What changed between these versions
This is a substantive revision of the bill, primarily expanding its scope to include 'medical clearance' in addition to 'medical certification' and clarifying the information to be provided to aviation stakeholders. v2 also adds new consultation requirements, specifies additional content for the medication list, and introduces a savings clause to limit the Administrator's liability.
Overview
There are extensive changes throughout the bill, affecting nearly every subsection of the core provisions. · v2 expands the scope of the bill to cover medical clearance, clarifies the types of information to be published, broadens stakeholder consultation, and adds a new liability-limiting provision.
The most significant change is the expansion of the bill's mandate to include 'medical clearance' alongside 'medical certification,' broadening the scope of individuals and situations covered. v2 also provides more detailed requirements for the content of the published medication list, including contra-indications and FAA review requirements, and expands the list of stakeholders to be consulted. Furthermore, a new savings clause has been added to protect the Administrator from liability related to the use of the published medication list.
Major additions
These new paragraphs explicitly state that the purpose of the Act is to inform stakeholders about medications on 'Do Not Issue' or 'Do Not Fly' lists, and under what conditions allowed medications may be safely used in the aviation environment, consistent with the Guide for Aviation Medical Examiners or successor documents.
This addition provides a clearer mandate for the type of information to be disseminated, ensuring that both prohibited medications and the specific conditions for safe use of allowed medications, as per official FAA guidance, are included. This enhances transparency and safety guidance for applicants.
These new subparagraphs add 'professional pilot flight training schools certified under part 141 of title 14, Code of Federal Regulations,' 'the Civil Aviation Medical Association,' and 'organizations representing general aviation operators and pilots' to the list of stakeholders that must be consulted prior to the dissemination of the medication list.
The inclusion of these additional groups broadens the expertise and perspectives considered during the drafting of the medication list, potentially leading to a more comprehensive and practically useful resource for a wider range of aviation professionals and trainees. It ensures input from key training and operational segments of the aviation community.
These new subparagraphs require the medication list to include 'contra-indications associated with the medications' and 'whether such medications may require review by the FAA' regarding treatment of medical conditions that may impact performance of duties.
This significantly enhances the practical utility and safety aspect of the medication list by providing crucial information about when a medication should not be used or when it necessitates further FAA review. This helps prevent unsafe medication use and guides applicants through the certification process more effectively.
This new section, titled 'Savings Clause,' specifies that the publication of the medication list shall not be construed as assigning liability to the Administrator for adverse medical reactions, harm, injury, or ineligibility for medical certification/clearance resulting from reliance on the list.
This addition limits the potential legal exposure of the Federal Aviation Administration (FAA) and its Administrator, providing a legal safeguard against claims arising from individuals' use of or reliance on the published medication information. It clarifies the scope of responsibility for the information provided.
Modifications
This is a technical update reflecting the likely year of enactment or reporting, with no operative policy impact on the bill's substance.
Before
The short title of the Act was 'Aviation Medication Transparency Act of 2025'.
After
The short title of the Act is 'Aviation Medication Transparency Act of 2026'.
This modification broadens the applicability of the Act's requirements to a wider range of aviation personnel who require medical approval, ensuring that individuals needing 'medical clearance' also benefit from the medication transparency provisions. This affects air traffic control specialists and certain airmen who might require clearance rather than a full certificate.
Before
These sections referred primarily to 'medical certification' for airmen and air traffic control specialists.
After
These sections now consistently refer to 'medical certification or medical clearance' for airmen and air traffic control specialists.
This modification provides a more comprehensive and explicit directive for the content of the medication list, ensuring that both prohibited medications and detailed usage conditions for allowed medications are clearly communicated to applicants, enhancing clarity and safety.
Before
The purpose was to inform stakeholders of medications they may be safely prescribed.
After
The purpose is now to inform stakeholders of medications on 'Do Not Issue' or 'Do Not Fly' lists, medications they may safely purchase over-the-counter or be prescribed, and the conditions for safe use consistent with the Guide for Aviation Medical Examiners.
This modification clarifies that the FAA's list must cover both prescription and OTC medications, ensuring comprehensive guidance for applicants regarding all types of medications they might use. This directly impacts applicants who use OTC medications, providing them with necessary transparency.
Before
This paragraph referred to medications determined safe to be 'prescribed' to an applicant.
After
This paragraph now refers to medications determined safe to be 'prescribed to or purchased over-the-counter by' an applicant.
This change shifts the emphasis from the FAA ensuring the medical appropriateness of the list content (which is still implied by the content requirements) to ensuring the transparency of the information itself. It underscores the bill's primary goal of making information accessible and clear.
Before
The list requirements were to ensure 'medical appropriateness, user-friendliness, and appropriate dissemination'.
After
The list requirements are now to ensure 'information transparency, user-friendliness, and appropriate dissemination'.
