Human Intervention Motivation Study (HIMS)

FAA HIMS Program
Seal of theFederal Aviation Administration
Agency	Federal Aviation Administration
Type	Substance abuse monitoring and return-to-duty program
Established	1974; 52 years ago (1974)
Budget	$530,632 (FY 2020 contract)[1]
Contractor	Air Line Pilots Association
Data ownership	FAA-owned; ALPA-maintained[1]
Participants	~3,000 current (2021); ~12,000 historical (unverified)[2][3]
Website	himsprogram.com
Effectiveness and oversight
Claimed success rate	85% (methodology undisclosed)[3][4]
Independent verification	"Could not be substantiated"[3]
Congressional mandate	Section 554 data request declined[1]
Study chair assessment	"Doesn't look that great"; "made me less sanguine about flying"[5]
Program transparency	"Did not really want to have a lot of scrutiny"[5]
External oversight	None documented in 49-year history[3]
Coercion model
Program philosophy	Move pilot from "coerced sobriety" to "choosing abstinence"[6]
Monitor directive	"Protect the program, not the pilot"[6]
Leverage policy	"Achieve and maintain leverage over the individual"[7]
Source validation	"Not necessary to validate sources" before action[7]
Unverified allegations	Anonymous reports, coworkers with grudges, or parties with conflicts of interest may trigger interventions without verification[7]
Union protection	Union explicitly precluded: "Fraternal bonds" should not protect pilots[6]
Participant framing	"Addictive disease behavior" = "hiding facts, providing miss-information [sic], and manipulation of data"[7]
Compliance assessment	Monitors judge if pilot is "playing the game" vs "walking the walk"[6]
Grievance rights	Waived under Last Chance Agreements[8]
Pilot recourse	"No mechanism to review or challenge" reports before FAA submission[9]
Policy document authors	Identified via metadata only; no medical/clinical credentials indicated; documents show no indication of clinical review[6][7][10][11]
Surveillance (methodology undisclosed)
Monitoring duration	Minimum 7 years; effectively lifetime special issuance medical[12]
Compliance failure	Any violation resets clock to zero[10]
Layover surveillance	"Layover behavior" monitored; "specific methods" not publicly documented[13][14]
Off-duty monitoring	Expected but methodology undisclosed by FAA/ALPA[14]
Information sources	"Fellow crewmembers...hotel incident reports...family members"[15]
Privacy rights	"Peer pilot cannot provide privacy, privilege, or anonymity"[13]
Rest regulation conflict	Potential conflict with FAA rules requiring rest "free from all restraint"[14]
Lay peer monitors (non-clinical)
Monitor training	2½-day seminar; "only the first step in qualifying"[15]
Ongoing qualification	"Experience...from other trained members in the system"[15]
Assessment standard	Instructed to "trust their intuition"[15]
Report standard	"Layman's report"; "not expected to meet clinical standards"[13]
Clinical status	Explicitly "Not a Medical Diagnosis / Assessment"[16]
Training accreditation	Internal HIMS seminars only; no external certification body[16]
Religious framing	Peer monitoring described as "AA '12th Step' work"[6]
Testing protocols
Testing methods	EtG,PEth biomarkers[13]
FDA status	Non-FDA approvedLaboratory Developed Tests[17][18]
Result review	NoMRO review; reported directly to HIMS AME[13]
SAMHSA warning	"Should not be used as sole basis for legal or disciplinary action"[17]
Testing window	4 hours to present for random testing[19]
False positive risk	Incidental alcohol exposure, collection errors, and other testing irregularities can cause false positives[20][21]
AME accountability	First jury verdict against HIMS AME: $513,000 for misattributed PEth result (2025)[22]
Costs
Participant cost	$8,000–$15,000 (first year)[23]
Payment model	Some AMEs: "cash program only; health insurance will not be accepted"[24]
Funding structure	Public funds ($530k) to ALPA; commercial AMEs charge separately[1][24]
Doctor-patient relationship	HIMS AME claimed "no doctor-patient relationship"; court denied dismissal[25]

