There is no question that the Pilot Mental Health Campaign has helped bring needed attention to serious problems within the FAA's aeromedical system.
Pilots have been discouraged from seeking legitimate mental-health treatment because of fears of grounding, certification delays, expensive examinations, invasive medical requirements, and uncertainty about whether asking for help could jeopardize their careers. Those problems are real. Reform is necessary. And when the FAA eliminates a requirement that does not meaningfully contribute to aviation safety, Pilots for HIMS Reform supports that progress.
But there comes a point when an organization calling itself the Pilot Mental Health Campaign must answer a basic question:
That question became impossible to ignore again with PMHC's celebration of the FAA's new AME-Assisted Special Issuance pathway for Anxiety, Depression, and Related Conditions.
The FAA announced the new pathway on July 29, 2026. PMHC subsequently celebrated the change and explained that chief-pilot reports would no longer be required for initial or follow-up antidepressant applications.
Then came the exception:
PMHC nevertheless applauded the FAA for moving toward what it characterized as greater self-monitoring and collaborative decision-making between the treatment provider and the airman.
We agree with that philosophy.
The question is:
Think about what is happening.
For certain pilots with anxiety, depression, and related conditions, the FAA is moving toward a system that places greater reliance upon the pilot, the treating medical professional, and the AME.
Employer reporting is being reduced.
That is progress.
But for pilots with a history of substance dependence participating in HIMS?
The employer remains in the medical-certification process.
Chief-pilot reports remain.
Peer reports remain.
Random testing remains.
Specialized HIMS evaluations remain.
Special Issuance remains.
Extensive monitoring remains.
And potentially years after a pilot has demonstrated stable recovery, the extraordinary machinery of HIMS can remain part of that pilot's professional and medical life.
The FAA's current HIMS recertification materials expressly contemplate recurring reports from chief pilots or airline-management designees and peer pilots, along with HIMS AME evaluations, testing, and other recovery documentation.
Nobody at P4HR is suggesting that pilots should be permitted to fly while impaired.
Nobody is arguing that substance-use disorders should simply be ignored.
Nobody is arguing that every psychiatric diagnosis presents precisely the same medical risk.
The question is much simpler:
And why isn't an organization dedicated to evidence-based aeromedical reform demanding the answer?
PMHC's own stated principles make this disparity particularly difficult to understand.
The organization has publicly described its mission in broad terms: reforming aeromedical policies so pilots can obtain appropriate mental-health treatment without unnecessary fear of professional consequences. Its public materials emphasize concepts including inclusion, transparency, and evidence-based medical policy.
Those are principles P4HR strongly supports.
But inclusion cannot mean:
Transparency cannot mean:
Evidence-based medicine cannot mean:
And reducing stigma cannot mean:
Substance-use disorders are mental-health conditions.
People recover from them.
Pilots recover from them.
And those pilots are entitled to evidence-based aeromedical policy too.
There is another reason this exclusion is so difficult to understand.
PMHC knows what HIMS is.
PMHC's own Board of Directors includes Dr. Brent Blue, whom PMHC identifies as a Senior Aviation Medical Examiner who is HIMS qualified.
That matters.
We are not suggesting that Dr. Blue personally designed the current HIMS system, supports every HIMS requirement, or opposes reform. We have no basis to make any of those claims, and we will not put words in his mouth.
But his presence establishes something important:
This is not some obscure corner of aeromedical policy that PMHC could reasonably overlook.
Furthermore, PMHC's own research library features significant outside research concerning HIMS, including the National Academies' landmark 2023 consensus report, Substance Misuse Programs in Commercial Aviation: Safety First.
To be precise, PMHC did not author that National Academies report, and P4HR is not suggesting that it did.
PMHC has, however, chosen to feature and summarize that research as part of its own mental-health research resources.
That means PMHC knows—or certainly should know—what the National Academies found.
And those findings deserve far more attention than they have received.
In 2023, the National Academies of Sciences, Engineering, and Medicine conducted an extensive examination of substance-misuse programs in commercial aviation, including HIMS.
