The call usually comes a few weeks after the AME deferred the application. Something came up: a DUI from last spring, a positive test at work, or an honest answer to a question on the medical form that the pilot had been dreading for months. The FAA has written back asking for a substance abuse evaluation, and the pilot wants to know one thing before anything else. What are they going to ask me?

It is a fair question, and it has a specific answer, because this evaluation is not improvised. The FAA publishes what it wants in these cases, down to the categories the report has to cover and the credentials of the people who write it. Pilots who understand that before the first appointment tend to come out the other side faster.

I'm Corinne, a licensed psychologist, FAA/HIMS trained aviation psychologist, and a former pilot. I have written elsewhere about the HIMS program as a whole, the structure that gets pilots evaluated, treated, monitored, and back in the seat. This piece is the close-up on the part you can prepare for.

The regulations define abuse and dependence, and one criterion is enough

Start here, because almost every misunderstanding downstream comes from this.

The standards in 14 CFR part 67 define substance dependence as dependence on a substance other than tobacco or ordinary caffeinated beverages, shown by any one of four things: increased tolerance, withdrawal symptoms, impaired control of use, or continued use despite damage to physical health or impairment of social, personal, or occupational functioning. One of four. Not a count of criteria met in a diagnostic manual, and not a judgment call about severity.

Substance abuse in the same standards covers use of a substance in a situation that is physically hazardous when there has been a previous such use, a verified positive drug test result, an alcohol test result of 0.04 or greater, a refusal to take a drug or alcohol test required by the Department of Transportation, and other misuse that the Federal Air Surgeon finds disqualifying. Abuse is measured against the preceding two years. Dependence has no such window, though it carries a recovery provision I will get to.

The medical application mirrors the split. The substance questions ask about dependence or a failed drug test ever, and about abuse or use of an illegal substance within the last two years.

What this means in a room with an evaluator: a pilot can sit down convinced that nothing clinical is wrong, and be correct about that, and still meet a regulatory definition because of a single hazardous-use event or a test result. The evaluator has to address both frames, and a report that only answers the clinical one leaves the FAA's question open.

A pilot substance abuse assessment is usually two evaluations, not one

This is the detail that surprises people. In substance-related cases, the FAA's specifications call for a psychiatric evaluation and a neuropsychological evaluation, submitted as separate reports from two clinicians. The agency's stated reason is that the evaluations have to assess the disorder, the quality of recovery, and any other psychiatric conditions or neurocognitive deficits, and that a psychiatrist and a doctoral psychologist bring different training to those questions.

So when a letter says "substance abuse evaluation," read it as the name of a package rather than the name of an appointment. The failure mode is predictable: one clinician booked, six weeks waited, a report paid for and submitted, and then a request for more information saying that half of what was asked for is still outstanding. If you are unsure which words your letter uses and what each one requires, I wrote a longer breakdown of the three evaluation types and the credentials behind them.

Who may write them is also specified. For first- and second-class commercial pilots, the psychiatric evaluation goes to a HIMS-trained psychiatrist in most cases; most others need a board-certified psychiatrist, and the FAA's specifications look for addiction psychiatry certification or HIMS training on top of that. The neuropsychological evaluation goes to a neuropsychologist from the FAA's list. Neither of those two reports is one I write, which is part of why I can be blunt about who should.

The psychiatric report reaches well beyond the drinking

Pilots expect to be asked about the drinking. They are often unprepared for how far outside it the interview goes.

The minimum content the FAA looks for in the psychiatric report includes a detailed history: psychosocial and developmental background, academic and employment performance, legal history, the substance use history and the course of recovery, aviation background, medical conditions and medications, and the examiner's behavioral observations during the interview. It rests on a thorough clinical interview, ends in a diagnosis stated plainly, addresses whether tolerance or withdrawal has been present, and arrives with copies of the supporting documentation attached.

The breadth is deliberate. A federal physician who has never met you is deciding whether a person with your history can be trusted alone with an aircraft in weather at night. Employment, legal history, and how you have handled setbacks that had nothing to do with alcohol all speak to that in a way a count of drinks per week does not.