TheHuman Intervention Motivation Study (HIMS), also known as theFAA HIMS program, is aUnited StatesFederal Aviation Administration (FAA) program that coordinates the identification, treatment, monitoring, and return-to-duty process for aviation professionals withsubstance use disorders or other conditions requiring FAA special issuance medical certificate review. Established in 1974 with support from the FAA, theAir Line Pilots Association, International (ALPA), and funding from theNational Institute on Alcohol Abuse and Alcoholism (NIAAA), the FAA describes HIMS as "an effective program that allows safety-sensitive employees to return to work in a safe and structured manner," and the program is supported by major airlines, pilot unions, and aviation industry organizations.^[26][27] FAA medical certification is required forpilots,air traffic controllers,flight engineers,flight navigators, and other aviation personnel;^[28] while originally developed for airline pilots, HIMS evaluations and monitoring are performed on all certificate holders requiring FAA medical clearance, including air traffic controllers and Aviation Safety Inspectors.^[23] The program has expanded to include pathways forpost-traumatic stress disorder andattention deficit hyperactivity disorder.^[3] As of 2021, approximately 12,000 pilots have been returned to flying under HIMS supervision since the program's inception.^[2]

The program requires participants to undergo monitoring including random drug and alcohol testing usingethyl glucuronide (EtG) andphosphatidylethanol (PEth) biomarkers, attendance at peer support meetings, and oversight by specially designated Aviation Medical Examiners, with a minimum monitoring period of seven years and effectively lifetime special issuance medical certification under current policy.^[13][12] Testing costs are borne by participants, with first-year expenses ranging from $8,000 to $15,000.^[23] TheSubstance Abuse and Mental Health Services Administration (SAMHSA) has warned that EtG tests "should not be used as the sole basis for legal or disciplinary action."^[17] Program stakeholders have acknowledged that claimed outcomes depend on coercive leverage over participants' careers rather than therapeutic efficacy alone.^[29]

A 2023National Academies of Sciences, Engineering, and Medicine study—the first independent review in the program's 49-year history—found "no solid evidence" supporting HIMS's claimed 85% success rate and concluded that effectiveness claims "could not be substantiated," noting that the FAA and ALPA had declined to provide outcome data to congressionally mandated researchers.^[3][4][5] The committee noted that without access to the underlying data, it could not "resolve questions that arose during the study about the quality of HIMS data and data systems."^[30] The study also found that HIMS treats roughly 1.5 percent of pilots despite research suggesting 13 to 15 percent may have a substance use disorder, attributing this gap in part to fear of career consequences—a concern the FAA's own Mental Health Aviation Rulemaking Committee later identified as "the most prevalent and serious barrier" to seeking treatment.^[3][31]

Several legal cases have challenged program-related practices, including whistleblower retaliation through psychiatric evaluations, religious and racial discrimination, mischaracterization of medical conditions as substance use disorders, disputed biomarker testing, and allegations that airlines use HIMS referrals to manage employees rather than address genuine clinical concerns.^{[9][32][33][34][35][25]} In 2025, a Florida jury awarded $513,000 to a pilot whose HIMS Aviation Medical Examiner erroneously attributed another pilot's positive blood test to him, the first known jury verdict finding a HIMS AME negligent.^[22] Fear of disclosure has been linked to pilot suicides, and the House of Representatives unanimously passed the Mental Health in Aviation Act in September 2025, requiring the FAA to implement recommendations from its rulemaking committee;^[36][37][38] pilot advocacy organization Pilots for HIMS Reform has argued the legislation does not address structural HIMS issues including due process deficits and testing protocols documented by the National Academies study.^[39] The HIMS model has been adopted internationally in Australia, New Zealand, Hong Kong, and several European countries.^[40]

HIMS originated in 1974 when the Air Line Pilots Association received a federal grant to develop an occupational alcoholism program, founded on the premise that traditional workplace intervention methods were ineffective for pilots due to their "high degree of autonomy and the difficulty of detecting performance issues in the cockpit environment."^[27][41][42]

The FAA joined the initiative by developing evaluation and monitoring procedures that enabled pilots who achieved adequate recovery to return to flying through special issuance authorization. This cooperative tripartite system among pilots, airline management, and the FAA became the foundation for HIMS operations.^[27][42]

The program operated under this informal cooperative structure for over three decades before undergoing significant expansion. In April 2010, the FAA reversed a nearly 70-year ban on pilots taking antidepressants, announcing that pilots with mild to moderate depression could fly while taking certainselective serotonin reuptake inhibitors if they demonstrated successful treatment for at least 12 months. The policy change, which the FAA said was designed to "change the culture and remove the stigma" associated with depression, expanded the role of HIMS AMEs to oversee monitoring and evaluation of pilots treated with approved psychiatric medications.^[43][44][42]