Its conclusions were not an endorsement of simply leaving everything exactly as it is.
The report identified areas in which aviation substance-misuse practices could be better aligned with evidence-based medicine.
Among other things, the committee addressed barriers to early help-seeking, individualized treatment, continuing care, privacy, disclosure, and the potential consequences of highly intrusive occupational medical systems.
The National Academies recommended individualized treatment and continuing-care approaches based upon the severity of the person's substance misuse and individual circumstances.
That concept should be revolutionary in the HIMS discussion:
Not simply the diagnosis.
Not merely the fact that someone once entered HIMS.
Not an assumption that every person carrying a substance-dependence diagnosis represents an identical risk indefinitely.
The individual matters.
The evidence matters.
The person's actual recovery matters.
And the duration of demonstrated stability should matter.
This is where the contradiction becomes even more pronounced.
The National Academies discussed how strict reporting and disclosure requirements can discourage aviation professionals from seeking help early.
That should sound extremely familiar to anyone following PMHC.
For years, pilot mental-health advocates have correctly argued that an aeromedical system that makes pilots afraid to seek treatment can actually undermine aviation safety.
If pilots believe asking for help will destroy their careers, some pilots will avoid asking for help.
That is not controversial anymore.
It has become one of the central arguments for FAA mental-health reform.
But the principle cannot suddenly disappear when the diagnosis is substance dependence.
A pilot contemplating asking for help with alcohol or another substance is also capable of thinking:
What happens to my medical?
What happens to my career?
Who will be told?
Will my employer become involved?
How long will I be monitored?
How much will this cost?
Will I ever be considered recovered?
Will I ever receive an unrestricted medical again?
If fear of aeromedical consequences discourages a pilot with depression from seeking treatment, that is a safety problem.
If fear of HIMS consequences discourages a pilot developing a problem with alcohol from asking for help before it becomes severe, that is also a safety problem.
The principle does not change because the diagnosis changes.
PMHC has repeatedly criticized expensive and burdensome HIMS-related examinations when those requirements are imposed upon pilots seeking certification involving antidepressants and other psychiatric conditions.
And there is nothing wrong with criticizing unnecessary examinations.
P4HR agrees.
If a $5,000 examination is medically unnecessary, eliminate it.
If a redundant report contributes nothing meaningful to aviation safety, eliminate it.
If an employer does not need access to a pilot's medical circumstances, keep the employer out of them.
If an individualized assessment can safely replace a blanket requirement, use the individualized assessment.
But then apply the principle consistently.
Because there is an uncomfortable contradiction when the argument effectively becomes:
That is precisely the inconsistency P4HR is calling out.
A strange artificial divide has developed in aviation between discussions of “pilot mental health” and discussions of “HIMS.”
They are often treated as separate worlds.
They aren't.
Substance-use disorders involve behavioral health, psychiatric diagnosis, treatment, recovery, relapse assessment, stigma, medical confidentiality, occupational consequences, and continuing care.
Those are mental-health issues.
Indeed, PMHC itself includes HIMS and substance-use research within its mental-health research resources.
So why do HIMS participants repeatedly appear to occupy the periphery of aviation's mental-health reform movement?
Why are we part of the conversation when researchers study us, but seemingly not when policymakers are reducing burdens?
Why are HIMS requirements criticized when they spill over onto other populations, but rarely subjected to the same sustained advocacy when imposed upon the HIMS population itself?
Those are fair questions.
And PMHC should answer them.
This is not the first time P4HR has raised concerns about representation within the aviation mental-health reform movement.
PMHC has publicly highlighted its involvement in the FAA's Mental Health and Aviation Medical Clearances Aviation Rulemaking Committee.
The ARC produced substantial recommendations addressing areas including psychotherapy, depression and anxiety, ADHD, PTSD, peer support, aeromedical education, and broader Special Issuance reform.
Many of those recommendations are worthwhile.
But where was the comparable comprehensive examination of the HIMS substance-dependence system?
