Denver Day Two: HIMS Itself Is Making the Case for Reform
From PEth testing and peer monitoring to relapse, certificate revocation, neuropsychology and the general aviation gap, Day Two of the 2026 HIMS Seminar revealed something important: many of the strongest arguments for HIMS reform are now being voiced from inside the HIMS community itself.
DENVER — Day Two of the 2026 HIMS Seminar may prove to be one of the most consequential days of the conference for Pilots for HIMS Reform.
Not because anyone stood on stage and declared that HIMS is fundamentally broken.
They did not.
In fact, speaker after speaker described lives saved, careers restored, families rebuilt and pilots successfully returned to the flight deck through treatment and recovery.
P4HR does not dispute those successes.
What made today important was something more subtle.
Throughout presentations on drug and alcohol testing, recovery programs, treatment, peer monitoring, relapse, neuropsychological evaluation, airline policies and general aviation, speakers repeatedly acknowledged limitations, inconsistencies and areas where the system can—and should—work better.
Taken together, those discussions sounded remarkably familiar.
Individualized medicine. Better science. Objective evidence. Less punitive policy. More transparency. Greater consistency. And meaningful safeguards when the system gets something wrong.
That is reform.
DOT Testing and HIMS Monitoring Are Not the Same Thing
One of the day’s earliest presentations carefully distinguished federally mandated DOT drug and alcohol testing from the abstinence testing required under an FAA Special Issuance.
That distinction matters.
DOT testing operates under detailed federal procedures governing collection, chain of custody, Medical Review Officer review, confirmatory testing, split specimens and defined return-to-duty and follow-up procedures.
HIMS Special Issuance testing exists in a different world.
The HIMS testing presentation described phased FAA monitoring requirements and emphasized that HIMS AMEs and other professionals may exercise considerable discretion beyond FAA minimums depending on their assessment of an individual’s recovery.
That immediately raises an important question for reform:
How much monitoring is enough?
And just as importantly:
What objective evidence determines when additional monitoring no longer improves aviation safety?
A modern medical system should be able to answer those questions.
PEth: Powerful Tool, Unsettled Standards
Perhaps the most notable testing statement of the day came during the discussion of PEth.
The answer to a question from the audience was direct:
“There are not uniform PEth standards.”
That should get the aviation community’s attention.
PEth has become an enormously consequential biomarker in alcohol monitoring, yet the presentation itself acknowledged variation in how PEth testing is applied and interpreted.
The session also explored important limitations that frequently disappear once a laboratory result reaches an administrative file.
Different tests have different detection windows.
EtG and EtS do not measure the same period as PEth.
Whole-blood and dried-blood-spot testing have different collection considerations.
Testing can involve threshold questions, specimen handling issues, cross-reactivity in certain screening methods and other technical limitations.
Most importantly, the presentation repeatedly emphasized that a negative test does not necessarily establish abstinence because a substance may fall outside that test’s window of detection or below its reporting threshold.
That scientific caution should work both ways.
A laboratory result is evidence.
It is not a substitute for clinical judgment.
And where a single test can profoundly affect a pilot’s career, P4HR believes the standards governing that test should be transparent, uniform and scientifically defensible.
We will have considerably more to say about PEth after Denver.
Monitoring Reports Should Be Facts, Not Suspicion
Another presentation dealt with one of the less glamorous but enormously consequential parts of HIMS: peer and management monitoring letters.
The guidance was remarkably direct.
Monitors were told to report facts and observations.
Not rumors.
Not speculation.
Not personality judgments.
And one instruction stood out:
Write the report as though you may someday have to defend it in court.
That statement deserves more attention than it received.
A peer-monitoring letter can become part of the information used to evaluate whether a pilot remains medically qualified.
It can therefore affect a pilot’s certificate, livelihood and career.
The seminar’s guidance was exactly right.
If information is consequential enough to influence a federal medical determination, it should be accurate, relevant and capable of surviving scrutiny.
That is due process.
The presentation even offered examples of what should never appear in a monitoring report: unsupported assertions that someone is using drugs, personal attacks, demands to test broadly simply to “see what sticks,” or conclusions unsupported by actual observations.
Those safeguards should not merely be good advice.
They should be foundational principles throughout aeromedical certification.
An Extraordinary Admission: Some Pilots Do Not Belong in HIMS
During the pilot and management breakout, another important point surfaced.
The presenter acknowledged that there are individuals in HIMS who simply should not be there.
