A HIMS Aviation Medical Examiner (HIMS AME) is a Federal Aviation Administration-designated physician who has completed specialized training to evaluate, certify, and monitor aviation professionals participating in the Human Intervention Motivation Study (HIMS) programâÂÂthe FAA's substance use disorder monitoring and return-to-duty program for pilots, air traffic controllers, and other aviation certificate holders. HIMS AMEs perform a dual function: they conduct aeromedical evaluations required for special issuance medical certification under 14 CFR ç 67.401, and they serve as the primary clinical point of contact for ongoing monitoring of participants throughout the duration of their program participation, which under current FAA policy extends for the remainder of a pilot's flying career.
As of 2019, only 204 of approximately 2,500 FAA Aviation Medical Examiners nationwide held HIMS AME certification, and as of the date of the 2023 National Academies of Sciences, Engineering, and Medicine review, only 48 handled the majority of HIMS cases. This concentration of a safety-critical function among a small number of providers has raised concerns about geographic access, financial conflicts of interest, and accountability, documented in two federal legal proceedingsâÂÂMcKeon v. Fries (2025) and Barnard v. Kozarsky (2024)âÂÂin which HIMS AMEs faced negligence claims, resulting in the first known jury verdict against a HIMS AME in the program's history.
The 2023 National Academies studyâÂÂthe first independent review of HIMS in the program's 49-year historyâÂÂfound that HIMS AMEs play a central role in the program's decentralized structure, that peer reports submitted by non-clinical lay monitors are included in FAA certification packages prepared by HIMS AMEs, and that commercial HIMS AME practices appear to access program outcome data that the FAA declined to provide to congressionally mandated researchers.
HIMS AME certification is issued by the FAA's Office of Aerospace Medicine following completion of a specialized training curriculum administered by the Air Line Pilots Association, International (ALPA) under FAA contract. To become a HIMS AME, a physician must first hold standard FAA Aviation Medical Examiner designation and then complete training through the HIMS basic and advanced seminars, which cover evaluation methodology, FAA certification requirements, monitoring protocols, and the program's contractual framework including Last Chance Agreements and Recovery Contracts.
The FAA's 2025 contract solicitation for HIMS program services specifies that ALPA's contract obligations include "conducting annual basic and advanced educational seminars" for HIMS AMEs, psychiatrists, psychologists, pilots, and airline management. The curriculum includes instruction on "Contracts and Last Chance Agreements" as a formal seminar component. No external certification body accredits HIMS AME training; qualification is conferred through internal HIMS seminars only.
The FAA maintains a publicly available directory of certified HIMS AMEs organized by geographic region.
Under 14 CFR ç 67.401, pilots with a history of substance dependence require an Authorization for Special Issuance of a Medical Certificate to exercise the privileges of their airman medical certificate. The HIMS AME serves as the primary architect of the submission package submitted to the FAA for special issuance certification, and retains ongoing authority over the pilot's certification status throughout the monitoring period.
According to official HIMS program documentation, "the AME is authorized at any time to recommend to the FAA to revoke the medical certificate" and "can advise the pilot that they should not exercise the privileges of their medical certificate if non-compliance with the Special Issuance is suspected or confirmed." This authority extends throughout the pilot's career under the FAA's 2020 lifetime monitoring policy.
FAA policy requires pilots to remain with the same HIMS AME for a minimum of seven years, with transfer requiring formal FAA approval and, in some cases, approval from the Federal Air Surgeon. The stated rationale is providing "continuity and familiarity" and preventing pilots from "doctor shopping." Critics have characterized this restriction as eliminating meaningful recourse for pilots who dispute their HIMS AME's assessments or conduct.
The National Academies noted that the HIMS AME serves as the conduit through which lay peer monitor reportsâÂÂexplicitly described in official program guidance as "not expected to meet clinical standards"âÂÂare incorporated into FAA certification submission packages.
HIMS AMEs oversee abstinence testing that is distinct from Department of Transportation workplace drug testing programs and operates under different methodological and oversight standards.
FAA HIMS monitoring requires participants to undergo a minimum of 14 urine ethyl glucuronide (EtG) tests annually for the first four years of monitoring, transitioning to quarterly blood phosphatidylethanol (PEth) testing after sustained compliance. Both EtG and PEth are classified as Laboratory Developed Tests (LDTs) not FDA-verified for safety, effectiveness, or quality.