Where was the recommendation establishing an objective pathway out of extraordinary monitoring following sustained recovery?
Where was the detailed examination of continuing employer involvement?
Where was the examination of whether peer surveillance remains necessary after years of demonstrated stability?
Where was the examination of testing frequency versus measurable safety benefit?
Where was the examination of whether every continuing HIMS burden remains scientifically justified?
HIMS existed.
The ARC knew HIMS existed.
Substance-use disorders are plainly part of aviation behavioral health.
Yet once again, HIMS participants were not at the center of the reform agenda.
And now we watch another reform arrive.
Once again:
Everyone moves forward.
HIMS stays behind.
This point deserves emphasis because it would be easy to deliberately mischaracterize P4HR's position.
We support the FAA's reduction of unnecessary requirements for pilots with anxiety and depression.
We do not want chief-pilot reports restored for those pilots simply because HIMS participants remain subject to them.
We do not believe pilots with depression should be punished so everyone can be treated equally badly.
That would be absurd.
The answer to unequal unnecessary regulation is not more unnecessary regulation.
The answer is to examine whether the remaining regulation is necessary.
Likewise, P4HR is not claiming that depression, anxiety, substance dependence, PTSD, ADHD, or any other diagnosis presents precisely the same aeromedical considerations.
They don't.
Different medical conditions can warrant different certification requirements.
But different does not mean unquestionable.
And it certainly does not mean permanent.
This is where P4HR's challenge to the FAA—and to organizations claiming to advocate for evidence-based aeromedical reform—becomes extraordinarily simple.
If a chief-pilot report provides a measurable aviation-safety benefit for a pilot who has demonstrated ten years of sustained recovery:
Show us.
If monthly peer reports remain necessary after years of documented stability:
Show us.
If continuing employer involvement in an individual's medical certification provides a measurable safety benefit that cannot reasonably be obtained through medical professionals:
Show us.
If a particular random-testing frequency is scientifically necessary after five, seven, ten, or fifteen years of demonstrated abstinence:
Show us how that number was derived.
If specialized psychiatric or neuropsychological examinations must continue at particular intervals:
Show us the evidence supporting those intervals.
If an individual who has demonstrated sustained recovery can never completely transition out of extraordinary HIMS oversight:
Show us the scientific basis for “never.”
And if the evidence supports different requirements for different stages of recovery?
Fine.
Then build an individualized, transparent, evidence-based step-down system around that evidence.
That is not anti-safety.
Perhaps the most fundamental issue underlying HIMS reform is this:
If a pilot completes treatment, participates in aftercare, undergoes random testing, remains abstinent, receives favorable evaluations, performs safely in the cockpit, demonstrates professional stability, and continues doing so year after year after year—
at what point does that evidence matter?
Three years?
Five?
Seven?
Ten?
Fifteen?
Never?
A medical system supposedly grounded in individualized risk assessment should be capable of answering that question.
If the answer is that extraordinary monitoring decreases as objective evidence accumulates, then there should be a transparent pathway showing pilots exactly how that occurs.
If the answer is that some requirements remain indefinitely, then the FAA should identify the empirical evidence demonstrating why.
What should no longer be acceptable is an opaque system in which a pilot's historical diagnosis becomes a permanent justification for extraordinary oversight simply because “that's how HIMS works.”
A program is not evidence.
A tradition is not evidence.
A policy manual is not evidence.
And repeating a requirement for decades does not establish that the requirement remains scientifically necessary.
This article is not being written because P4HR opposes the Pilot Mental Health Campaign.
Quite the opposite.
PMHC has helped move aviation mental health into congressional offices, FAA policy discussions, aviation conferences, mainstream media, and public debate.
That matters.
When PMHC helps eliminate an unnecessary barrier to treatment, pilots benefit.
We want them to succeed.
But influence brings responsibility.
And an organization claiming to represent pilot mental health broadly should be willing to examine which pilots repeatedly remain outside the reforms it champions.
PMHC cannot reasonably claim ignorance of HIMS.