The neuropsychological battery asks what the use left behind

The second report is about cognition. The neuropsychologist interviews you, performs a mental status examination, and administers a full battery that goes beyond the FAA's core list, including the CogScreen-Aeromedical Edition, a computerized test built for aviators. The submission includes the CogScreen summary output and score sheets for the rest of the testing, and the FAA keeps the itemized core battery on a secure portal for authorized clinicians rather than publishing it, for test security.

The question behind all of it is whether sustained heavy use has cost you anything in attention, processing speed, memory, or executive function that would matter at altitude. Most pilots do fine. The point is that the agency wants it measured rather than assumed, in either direction.

Two years of documented abstinence is set by regulation, and no clinician can shorten it

Under the mental standards, substance dependence is disqualifying unless there is clinical evidence of recovery, and that evidence includes sustained total abstinence from the substance or substances for not less than the preceding two years.

Pilots sometimes hear that as a sentence handed down by the evaluator, and get angry at the wrong person. No clinician sets that number, shortens it, or waives it. What the evaluation can do is characterize your recovery honestly and document it well: the abstinence and how it has been verified, the structure supporting it, the monitoring record, and the insight you have developed about how you got here. That documentation is most of what separates a package that moves and a package that sits.

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If you are early in the two years, the useful work is building the record you will need at the end of it rather than waiting quietly for the clock to run out.

The SAP evaluation your employer required does not satisfy the FAA

This one costs people months.

A safety-sensitive employee who violates the DOT drug and alcohol rules goes through the return-to-duty process in 49 CFR part 40, which begins with an evaluation by a substance abuse professional and includes a return-to-duty test under direct observation with a verified negative result, followed by a follow-up testing plan of at least six unannounced tests in the first twelve months back.

That process returns you to your employer. It does not return you to your medical certificate. The FAA is explicit that a pilot who holds a part 67 medical and wants to resume certificated duties also has to meet whatever the AME or Regional Flight Surgeon requires and hold a new medical certificate issued after the violation. Two tracks, both required, run by different people on different timelines. A SAP letter in hand is not a finished FAA file, and a pilot who stops at that letter discovers the gap at the worst possible moment.

Your 60-day report to the FAA is separate from anything you tell your AME

If the event was a drug- or alcohol-related motor vehicle action, part 61 requires a written report to the FAA within 60 calendar days. The clock runs from the effective date of the administrative action, such as a license suspension, revocation, or cancellation, or from the date of conviction. A short suspension still counts. A refusal that costs you your license still counts.

Answering the question on the medical application does not satisfy this requirement, and neither does telling your AME. It is a separate notification, and the FAA treats a late report filed before the agency finds the action on its own as a mitigating factor, which tells you how it treats one that never arrives. Certificate action for failing to report is a different and worse problem than the medical one you are already solving.

Bring the whole file, and submit it as one package

Gather the documents before you book anything. For an alcohol-related offense the FAA's own guidance points to a personal statement, blood alcohol results from every offense, the police report, and court records, along with a driving record covering the past ten years. Add treatment records, aftercare documentation, and any prior psychiatric or substance-related treatment the agency does not already have.

Two practical notes. The package is reviewed as a whole, and an incomplete one delays the review rather than starting it, so partial submissions buy nothing. And collecting records from a court clerk, a treatment program, and a DMV takes longer than scheduling two clinicians, so start that part first.

Before the interview, write yourself a chronology: dates, amounts, consequences, what changed and when. Not to rehearse, but because memory under stress is poor at sequence, and a pilot who contradicts their own court record on a date they simply misremembered has created a credibility problem out of nothing.

That is also the quiet thing I would tell anyone walking into this. The evaluator already has the file. Minimizing never works, because the discrepancy is visible on the page, and the discrepancy is what gets written up.

The bottom line

A substance abuse evaluation for the FAA is a structured, documented answer to a short list of questions a federal physician needs settled: what happened, what it means under the regulations, what has changed, and how well that change is evidenced. It is demanding, it is survivable, and pilots complete it every month and go back to flying.

If you have a letter asking for one and you are not sure what it covers or who should write which piece, bring it to a free consultation and we will read it together before you spend anything. General FAA psychological evaluations are completed in person at my office in Orange County, California, and aviation therapy for the rest of what this stretch brings up is available by video anywhere I am licensed.

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