By 2018, HIMS had grown from an occupational alcoholism program^[41][42] to a broader aeromedical certification pathway, prompting Congress to formally authorize the program and mandate independent review. The FAA Reauthorization Act of 2018 included Section 554, based on legislation authored by SenatorJeanne Shaheen (D-NH) called the "Transportation Workforce Recovery and Retention Act," which permanently authorized HIMS and mandated that the National Academies of Sciences, Engineering, and Medicine conduct an independent study of the program's effectiveness.^[45][46] When the National Academies committee attempted to conduct this congressionally mandated study, the FAA and ALPA declined to provide requested outcome data, leading the committee to conclude there was "no solid evidence to support HIMS's claims of success."^[3]

The HIMS program has historically been administered through the FAA's Medical Specialties Division within the Office of Aerospace Medicine, with ALPA serving as contractor for program operations. The following personnel have been identified through review of publicly available program documents, metadata, news coverage, and official correspondence as of January 2026. Document metadata identifies authors but does not indicate medical, clinical, or addiction medicine credentials for non-physician personnel; reform advocates have questioned whether policy documents affecting pilots' careers should be subject to clinical review.^[47][48] This represents a snapshot based on discernible public records; the National Academies documented that the program "did not really want to have a lot of scrutiny,"^[5] and the full scope of personnel, decision-making processes, and organizational relationships within this system—which declined to provide data to congressionally-mandated researchers^[1]—may not be reflected in available documentation.

Dr. Susan Northrup has served asFederal Air Surgeon since 2019. In June 2021, Northrup characterized HIMS as having an "incredible success rate" and stated that approximately 12,000 pilots had been returned to flying under program supervision since inception, with roughly 3,000 individuals then in monitoring.^[2] Northrup observed that prior to HIMS, "a pilot with a diagnosis of a substance abuse or addiction was done. They didn't go back to flying."^[2] The success rate Northrup cited was among the claims the National Academies found "could not be substantiated" two years later.^[3]

Penny M. Giovanetti, D.O. served as Director of the Medical Specialties Division. In a September 8, 2020 letter to HIMS stakeholders, Giovanetti announced the retirement of Dr. Mike Berry and described the FAA's commitment to "maintaining our program as the gold standard for the world."^[49]

Dr. Mike Berry retired from the FAA on September 30, 2020. In a letter announcing the retirement, Giovanetti wrote that she "cannot begin to describe the void his departure will create."^[49] Berry had served during a period when the program operated under an informal cooperative structure with no external oversight;^[27] the 2023 National Academies study was the first external review in the program's 49-year history, and its chair observed that HIMS "did not really want to have a lot of scrutiny."^[3][5] The program's operations involve federal funds flowing to ALPA under contract,^[1][50] fees charged to participants by commercial HIMS AME practices,^[24][23] and a network of only 48 certified HIMS AMEs handling the majority of cases nationwide.^[24]

Judith Frazier has served as a key FAA staff member responsible for HIMS policy documentation, authoring the Phase Reset and Step-Down Plan guidance memoranda that govern monitoring timelines.^[10] The FAA does not publicly disclose its policy-making procedures for HIMS guidance.

Dr. Don Hudson authored a 2004 article in ALPA'sAir Line Pilot magazine documenting the program's claimed 85 to 90 percent success rate, which he attributed to data from approximately 1,200 pilots monitored between 1974 and 1984.^[15] These early-era statistics have been cited by program stakeholders for decades without subsequent independent verification; the National Academies noted that the figures "originated from ALPA's own reporting dating to the 1980s."^[51][30]

Capt. Chris Storbeck served as chairman of the ALPA National HIMS Committee and authored the program's core policy documents, including the HIMS Monitor Guidelines (2012), HIMS Chairman Guidelines (2012), Recovery Contract template (2021), and Last Chance Agreement template (2021).^{[6][7][19][8]} These documents establish the "coerced sobriety" model, instruct monitors to "achieve and maintain leverage over the individual" and to "protect the program, not the pilot," and state that it is "not necessary to validate sources" before acting on reports about pilot behavior.^[6][7]

Jill Smith authored the Pre-Special Issuance Process Diagram (2019) that defines program entry points including spouse referral, "layover/peer concerns," and company referral.^[11]

Brandi Williamson is identified in document metadata as author of the FAA Mental Health Aviation Rulemaking Committee Final Report (April 2024), which published an unverified "~85% relapse free" claim ten months after the National Academies found such claims could not be substantiated.^[52] The FAA has not publicly explained why it continued publishing unverified statistics after the National Academies finding.

