FOIA Breakthrough: FAA’s Own HIMS Contract Deepens Questions Over Data Withheld from Congress-Mandated Review

A new Freedom of Information Act release from the FAA’s Office of Aerospace Medicine has opened a fresh and potentially important window into the governance of the Human Intervention Motivation Study (HIMS) program.

The interim response, FOIA No. 2026-01412, concerns a request filed December 31, 2025 by P4HR coalition member Brent Weyhrauch through MuckRock. The request targets the underlying HIMS database, FAA–ALPA communications, internal FAA decision-making about the National Academies’ data requests, communications with Senator Jeanne Shaheen’s office, legal analyses, program audits, quality-assurance reviews, records behind the public “85%” success claim, and FAA compliance with Section 554 of the FAA Reauthorization Act of 2018.

This first installment does not yet include the internal emails or legal analyses. Instead, the FAA produced 19 pages: the 2020 FAA–ALPA Other Transaction Agreement that governed HIMS support. The FAA also stated that additional searches remain underway and that separate processing is occurring in the Office of Policy & Strategic Engagement and the FAA FOIA Program Management Office.

What the FAA Contract Actually Required

The September 22, 2020 agreement is not a casual memorandum of cooperation. It is a funded FAA agreement with ALPA requiring personnel, management, training, education, website support, research/outreach, a program manager, an advisory board, recurring reports, and continued operation of the HIMS tracking database.

The agreement required ALPA to enhance the database in cooperation with the FAA, pilot unions, and carriers. It directed procedures for data input from FAA consultants, FAA HIMS AMEs, and Independent Medical Sponsors; required the HIMS Program Manager to review database information for trends and program improvement; and required FAA approval for database modifications recommended by the HIMS Advisory Board.

For privacy protection, the contract states that individuals would not be identified by name in the database. It also says that the FAA would retain access to the HIMS tracking database data when the agreement ended. Separately, Article 5 grants the government broad “Government Purpose Rights” in data developed under the agreement, including unrestricted use and disclosure within the government and specified government-purpose disclosure outside it.

The Congressional Study—and the Data It Couldn’t Get

Section 554 of the FAA Reauthorization Act of 2018 directed the Department of Transportation to enter into an agreement with the Transportation Research Board to study HIMS, the Flight Attendant Drug and Alcohol Program (FADAP), and comparable DOT programs, and then provide findings and recommendations to Congress.

The statute mandated the study; it did not spell out a specific unrestricted database-disclosure command. But the National Academies committee later said its work was constrained because it could not obtain complete HIMS participant data needed to independently evaluate the program.

Why This FOIA Release Is Significant

The Financial Structure Matters Too

The base year was fully funded at $530,632.07. The agreement listed four option years and a total potential five-year value of $2,695,413.17 if all options were exercised. That distinction is important: the document proves the ceiling and base-year obligation, not by itself that every option-year dollar was ultimately spent.

The larger point is not the relative size of any one line item. It is that HIMS administration, research/outreach, training, database work, reporting, and program management were formal federal deliverables under an FAA-funded structure. The agreement also required quarterly progress reports and annual reports identifying accomplishments, ongoing issues, proposed corrections, and desired correction results—precisely the kind of material the pending FOIA searches may now uncover.

And Then There Is the “85%” Claim

HIMS public materials still cite an 85% long-term abstinence/success rate. That number is not wholly without historical origin: an FAA Civil Aeromedical Institute technical report published in 1985 surveyed more than 500 recertified airline pilots diagnosed with alcoholism and reported an 85% success rate since 1976. Current HIMS materials refer to 800 recovering alcoholic pilots and an 85% long-term abstinence rate.

But that is not the same as having a current, complete, independently analyzable database demonstrating the effectiveness of today’s HIMS program across today’s population and practices. The 2023 National Academies review specifically identified the lack of independent HIMS data access as a barrier to evaluating program outcomes and recommended that the FAA require reliable, complete data collection and maintenance.

Weyhrauch’s FOIA request therefore asks a very precise question: What records support the 85% claim as it is used today? The interim production does not answer that question yet. It would be premature to say no supporting records exist; the FAA says additional searches are still pending.

What This Release Proves—and What It Does Not

What it does do is sharpen the accountability question dramatically: If the FAA funded the database, retained broad rights and access, and had the ability to receive recurring program reports, who decided that the independent reviewers Congress ordered to study HIMS would not receive the underlying evidence—and why?

What Comes Next

This is an interim response. The most consequential material may still be coming: internal FAA and ALPA communications, legal analyses, quality-assurance records, program evaluations, the promised aggregate-data trail, and documentation of the 85% claim.

P4HR will continue reviewing and publishing the records as they arrive. The goal is not to prejudge what the remaining documents will show. The goal is to make sure that a program with enormous consequences for pilots’ careers and medical certification can be tested against its own data, its own contracts, and the public record.