This modification centralizes the authority for identifying additional consultation partners with the Administrator, potentially streamlining the process and ensuring alignment with broader FAA objectives. It gives the Administrator direct control over expanding the consultation base.
Before
This subparagraph allowed for consultation with 'any other stakeholder determined relevant by the Working Group'.
After
This subparagraph now allows for consultation with 'any other stakeholder determined relevant by the Administrator'.
This modification significantly enhances the granularity and utility of the medication list. By requiring contra-indications and FAA review information, it provides critical guidance to applicants and medical providers, potentially reducing confusion and improving safety outcomes. It ensures a more comprehensive and actionable resource.
Before
This paragraph required the list to 'cover all medications approved by the Administrator, including prescription medications and over-the-counter medications'.
After
This paragraph was replaced with a new structure requiring the list to include specific details 'regarding treatment of medical conditions that may impact the performance of duties or the exercise of privileges of an airman certificate', including allowed medications (prescription and OTC), contra-indications, and whether FAA review is required.
This modification provides flexibility to the Administrator by making the inclusion of stabilization periods conditional on practicability, acknowledging potential difficulties in providing such data for all medications. Removing 'average period' simplifies the requirement, while broadening the scope to include trainees ensures they also receive this guidance.
Before
This paragraph required the list to indicate the 'minimum and average period of time' an airman or ATC specialist is required to have limited or no duties to stabilize on an approved medication, if applicable.
After
This paragraph now requires the list, 'if practicable,' to indicate the 'minimum period of time' an airman, ATC specialist, or individual training to become one is required to have limited or no duties to stabilize on a medication 'allowed by the Administrator'. It removed the 'average period'.
This modification ensures that the list comprehensively covers all categories of medications that would render an applicant ineligible, providing clearer guidance and preventing confusion between 'Do Not Issue' and 'Do Not Fly' designations.
Before
This paragraph required the list to include medications designated as 'Do Not Issue'.
After
This paragraph now requires the list to include medications designated as 'Do Not Issue' or 'Do Not Fly'.
This modification grants the Administrator greater flexibility in determining what additional information to include on the list, potentially simplifying the drafting process while still allowing for comprehensive guidance. It shifts from specific mandates to a more general discretionary power.
Before
V1 had two separate paragraphs, 2(c)(7) and 2(c)(8), detailing additional information the Administrator could include (conditions, reasons for allowance/prohibition, and other appropriate info).
After
V2 consolidates these into a single paragraph, 2(c)(7), stating that the list shall 'include any other information or clarification that the Administrator determines appropriate'.
This modification ensures that the medication list remains current and aligned with the latest FAA medical policies and the Guide for Aviation Medical Examiners. It moves away from a potentially arbitrary annual schedule to a more responsive, policy-driven update process, ensuring the information is always relevant and accurate for affected groups.
Before
This subsection required the Administrator to update the list annually after its initial publication.
After
This subsection now requires the Administrator to update the list not later than 1 year after publication, and 'when relevant information in the Guide for Aviation Medical Examiners (or any successor document) or other relevant FAA medical certification policy is updated'.
Scope
Meaningful expansion or narrowing — Changes are concentrated within Section 2, which is the sole operative section of the bill, affecting nearly all its subsections and paragraphs. — v2 represents a meaningful expansion and clarification of the policy direction, broadening the scope of individuals covered (medical clearance) and specifying more detailed content requirements for the medication list, while also introducing a liability limitation. — The changes primarily expand upon and refine the core requirements established in v1, rather than interacting with or modifying provisions outside of the explicitly changed sections. The addition of 'medical clearance' has a pervasive effect across the bill's applicability.
Impact analysis
Applicants for medical certification or medical clearance (airmen, air traffic control specialists, and individuals training to become them)
Gains clearer guidance and expanded access to information.
This group will receive more comprehensive and detailed information regarding both approved and prohibited medications, including contra-indications and requirements for FAA review. The information will also be available for those seeking 'medical clearance', which was not explicitly covered in v1. The information will also be available on MedXPress.
Doctors and medical providers consulting the FAA list
Gains more comprehensive information to aid in patient care and FAA compliance.
The list will include more specific details like contra-indications and FAA review requirements, making it a more robust resource for medical professionals advising aviation personnel.
Aeromedical Innovation and Modernization Working Group and other consultation stakeholders
Experiences a procedural change in consultation dynamics; some groups gain a formal seat at the table.
The list of required consultation stakeholders has been expanded to include professional pilot flight training schools, the Civil Aviation Medical Association, and general aviation operators and pilots. The authority to determine 'other relevant stakeholders' shifted from the Working Group to the Administrator.
Federal Aviation Administration (FAA) and the Administrator
Gains legal protection and clarified operational directives, while also taking on more specific content requirements.
The Administrator's responsibilities for the content and update triggers of the medication list are more detailed. The Administrator gains flexibility in determining additional information to include and now has explicit liability protection via a savings clause.