Dr. Ian Blair Fries is a Senior FAA HIMS Aviation Medical Examiner who serves as Chairman of theAOPA Board of Aviation Medical Advisors, on the FAA/ALPA HIMS Advisory Board, and as aviation medical consultant for theTeamsters Airline Division.^[53][54] Fries has presented on "HIMS: The Standard of Care and Legal Liability" at theLawyer-Pilots Bar Association.^[54] In June 2025, a Florida jury awarded $513,000 to a pilot after Fries erroneously attributed another pilot's positive PEth blood test result to him—the first known jury verdict against a HIMS AME (seeMcKeon v. Fries).^[22][55] In February 2024—eight months after the National Academies found HIMS success claims "could not be substantiated"—Fries presented a poster atEmbry–Riddle Aeronautical University's National Training Aircraft Symposium asserting that "The HIMS Program is extremely successful with about 85 percent of pilots who participate recovering and returning to the cockpit" and proposing to expand the HIMS model to mental health under a program he titled "Aviation Mental Health," with group meetings, sponsors, random testing, and a framework "[p]arallel to Alcoholics Anonymous 12 steps" requiring pilots to "honestly acknowledge they have a mental condition," "provide apologies and then assist others with mental conditions."^[56] As of February 2026, Fries remained listed as an active HIMS AME on the FAA's directory.^[57]

"If you threaten a pilot with taking away his wings, it's like threatening a doctor with taking away his stethoscope. That's a lot of leverage," explained Dr. Lynn Hankes, who ran an addiction treatment center treating pilots through HIMS, in a 2017 CBS News interview.^[29] Program officials have credited this leverage-based approach with producing favorable outcomes: official materials claim a nine-to-one return on investment for every dollar spent on treatment, with 85 percent long-term abstinence rates, but these claims have never been independently verified.^[58][3]

These claims appear in official program documents. A December 2013 HIMS Executive Summary claimed thatUnited Airlines had calculated a "$16.95 return for every dollar" invested in the program, while citing aUnited States Department of Labor range of "$5 to $16" return on investment for workplace substance abuse programs generally.^[59] The same summary reported "well over 5,000 pilots" had participated in the program with claimed "85 to 90 percent" long-term abstinence rates.^[59]

Hankes acknowledged that the program's success rates cannot be replicated in the general public because "we don't have the leverage," explaining: "If they want to get back to the cockpit or the operating room, they gotta jump through the hoops."^[29]

This leverage-based philosophy is codified in the official ALPA HIMS guidelines authored by Capt. Chris Storbeck.^[6][7] The guidelines explicitly describe the program's coercive dynamic, stating that the goal is to move a pilot from "coerced sobriety" to "choosing abstinence," while instructing HIMS monitors to "achieve and maintain leverage over the individual." The guidelines do not include clinical methodology for this transition or citations to peer-reviewed research.^[6]

Critics have argued that this leverage model creates perverse incentives that may compromise aviation safety culture. InPetitt v. Delta Air Lines, Administrative Law Judge Scott Morris ruled it "improper for [Delta] to weaponize this process for the purposes of obtaining blind compliance by its pilots due to fear that Respondent can ruin their career by such cavalier use of this tool of last resort."^[9] Aviation attorneys have characterized the system as enabling airlines to use psychiatric evaluations as "an HR backboard and litigation shield" to manage pilots who raise safety concerns.^[60]

Despite these criticisms and the economic claims made by program stakeholders, the underlying data for ROI calculations and success rate claims was never made available for independent verification. When Congress mandated review in 2018, neither the FAA nor ALPA provided the requested outcome data to the National Academies study committee, which ultimately found the claims unverifiable.^[3][30]

Program materials consistently frame HIMS against a pre-1974 baseline. The FAA's 2024 Mental Health Aviation Rulemaking Committee presentation stated: "Prior to 1974 – permanent grounding for substance dependence – no exceptions."^[52] Critics argue this creates a false binary—either accept HIMS exactly as structured, or face permanent career death—that discourages questions about program effectiveness, due process protections, or alternative models. Critics contend this framing enables the program to demand gratitude rather than accountability, suppresses pilot complaints about surveillance or rights waivers, and deflects requests for data transparency.^[3]

Despite the FAA's and ALPA's refusal to provide data for independent verification, program stakeholders continued to publicly assert high success rates. The FAA, ALPA, HIMS AMEs, and aviation industry publications consistently cited approximately 85 to 90 percent long-term sobriety rates, figures that appeared on the official HIMS program website and in peer-reviewed literature dating to the 1990s.^[61][51] These figures originated from ALPA's own reporting dating to the 1980s, with program officials stating that "85 to 90 percent will have remained sober at the two-year mark."^[51] However, the National Academies noted that without access to the underlying data, the committee could not "resolve questions that arose during the study about the quality of HIMS data and data systems."^[30]

