FAA Medical Certification After TBI or Concussion: Recovery Periods, Required Evaluations, and How to Prepare

Introduction

A history of a concussion or traumatic brain injury (TBI) is important to the FAA. They have a defined process for AMEs to evaluate pilots and pilot applicants and determining whether medical certification can be issued or reinstated. Understanding that process can make a difference in setting expectations regarding the path back to flying.

The FAA Severity Classification System

The FAA's required documentation, recovery period, and overall timeline depend on which category your injury falls. Their approach (FAA's Head Injury guidance (PDF)) was updated in December 2025 and breaks down TBI into four categories. The document is officially called "The HEAD INJURY or BRAIN INJURY Concussion, Closed Head Injury (CHI), Open Head Injury, Traumatic Brain Injury (TBI) Disposition Table."

Row A: Head Injury Only, No Brain Injury If there was no concussion, no neurological symptoms, and imaging was negative, the AME may be able to issue your certificate at the exam with no required deferral.

Row B1: Mild Brain Injury or Concussion, Five or More Years Ago If your concussion or mild TBI occurred five or more years ago with no seizures or ongoing concerns, your AME may be able to clear you using a brief decision tool, without deferring to the FAA.

The remaining options require the AME to defer to the FAA and not issue a medical certificate.

Row B2: Mild Brain Injury or Concussion, Within the Past Five Years If the injury involved loss of consciousness, alteration of consciousness, or post-traumatic amnesia of less than one hour and occurred within the past five years, a six-month recovery period is required. After that, the case is deferred to the FAA for special issuance review. A neuropsychological evaluation is not automatically required at this level, though the FAA may request one depending on what the records show. This category requires the treating clinician or neurologist to write a detailed progress within 90 days of the AME visit.

Row C: Moderate Brain Injury This applies when loss of consciousness, alteration of consciousness, or post-traumatic amnesia lasted between one and 24 hours, or when there was a non-depressed skull fracture, or a small hemorrhage that resolved on MRI. A 12-month recovery period is required, followed by a full documentation package including a neurological evaluation, a neuropsychological evaluation meeting FAA specifications, an MRI, and hospitalization records. The neuropsychological evaluation is mandatory.

Row D: Severe Brain Injury This applies when there was blood in the brain, a contusion, intracranial bleed, hematoma, diffuse axonal injury, depressed skull fracture, penetrating injury, or loss of consciousness lasting 24 hours or more. The required documentation is the same as Row C, but the mandatory recovery period is five years. The FAA does not offer early review regardless of the clinical picture. The AME Guide is clear on this point and informal advice suggesting otherwise is not accurate.

The Neuropsychological Evaluation Comes After FAA Engagement

For Row C and Row D cases, the neuropsychological evaluation is required. The FAA's preferred workflow is to receive the full documentation package from the AME first, review it, and then issue a deferral letter specifying what evaluation is needed. The neuropsychological evaluation is scoped to address those specific questions.

Once the letter arrives, record gathering, FAA file requests, and coordination with outside providers still need to happen before the evaluation itself can begin. That process is covered in more detail here.

Why Getting on the Schedule Early Matters

HIMS neuropsychologists with FAA evaluation experience are often booked several months out. If you are approaching your recovery period milestone, whether that is 12 months or five years, making contact early means you can reserve a date before the deferral letter arrives. If circumstances change, appointments can be adjusted. The cost of waiting is measured in months. The cost of planning ahead is minimal.

Pilots and Applicants with a Prior ADHD History

If your records also include an ADHD diagnosis, the FAA treats that as a separate question with its own documentation requirements. If you meet the criteria for the ADHD Fast Track, that process can often be initiated before FAA engagement on the TBI side. A consultation can help clarify whether that applies to your case and what the right sequence looks like.

Takeaway

The FAA's head injury classification system determines your recovery period and what documentation is required. For moderate and severe injuries, the path runs through the FAA first and the neuropsychological evaluation second. Because qualified evaluators book out months in advance, the pilots and applicants in the best position are those who make contact before the deferral letter arrives.

If you have experienced a concussion or TBI and are approaching your recovery period, or if you have already received a deferral letter requesting a neuropsychological evaluation, a brief consultation can help clarify where you stand and what comes next.

Schedule a 15-minute consultation.

Written by Jason Olin, PhD, Licensed Clinical Psychologist and Neuropsychologist. Dr. Olin provides neuropsychological evaluations for FAA medical certification and high-stakes licensing decisions. He is licensed in California, New York, and Arizona and provides services in California and via telehealth where authorized.