P4HR FOIA Library
When Transparency Becomes a Threat
Why P4HR is publishing these FOIA responses — and why pilots should keep asking questions.
Pilots for HIMS Reform recently submitted two Freedom of Information Act requests to the FAA seeking records that go directly to the heart of pilot medical certification, HIMS oversight, and the systems that affect pilots’ careers, families, and futures.
The responses we received show exactly why this movement matters.
In one request, we asked for records related to the FAA’s HIMS program, including training materials provided to HIMS-credentialed providers and agreements between the FAA and HIMS-designated AMEs, psychiatrists, and neuropsychologists. These are not obscure academic materials. These are the materials and relationships behind a system that can determine whether a pilot is allowed to work, fly, support their family, or move forward with their life.
The FAA denied the request in full, citing FOIA Exemption 2 and Privacy Act Exemption (k)(6). The agency’s position was that HIMS training materials are available only to authorized AMEs and that disclosure could harm interests protected by the exemption.
In the second request, P4HR sought records associated with an FAA whistleblower complaint involving alleged concerns about HIMS testing procedures. The FAA’s Office of Aerospace Medicine responded that it could not locate the whistleblower complaint in the offices searched, while also noting that portions of the request were assigned to other FAA offices for separate processing.
The central question
How can the government act upon pilots through a closed medical-monitoring system, while refusing to disclose the rules, training, agreements, complaint records, and oversight materials that explain how that system actually works?
That is not transparency. That is controlled access.
And for pilots trapped inside this system, it is not theoretical.
These decisions affect medical certification. They affect careers. They affect reputations. They affect whether a pilot is treated as a person with rights or as a file to be managed behind closed doors.
The government cannot credibly claim that HIMS is a fair, accountable, safety-based process while shielding the materials that explain how HIMS providers are trained, how they are authorized, what standards they are taught to apply, and how complaints about the system are handled.
A system that operates on trust must be open to scrutiny. A system that demands lifelong compliance from pilots must itself comply with transparency, fairness, and due process.
P4HR is not asking for special treatment.
We are asking for the public’s right to know. We are asking for pilots to be allowed to understand the rules of the system being used against them. We are asking for sunlight.
And when agencies respond by withholding, denying, narrowing, or claiming they cannot locate records, that does not end the conversation. It proves why the conversation must continue.
These FOIA responses will be published in the P4HR FOIA Library so pilots, advocates, attorneys, AMEs, policymakers, journalists, and the public can review them directly. We welcome feedback, analysis, legal insight, and public discussion about what these responses mean and what should happen next.
We also encourage others to submit their own FOIA requests.
Do not assume someone else is asking the question. Do not assume the records are unavailable. Do not assume the agency’s first answer is the final answer. Public systems only become accountable when the public keeps asking, keeps appealing, keeps documenting, and keeps publishing.
P4HR will continue to fight for transparency, fairness, and reform in FAA medical certification and HIMS oversight. Pilots deserve a system that is clear, accountable, evidence-based, and respectful of due process.
If the FAA believes its system is fair, it should not fear disclosure.
And if the system cannot withstand sunlight, then the system needs reform.