The Substance Abuse and Mental Health Services Administration (SAMHSA) has warned that EtG tests "should not be used as the sole basis for legal or disciplinary action" and specifically warned that positive results "could have devastating consequences for someone who signs an alcohol abstinence contract." Peer-reviewed research has documented false positive EtG results from incidental exposure to alcohol-based hand sanitizers and false positive PEth results from alcohol vapor exposure during dried blood spot sample collection and red blood cell transfusions.
Unlike DOT workplace testing, which requires positive results to be reviewed by a Medical Review Officer (MRO) who evaluates whether a legitimate medical explanation exists before reporting results to employers, HIMS abstinence testing results are reported directly to the HIMS AME without comparable independent medical review. The HIMS AME thus serves simultaneously as the physician receiving the test result, the decision-maker on its clinical significance, and the certifying authority for the pilot's FAA medical status.
The National Academies noted this structure in its review of program monitoring practices, observing that HIMS testing operates outside the federal workplace testing framework and its associated oversight mechanisms.
The concentration of HIMS cases among a small number of certified providers creates geographic access barriers, particularly for pilots employed at smaller carriers or based in rural areas. As of 2019, only 204 FAA AMEs held HIMS certification nationally, and as of the National Academies review, only 48 handled the majority of active cases. The FAA maintains a directory of HIMS AMEs organized geographically, but the directory does not indicate case volume, specialty, or availability.
The 2023 National Academies study noted that HIMS implementation is "highly decentralized," with individual airlines and unions having "considerable autonomy in how they carry out the expectations of the program," and that airlines "often maintain the managerial functions" of HIMS monitoring for their own pilots. This decentralization means that access to HIMS AME services, the quality of oversight, and the level of accountability vary significantly by carrier and geographic region.
HIMS participation costs pilots $8,000 to $15,000 in the first year alone, the majority of which flows to HIMS AME practices. Some HIMS AME practices require cash payment only and decline to accept health insurance, a practice documented on at least one commercial HIMS AME practice website. Some HIMS AMEs have been reported to charge $500 to $600 per hour for consultations.
The program's financial structure involves parallel funding streams: federal public funds flow to ALPA under FAA contract (Other Transaction Agreement 693KA9-20-H-00004, $530,632.07 for FY 2020), while commercial HIMS AME practices charge participants separately on a fee-for-service basis outside the federal contract.
A 2023 Department of Transportation Office of Inspector General report noted that pilots may experience "financial hardship if FAA's approval process extends beyond the pilot's prescribed disability benefit period."
Harvard researcher J. Wesley Boyd, MD, PhD, commenting on analogous monitoring programs, stated: "Injecting the profit motive into a situation where folks generally have no choice but to comply with any and every recommendation you make if they want to be able to continue practicing is a recipe for abusive practices."
Commercial HIMS AME practices publish outcome statistics on their websites that they attribute to FAA data, yet the same data was not provided to the congressionally mandated National Academies study committee despite repeated requests. Kansas Aviation Medicine, a private HIMS AME practice, states on its website that "FAA data from April 2011 through October 2019" shows 1,162 first-class certificate holders in HIMS with an 85 percent sustained abstinence rate, claiming access via "a new online tool." The National Academies was denied access to this same data.
Multiple other commercial HIMS AME practices publish similar statistics without verifiable citation:
The National Academies highlighted this as an internal contradiction: commercial HIMS AME practices, which have direct financial interests in presenting the program favorably to prospective clients, appear to access outcome data withheld from the congressional mandate. The FAA and ALPA have not publicly addressed this discrepancy.
In June 2025, a Florida jury awarded $513,000 to a pilot after HIMS AME Dr. Ian Blair Fries erroneously attributed another pilot's positive PEth blood test result to him, resulting in years of wrongful grounding. The verdict in McKeon v. Fries (Fla. Cir. Ct., 19th Jud. Cir., Indian River Cnty., No. 2023-CA-001095) represents the first known jury verdict finding a HIMS AME negligent in the program's history.
The case illustrated risks inherent in the program's decentralized structure: a single HIMS AME monitoring multiple pilots simultaneously misattributed one pilot's blood test result to another. The 2023 National Academies study had previously noted HIMS's "highly decentralized" implementation as a structural concern.
In Barnard v. Kozarsky (2024), a court denied a HIMS AME's motion to dismiss a negligence claim, rejecting the AME's argument that no doctor-patient relationship existed with the pilot he monitored. The ruling allowing the negligence claim to proceed to discovery established that HIMS AMEs may be subject to standard medical malpractice liability notwithstanding the program's administrative structure. As of the date of this article's most recent revision, the case was proceeding through discovery.