It has a HIMS-qualified Senior AME on its own Board of Directors.
It features the National Academies' extensive examination of HIMS and aviation substance-misuse programs in its own research resources.
It discusses HIMS specialists and HIMS-derived requirements when those requirements affect other mental-health certification populations.
It knows the system exists.
It knows its burdens exist.
It knows the research exists.
It knows HIMS participants remain subject to chief-pilot reporting even as that requirement is being removed elsewhere.
That is the question.
P4HR does not know what happens inside PMHC's private meetings.
We are not claiming to know why particular priorities were selected.
We are not accusing individual PMHC directors of hostility toward HIMS participants.
And we are certainly not suggesting that every PMHC member personally supports the existing HIMS structure.
Our criticism concerns something we can evaluate:
When major reforms affecting depression, anxiety, ADHD, psychotherapy, and other areas move forward, PMHC publicly champions them.
Good.
When a reform announcement expressly says a burden is being removed for antidepressant cases but retained for substance-dependence HIMS cases, HIMS participants deserve more than a parenthetical acknowledgment of their exclusion.
They deserve an advocate asking:
That is what P4HR is asking.
And we believe an organization representing itself as a national voice for pilot mental health should be asking it too.
So Pilots for HIMS Reform is publicly challenging the Pilot Mental Health Campaign.
Not to abandon its existing work.
Not to stop advocating for pilots with depression.
Not to stop advocating for pilots with anxiety.
Not to stop fighting unnecessary FAA bureaucracy.
Put meaningful HIMS reform on the agenda.
Demand that the FAA identify the empirical basis for continuing HIMS monitoring requirements.
Demand individualized step-down decisions based upon objective evidence and demonstrated recovery.
Demand an examination of whether employer involvement remains medically necessary after sustained stability.
Demand meaningful medical privacy.
Demand transparency regarding testing frequencies and monitoring durations.
Demand an objective pathway by which pilots demonstrating sustained recovery can eventually leave extraordinary monitoring behind.
Demand that HIMS participants themselves have meaningful representation when policies governing their lives and careers are developed.
And the next time the FAA announces that an intrusive requirement is unnecessary for one mental-health population but expressly remains mandatory for HIMS participants:
Ask the FAA why.
Ask for the evidence.
Use the political access and public platform PMHC has worked so hard to build.
Because that is advocacy.
There is a larger principle at stake.
P4HR believes aviation needs an aeromedical system that protects the flying public while recognizing that pilots are human beings.
We believe genuine impairment must be addressed.
We believe pilots should be encouraged to seek treatment early.
We believe treatment should not unnecessarily destroy careers.
We believe medical privacy matters.
We believe objective evidence matters.
We believe individual circumstances matter.
We believe demonstrated recovery matters.
And we believe extraordinary restrictions should have identifiable safety purposes and should be reduced or eliminated when objective evidence no longer supports them.
Those principles should not disappear because the letters H-I-M-S appear in someone's medical file.
PMHC says it believes in inclusion.
It says it believes in transparency.
It says it believes in evidence-based medical policy.
It advocates reducing stigma.
It advocates removing unnecessary barriers between pilots and mental-health treatment.
We agree.
Now apply those principles to HIMS.
Because this latest FAA reform exposes a contradiction that can no longer simply be brushed aside:
P4HR celebrates the pilots receiving relief.
We support their progress.
We want more of it.
Mental-health advocacy cannot mean fighting only for the diagnoses that are easiest to champion.
Inclusion cannot stop when substance-use disorders enter the conversation.
Evidence-based medicine cannot mean demanding evidence for restrictions imposed upon everyone else while accepting HIMS requirements because they have existed for years.
And #SafetyNotStigma cannot merely be a slogan applied selectively while one of aviation's most stigmatized behavioral-health populations continues to live under extraordinary occupational surveillance without a transparent, evidence-based pathway completely out.
So Pilots for HIMS Reform is publicly asking the Pilot Mental Health Campaign a question we believe every HIMS participant deserves to have answered: