MY 2 CENTS By Randy Rowles
WHEN SERVICE TO COUNTRY COLLIDES WITH BUREAUCRACY FAA CERTIFICATE REVOCATIONS OVER VA BENEFIT OMISSIONS
When a pilot applies for or renews an FAA medical certificate, he or she must complete FAA Form 8500-8, also known as MedXPress, certifying that all responses are true and complete. Under 14 C.F.R. § 61.59, any fraud, intentional falsification, or material omission in this application can serve as grounds for suspending or revoking any airman certificate. One of the most consequential areas of disclosure relates to question 18.y; it asks whether the applicant has ever received medical disability benefits. Although the form does not explicitly say “VA benefits,” omission of Veterans Affairs disability benefits — or the underlying conditions tied to them — has triggered numerous FAA enforcement actions. If the agency determines that the omission was material, it can be treated as intentional falsification and lead to certificate revocation, even in cases where the pilot maintains the omission was inadvertent.
In 2022 and 2023, the FAA launched a focused initiative with the Department of Veterans Affairs to cross-reference records of pilots who receive VA disability benefits. The goal was to identify discrepancies between VA records and information disclosed on FAA medical applications. The FAA estimated that fewer than 1% of U.S. pilots, roughly 4,800 airmen, had potential discrepancies. Some cases were handled administratively, allowing pilots to “reconcile” the omissions by submitting corrected
medical applications. Others, however, have
resulted in formal enforcement, including certificate revocation. According to AVweb, the FAA has revoked the certificates of around 60 pilots as part of this effort, underscoring the seriousness with which the agency views these omissions. The FAA has publicly emphasized that disclosure of VA disability benefits is mandatory and that nondisclosure may result in legal enforcement under FAA Order 2150.3C (FAA Compliance and Enforcement Program).
The strict enforcement contrasts sharply with the FAA’s own compliance philosophy, introduced in 2015 under then- Administrator Michael Huerta. That program, now known as the Compliance Program, was intended to create a regulatory framework based on “Just Culture,” distinguishing between intentional violations and inadvertent errors. The guiding principle is that honest mistakes or flawed systems should be addressed with education, remediation, or corrective actions rather than punitive enforcement. The FAA has repeatedly stated that the goal of compliance is to identify root causes, restore compliance, and prevent recurrence rather than to punish. In theory, a veteran who inadvertently omitted VA disability benefits
8 Sept/Oct 2025
should fall under this compliance framework and be eligible for remediation rather than revocation. Yet many affected pilots argue that FAA attorneys are ignoring the compliance philosophy when applying the law to these cases, and that the agency is defaulting to punitive enforcement inconsistent with its stated policy (FAA, Compliance Philosophy).
This inconsistency is highlighted by the case of a state law enforcement pilot who was recently notified that his FAA certificates would be revoked due to alleged omissions on his medical application. Ironically, only weeks earlier, this same pilot had been recognized as a hero, along with other members of his unit, for rescuing children during catastrophic flooding in their state. These are the very individuals who put their lives on the line in service to the public, yet the FAA’s enforcement arm now threatens to end their aviation careers over paperwork that many contend was misunderstood or unintentionally incomplete. Veterans receiving disability benefits often filed those claims years earlier, sometimes with conditions long resolved or misunderstood, and many simply did not realize they were obligated to list them on their FAA medical applications.
The outcome feels especially unfair when considering reports that FAA inspectors themselves, some of whom are military veterans receiving VA disability benefits, have not faced similar certificate actions for the same omissions. While there is no public record confirming FAA employees losing their certificates in these cases, the perception of selective enforcement creates the appearance of bias. Pilots outside the FAA are being aggressively targeted while those within the agency appear immune. For those who fought for their country and now serve as professional aviators, such inconsistency is viewed not just as unfair but as bordering on criminal.
This issue is not simply about technical compliance. It is about whether the FAA is willing to apply its own stated philosophy of fairness and proportionality. Revoking a pilot’s certificate is the ultimate punishment, one that eliminates not only a career but also may limit the ability to serve in law enforcement or public safety missions that depend on aviation capability. The question is whether the public interest is truly served when a decorated pilot who risked his life rescuing children in a flood is grounded permanently for a non-intentional omission.
Advocates for these pilots argue that the FAA should return to its compliance roots, recognizing that omissions of VA
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