Special Issuance Medical (SODA / Authorization)

Special issuance is the mechanism in 14 CFR 67.401 by which the FAA certificates pilots who do not meet the standard medical requirements of Part 67 but who can nonetheless perform airman duties safely. Rather than a flat denial, the regulation gives the Federal Air Surgeon discretion to issue a medical certificate to an applicant with a disqualifying condition when that condition is demonstrated to be adequately treated, controlled, or stable.

There are two distinct instruments under 67.401. The first is an Authorization for Special Issuance of a Medical Certificate — usually just called an Authorization or SI. It is time-limited and condition-specific: the FAA issues a certificate valid for a defined period and attaches conditions, which commonly include periodic reporting of test results, status letters, or follow-up examinations. When the Authorization period ends, the pilot must submit updated documentation to be reconsidered. The second instrument is the Statement of Demonstrated Ability (SODA), granted for a static or non-progressive deficiency — a condition that will not deteriorate, such as a stable loss of limb function or a fixed visual defect. A SODA does not expire; it authorizes an examiner to issue a certificate of a specified class as long as the described condition has not adversely changed.

The review authority sits with the FAA's Aerospace Medical Certification Division (AMCD) in Oklahoma City, whose manager, along with each Regional Flight Surgeon, exercises the Federal Air Surgeon's authority under 67.401. When an Aviation Medical Examiner encounters an applicant with a potentially disqualifying condition, the AME typically cannot issue on the spot and instead defers the application to the AMCD for a decision. This deferral-versus-denial distinction is important and often misunderstood: a deferral means the case is under review and additional information has been requested, whereas a denial is a formal refusal that closes the current application. For students, the anxiety of waiting through a deferral — sometimes months while records are gathered and reviewed — is real, but a deferral is not a denial and frequently ends in an Authorization.

Common conditions that trigger a special issuance include cardiac history (such as coronary artery disease or a prior stent or bypass), diabetes mellitus treated with insulin, and certain mental-health and neurological conditions where the FAA requires evidence of stability and, where relevant, cognitive testing. Each condition carries its own documentation protocol.

To streamline recurring cases, the FAA also uses the AME-Assisted Special Issuance (AASI) process. Under AASI, once an initial Authorization has been granted by the FAA, a designated AME may re-issue the certificate at subsequent exams — provided the pilot brings the required current test results and the condition remains within defined parameters. Examiners cannot grant an initial Authorization; AASI applies only to the renewal of an existing one, keeping the pilot from having to route every cycle back through Oklahoma City.

For a flight school, a student or renter on a special issuance introduces a compliance dimension that a standard medical does not. A special-issuance certificate is only valid while its conditions are met — the Authorization has not lapsed, and any required periodic testing is current. A school that puts such a pilot on a booking without tracking those conditions risks dispatching a flight on an effectively invalid medical, because a special-issuance certificate can be current on its face date yet void if a reporting condition was missed.

Special issuance also affects how a school manages student expectations and enrollment risk. A prospective student with a known cardiac or diabetic history may face a multi-month deferral before their first solo, and a program that understands the difference between deferral and denial can advise the student to begin ground training and dual instruction while the AMCD review runs, rather than losing the student to uncertainty. Framing the process accurately — that a disqualifying condition adequately treated is often certifiable, not a career-ender — is both good counseling and good retention.

Aviatize's Digital Data & Records module stores each pilot's medical details including the special-issuance status, the Authorization's validity period, and the class it covers, so the binding expiry is visible rather than buried in a paper folder. Where an Authorization carries periodic reporting or follow-up conditions, those dates can be tracked alongside the certificate itself.

Aviatize's Compliance & Auditing module can surface a pilot whose special issuance is approaching its Authorization end date or whose required testing is overdue, letting the school intervene before a booking is made rather than discovering an expired authorization after the fact.