the table says ISSUE if there are no complications or issues affecting flight duties. The examiner annotates this information in Block 60. The row also says that if there are any complications or concerns, DEFER.
A. Donor Surgery One year ago or longer If the AME can determine the condition has fully resolved with no issues affecting flight duties: Surgery Within the Last Year AME must review a detailed clinical progress note from the transplant team physician. If no complications or issues affecting flight duties: ISSUE Annotate this information in Block 60. If any complications or concerns, DEFER.
- Row B · Special Issuance
A recipient. The row's list is for after a six (6) month post-transplant recovery period with documented stability for the last three (3) months. The table lists what to submit for FAA review. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Item 60.
B. Recipient After a six (6) month post-transplant recovery period with documented stability for the last three (3) months: Submit the following for FAA review: … DEFER Submit the information to the FAA for a possible Special Issuance Annotate (elements or findings) in Item 60.
- Row C · Special Issuance
Combined transplants -- liver + kidney, liver + heart, or liver + other. The table says to submit the required items for each individual organ transplanted. The examiner defers, submits the information to the FAA for a possible Special Issuance, and annotates the elements or findings in Block 60.
C. Combined Transplants Liver + kidney Liver + heart Liver + other Submit the required items for each individual organ transplanted. DEFER Submit the information to the FAA for a possible Special Issuance Annotate (elements or findings) in Block 60.
If the examiner defersSpecial Issuance
The table marks Row B, a recipient, DEFER.
The table marks Row C, combined transplants, DEFER.
Show the FAA's words: if the examiner defers
When the examiner defers
- Reason 1
The table marks Row B, a recipient, DEFER.
B. Recipient After a six (6) month post-transplant recovery period with documented stability for the last three (3) months: … DEFER Submit the information to the FAA for a possible Special Issuance
- Reason 2
The table marks Row C, combined transplants, DEFER.
C. Combined Transplants Liver + kidney Liver + heart Liver + other Submit the required items for each individual organ transplanted. DEFER Submit the information to the FAA for a possible Special Issuance
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 workAt later exams
The disposition table is headed All Classes.
Show the FAA's words: how often the FAA asks again
LIVER TRANSPLANT All Classes
For recertification, the protocol says applicants found qualified will be required to provide follow up evaluations, including updated items 4-7 of its list, plus any additional information specifically requested in the airman's Authorization letter.
Show the FAA's words: at later exams
Recertification : Applicants found qualified will be required to provide follow up evaluations. This includes updated items 4-7 above, plus any additional information specifically requested in the airman's Authorization letter.
Follow up evaluations for recertification
For recertification, the protocol says applicants found qualified will be required to provide follow up evaluations, which include updated items 4-7 of its list -- the current status report, the complication history, the current medication list, and the lab and images -- plus any additional information specifically requested in the airman's Authorization letter.
Show the FAA's words: Follow up evaluations for recertification
A current status report from the treating physician that describes: … Complication history such as: … Current medication list to include names and dosage of immunosuppressive medications, the presence or absence of any side effects, and how long the airman has been on these medications. … Lab and images to include copies of most recent lab performed by the treating physician (CBC, CMP with LFTs) and any other tests deemed necessary by the treating physician such as imaging or liver biopsy. … Recertification : Applicants found qualified will be required to provide follow up evaluations. This includes updated items 4-7 above, plus any additional information specifically requested in the airman's Authorization letter.
Good to know
Points from the FAA's own documents that are easy to miss.
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, 1
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. … You may also see this called a “current status report” or “status report” in current FAA Guidance. Any reference to a “status report” equals the criteria listed on this sheet.
The table and the protocol name the author in different words
The table asks for a current, detailed clinical progress note from the transplant surgeon or transplant team physician, no more than 90 days before the exam. The protocol asks for a current status report from the treating physician. Both are shown as published.
Show the FAA's words: good to know, 2
1. A current, detailed Clinical Progress Note generated from a clinic visit with the transplant surgeon or transplant team physician no more than 90 days before the AME exam from transplant surgeon or transplant team physician.
A current status report from the treating physician that describes:
Alcohol as a contributing factor
The table lists if alcohol was a contributing factor (abuse or dependence) among what its second item must specifically include. The protocol says that if alcohol was a contributing factor (abuse or dependence), submit evidence of treatment and recovery.
Show the FAA's words: good to know, 3
2. It must specifically include: Indication for transplant, any sequelae prior to transplant, if alcohol was a contributing factor (abuse or dependence), status of the transplant, functional capacity, modifiable risk factors, and prognosis for incapacitation.
If alcohol was a contributing factor (abuse or dependence), submit evidence of treatment and recovery;
The two documents ask for labs and images differently
The table asks for a CBC and CMP with LFTs performed within the past 90 days, copies of the initial and most recent MRI, CT, or PET scan with clinical interpretation, and the results of liver biopsy (already performed). The protocol asks for copies of the most recent lab performed by the treating physician (CBC, CMP with LFTs) and any other tests deemed necessary by the treating physician such as imaging or liver biopsy. Both are shown as published.
Show the FAA's words: good to know, 4
5. Lab: Complete blood count (CBC), CMP with LFTs performed within the past 90 days. … 6. Imaging: Copies of the initial and most recent MRI, CT, or PET scan with clinical interpretation. … 7. Specific testing: Results of liver biopsy (already performed).
Lab and images to include copies of most recent lab performed by the treating physician (CBC, CMP with LFTs) and any other tests deemed necessary by the treating physician such as imaging or liver biopsy.
Hospital records, in two sets of words
The table asks for the history and physical (H&P), operative notes, and discharge summary. The protocol asks for the admission note, operative note, and hospital discharge summary.
Show the FAA's words: good to know, 5
8. Hospital records: History and Physical (H&P), operative notes, and discharge summary.
Hospital reports to include admission note, operative note, and hospital discharge summary;
A donor with complications or concerns
Row A, a donor, ends its disposition with a line of its own -- if any complications or concerns, DEFER.
Show the FAA's words: good to know, 6
ISSUE Annotate this information in Block 60. If any complications or concerns, DEFER.
A combined transplant asks for each organ's items
For combined transplants -- liver + kidney, liver + heart, or liver + other -- the table says to submit the required items for each individual organ transplanted. It does not say where those items are listed.
Show the FAA's words: good to know, 7
C. Combined Transplants Liver + kidney Liver + heart Liver + other Submit the required items for each individual organ transplanted.
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.
- Liver Transplant(recipient, donor, and in combination with other organs)Open to print: Liver Transplant(recipient, donor, and in combination with other organs), a PDF at the FAA, in a new tab
Examiner can issue, Special Issuance
- Open at the FAA: Liver Transplant (Recipient), 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
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.