The message was straightforward: if someone does not actually have the substance-use disorder HIMS is designed to address, it is neither appropriate nor fair to keep that person in the program.
That may be one of the most important areas of common ground emerging from Denver.
P4HR agrees completely.
But acknowledging the problem immediately raises the next question:
What happens when the system gets it wrong?
What happens when later evidence undermines the original diagnosis?
What happens when independent specialists produce favorable findings?
What happens when years of objective data no longer support the level of oversight being imposed?
And where is the meaningful off-ramp for someone whose continued participation can no longer be medically justified?
HIMS has developed sophisticated pathways for bringing people into monitoring.
A modernized system needs equally credible pathways for determining when they should come out.
Recovery Is Not One Size Fits All
Day Two also included an extensive discussion of peer recovery programs.
Alcoholics Anonymous and Birds of a Feather remain deeply embedded in HIMS culture.
But speakers also discussed SMART Recovery, Recovery Dharma, secular recovery programs and other alternatives.
That was important.
The central message was not that every pilot must recover the same way.
It was that recovery is the objective.
Pilots differ.
Their beliefs differ.
Their experiences differ.
Their families differ.
The recovery program that works extraordinarily well for one person may not resonate with another.
What matters is whether the individual develops genuine, sustainable recovery.
This is exactly the sort of individualized approach P4HR believes should extend beyond peer-support meetings.
If HIMS can recognize multiple legitimate pathways to recovery, aviation medicine should also recognize that the appropriate duration, intensity and structure of monitoring may differ between individuals.
Individualized recovery should eventually lead to individualized certification.
Relapse: Disease or Punishment?
The seminar’s discussion of relapse was equally revealing.
One speaker described addiction as a chronic condition involving periods of remission and, in some cases, relapse.
The emphasis was repeatedly placed on understanding what happened, identifying underlying contributors and getting the individual back into meaningful recovery.
Shame and stigma were specifically identified as barriers.
So were punitive responses.
One presenter compared the way aviation sometimes responds to substance-use relapse with the way another chronic medical condition might be managed.
The larger question was obvious:
If we say addiction is a disease, are our policies actually treating it like one?
Or do some policies continue to treat relapse primarily as misconduct deserving additional punishment?
That distinction matters enormously.
Nothing about recognizing substance-use disorder as a medical condition requires ignoring aviation safety.
The opposite is true.
A safety system should encourage pilots experiencing difficulty to come forward early.
Policies that make pilots terrified of seeking help can undermine that objective.
The strongest HIMS program is one pilots trust enough to enter before catastrophe occurs.
Punishment Is Not Automatically Safety
The pilot-management breakout pushed that question even further.
Twenty-three airlines reportedly participated in an informal comparison of HIMS-related policies.
The differences were significant.
Some airlines pay treatment and evaluation expenses.
Others do not.
Some provide substantial HIMS education.
Others provide little or none.
Relapse policies vary.
Disability benefits vary.
DOT-positive employment policies vary dramatically.
And a particularly striking inconsistency was raised during the discussion:
Some airlines may terminate their own pilot following a DOT-positive test while later hiring a successfully recovered pilot who experienced a DOT positive somewhere else.
The presenter essentially asked the room:
How does that make sense?
It is a fair question.
The discussion then turned toward FAA certificate enforcement following certain DOT violations.
The seminar openly wrestled with whether revoking certificates and type ratings provides an aviation-safety benefit when the pilot is already unable to exercise those privileges.
That distinction is central to reform.
A consequence can be severe without making aviation safer.
If a policy exists primarily as punishment, policymakers should be willing to say so.
If the justification is safety, there should be evidence showing how the policy improves safety.
Those are very different rationales.
P4HR believes aviation regulation should always be capable of answering the question:
What safety outcome does this requirement actually produce?
Neuropsychology: A Test Should Not Be a Coffin Nail
The neuropsychology breakout offered one of the day’s more encouraging messages.
Pilots frequently approach FAA-directed neuropsychological testing terrified that one poor performance will end their career.
The neuropsychologists speaking today pushed hard against that perception.
They described these evaluations as clinical tools.
Anxiety matters.
Developmental history matters.
Learning differences matter.
Past substance exposure matters.
Previous educational functioning matters.
Actual professional performance matters.
And if something unexpected appears, the proper question is not simply whether the pilot “passed” or “failed.”
The question is:
Why?
Was the result caused by anxiety?
Is it developmental?
Is it residual?