Dr. David B. Altman was a HIMS Aviation Medical Examiner retained by Delta Air Lines to conduct a psychiatric evaluation of pilot whistleblower Karlene Petitt, for which Delta paid him approximately $74,000. Altman diagnosed Petitt with bipolar disorder, grounding her; however, a panel of nine physicians from the Mayo Clinic's Aerospace Medicine Department unanimously concluded she did not have bipolar disorder or any psychiatric disorder. In December 2020, Administrative Law Judge Scott Morris ruled that Delta had "weaponized" the psychiatric evaluation process and awarded Petitt $500,000 in damages.
In 2020, Altman forfeited his medical license rather than face disciplinary charges from the Illinois Department of Financial and Professional Regulation related to his conduct in psychiatric evaluations of two Delta pilots. Altman had testified that his bipolar diagnosis of Petitt was driven in part by her professional accomplishments, which he characterized as beyond what "any woman I've ever met could do"âÂÂtherefore suggestive of mania. As of the date of this article's most recent revision, the FAA has not publicly addressed how it evaluates the ongoing eligibility of HIMS AMEs following license forfeitures in other jurisdictions.
Dr. Ian Blair Fries is a Senior FAA HIMS Aviation Medical Examiner who has served as Chairman of the AOPA Board of Aviation Medical Advisors, on the FAA/ALPA HIMS Advisory Board, and as aviation medical consultant for the Teamsters Airline Division. Fries has presented on "HIMS: The Standard of Care and Legal Liability" at the Lawyer-Pilots Bar Association, and presented an academic poster at EmbryâÂÂRiddle Aeronautical University's 2024 National Training Aircraft Symposium asserting that "The HIMS Program is extremely successful with about 85 percent of pilots who participate recovering and returning to the cockpit"âÂÂeight months after the National Academies found such claims could not be substantiated.
In June 2025, a Florida jury awarded $513,000 to a pilot after Fries erroneously attributed another pilot's positive PEth blood test result to him (see McKeon v. Fries). As of February 2026, Fries remained listed as an active HIMS AME on the FAA's directory.
Dr. Alan Kozarsky is an ophthalmologist serving as a HIMS Aviation Medical Examiner for Delta Air Lines pilots. In August 2024, Captain Martin Barnard, a Delta pilot, filed a negligence lawsuit against Kozarsky alleging that in October 2022, after Barnard reported possibly consuming low-alcohol beer accidentally, Kozarsky reported to the FAA that Barnard was experiencing "imperfect recovery" and presented an "increased risk for full relapse"âÂÂdespite a subsequent PEth test returning negative. Delta subsequently demanded Barnard accept the diagnosis and undergo 98 days of inpatient treatment.
Kozarsky moved to dismiss, arguing he had no doctor-patient relationship with Barnard and was exempt from liability as an FAA representative. The court denied the motion, ruling that Barnard's complaint "plausibly alleges that it was foreseeable that Dr. Kozarsky's report would cause the FAA to revoke Barnard's medical license." The ruling established that HIMS AMEs may be subject to standard medical malpractice liability notwithstanding claimed exemptions based on the absence of a traditional doctor-patient relationship. As of the date of this article's most recent revision, the case was proceeding through discovery.
Reform advocates have raised concerns about the structural role of HIMS AMEs, focusing on three areas: accountability deficits in a market with no competitive oversight, the absence of independent review of testing results, and the financial incentives created by a mandatory program with a captive participant population.
Pilots for HIMS Reform, an advocacy organization, has called for "oversight of AMEs and providers by neutral partiesâÂÂnot insiders" and stated that "medical decisions should be explainable, reviewable, and rooted in evidence." The organization's proposed AEROPath alternative framework specifically calls for independent medical review panels as a replacement for the current HIMS AME authority structure.
The FAA HIMS Program Information Center, an independent resource, notes that "FAA medical consultants operate behind closed doors" and advocates for "updated policies that reflect modern addiction science, relapse risk assessments, and peer-reviewed data."
The National Academies found that without access to outcome data, it could not evaluate whether HIMS AME practices are evidence-based or effective, and that the program had operated for 49 years without generating publicly available peer-reviewed research on its own effectiveness.
The DOT Office of Inspector General announced in March 2026 an audit of FAA's oversight of the HIMS program (Project No. 26A3004A000), which will assess FAA's administration and effectiveness of HIMS at FAA Headquarters and the Civil Aerospace Medical Institute in Oklahoma City.