Does it conflict with years of demonstrated professional performance?
Does additional information resolve the issue?
One neuropsychologist emphasized that an unfavorable finding on a particular day should not be understood as the pilot having the proverbial coffin nailed shut.
There should still be a pathway.
That philosophy is exactly what evidence-based aeromedical certification should look like:
Investigate. Understand. Individualize. Then decide.
The General Aviation Gap Is Real
One of the day’s strongest presentations focused on general aviation and non-airline pilots.
The difference between the airline HIMS experience and the GA experience can be enormous.
An airline pilot may have access to a union HIMS chair, peer monitors, management pilots, company-funded treatment, disability protection and experienced professionals who know how to navigate FAA requirements.
A general aviation pilot may have none of those things.
The presenter described entering the FAA medical process largely alone and spending years attempting to navigate a system that airline pilots frequently experience with an entire support network around them.
That disparity matters.
The medical standards do not become less consequential because someone flies general aviation.
Nor should access to a fair, understandable certification pathway depend upon which airline employs the applicant.
HIMS and FAA medical certification ultimately affect a much larger aviation community.
Any serious reform effort must recognize that.
Treatment Itself Deserves Scrutiny
Another presentation offered an unusually practical discussion about choosing treatment programs.
Not every facility is the same.
Not every program understands aviation.
Insurance authorization may conflict with the duration or type of treatment professionals believe a pilot needs.
“Accepts insurance” does not necessarily mean “in network.”
Ancillary costs can become significant.
Discharge planning matters.
Family support matters.
Clinical staffing matters.
And documentation matters because delays in obtaining treatment records can translate directly into delays in returning an airman to work.
There was even discussion of situations where aviation professionals attempted to influence treatment-facility diagnoses using aviation standards rather than allowing clinicians to make diagnoses based upon their own professional criteria.
That should concern everyone.
Clinical diagnosis and federal certification are related.
They are not interchangeable.
A treatment professional should diagnose the patient.
The FAA should determine certification.
Blurring those roles creates enormous potential for error.
The Theme We Keep Hearing: Quality Over Box Checking
Perhaps the most consistent theme throughout Day Two was that good recovery cannot be reduced to checking boxes.
Going to a meeting does not necessarily prove recovery.
Passing a test does not necessarily prove abstinence.
Missing a meeting once does not necessarily prove instability.
A disagreement at work does not automatically prove relapse.
A neuropsychological weakness does not automatically prove impairment.
And being technically compliant with a monitoring program does not necessarily tell anyone whether the underlying recovery is strong.
Speaker after speaker emphasized context.
Quality.
Relationships.
Patterns.
Clinical judgment.
Observable facts.
That is important because bureaucracy naturally moves in the opposite direction.
Bureaucracies like checklists.
Thresholds.
Categories.
Mandatory requirements.
Fixed schedules.
They are easy to administer.
But people are not checklists.
And medicine cannot become more scientific by becoming less individualized.
This Is What Reform Looks Like
P4HR came to Denver because we believe strongly in aviation safety.
We also believe the HIMS program has helped many pilots recover and return to productive careers.
Those things can be true while another thing is also true:
The program can be improved.
Day Two demonstrated just how much common ground exists.
We heard that monitoring reports should be factual and defensible.
We heard that recovery pathways can be individualized.
We heard that some pilots do not belong in HIMS.
We heard that PEth practices are not uniform.
We heard concerns about punitive policies that do not clearly improve safety.
We heard that relapse should be approached clinically rather than simply through stigma.
We heard that general aviation remains underserved.
We heard neuropsychologists emphasize pathways rather than automatic failure.
None of those statements undermine HIMS.
They point toward what the next generation of HIMS should become.
The reform conversation is no longer happening only outside the room.
Increasingly, we are hearing pieces of it from inside the room as well.
That may be the most encouraging development of the entire seminar.
This is P4HR’s Day Two report from the 2026 HIMS Seminar in Denver. In the coming days, we will take deeper looks at several issues raised during today’s sessions, including PEth standardization, punitive certificate enforcement, procedural safeguards in monitoring reports, and the need for a meaningful pathway out of HIMS when continued monitoring is no longer scientifically justified.
About P4HR: Pilots for HIMS Reform is an independent pilot advocacy organization seeking transparent, evidence-based, time-limited, and safety-focused reform of FAA HIMS medical certification and monitoring practices. P4HR is not affiliated with the FAA or the official HIMS Program.