Despite the National Academies' June 2023 finding that HIMS success claims "could not be substantiated," the FAA continued publishing the 85 percent figure in official documents. The Mental Health Aviation Rulemaking Committee Final Report, released in April 2024—ten months after the National Academies report—included a slide stating "HIMS Program • Success story • ~85% relapse free" with no citation.^[52] Document metadata identifies Brandi Williamson as the author.^[52]

The same year, Dr. Ian Blair Fries—a Senior HIMS AME who would later be found liable for $513,000 in negligence (seeMcKeon v. Fries)—presented an academic poster atEmbry–Riddle Aeronautical University asserting that HIMS "is extremely successful with about 85 percent of pilots who participate recovering and returning to the cockpit" and proposing to expand the model to mental health, with a framework "[p]arallel to Alcoholics Anonymous 12 steps" requiring pilots to "honestly acknowledge they have a mental condition" and "provide apologies."^[56]

The National Academies also identified a significant gap between program participation and estimated need: HIMS treats roughly 1.5 percent of pilots, while published research literature suggests 13 to 15 percent of pilots may have a substance use disorder. The study attributed this gap in part to pilots' reluctance to disclose conditions due to concerns about career consequences, a finding later echoed by the FAA's own Mental Health Aviation Rulemaking Committee, which identified fear of certificate loss as "the most prevalent and serious barrier" to pilots seeking treatment.^[3][31]

The National Academies reported that without access to the underlying HIMS database, the committee could not verify program statistics.^[3] This affects not just the 85 percent success claim but all program statistics cited by stakeholders—including total participants, current enrollment, entry point percentages, testing budgets, and demographic breakdowns.^[30]

These statistics circulate among FAA, ALPA, HIMS AMEs, treatment centers, and international programs as mutual citations without external validation. For example, HIMS Australia cites "12,000 pilots in the US have remained employed following AOD issues" and "approximately 2,000 pilots are currently in the system" and "23% of all pilots in the US HIMS Program come from DUIs" and "the FAA spends $60 million USD on testing 10% of their pilots for alcohol and 25% of their pilots for other drugs"—but provides no verifiable source for these figures.^[62] Similarly, the FAA's 2024 Mental Health ARC Report claims "522 pilots flying while taking SSRI antidepressants" and "2,996 pilots flying with history of substance dependence"—but if the FAA would not share data with the National Academies, the provenance of these statistics remains unclear.^[52]

This creates what critics characterize as a closed loop of unverified claims: statistics circulate among FAA, ALPA, airline HIMS committees, HIMS AMEs, treatment centers, and international programs as mutual citations—with no independent verification at any point.^[3]

Beyond the data transparency concerns, the coercion model Hankes described is not unique to aviation. Similar concerns have been raised about state-runphysician health programs (PHPs) that monitor healthcare workers for substance use disorders. In October 2025, a physician and ten nurses filed a federal class action lawsuit against Montana's monitoring program contractor, Maximus, alleging "punitive, expensive, and clinically unwarranted" practices including excessive monitoring, costly tests not clinically indicated, and lack of meaningful appeals. The lawsuit also alleged that one program participant died by suicide in January 2025 and that the contractor did not appropriately report the incident.^[63] A 2022 study in theAmerican Journal on Addictions found that while 85 percent of physicians viewed their PHP experience favorably five years after completing it, out-of-pocket costs ranged from $250 to $321,000.^[64]

According to the HIMS program website, "PHPs grew out of the HIMS programs and both look to the other to adopt better strategies for maintaining long-term sobriety."^[13] Dr. Hankes, who explained HIMS's reliance on coercive leverage in the CBS interview, also served as president of the Federation of State Physician Health Programs.^[29]

Only 48 of approximately 2,500 Aviation Medical Examiners nationwide handle the majority of HIMS cases, creating limited access to the program particularly for pilots in rural areas.^[24][70][42] As of 2019, only 204 AMEs were certified as HIMS AMEs.^[24]

Pilots who complete HIMS evaluation and enter monitoring must obtain an Authorization for Special Issuance of a Medical Certificate under14 CFR § 67.401, which permits the FAA to impose conditions or limitations on medical certification. This special issuance status remains in effect for the duration of the pilot's participation in HIMS monitoring—effectively for the remainder of their flying career under current policy.^[12][42]

Once assigned a HIMS AME, pilots have limited ability to change providers. FAA policy requires pilots to remain with the same HIMS AME for at least seven years, with the stated purpose of providing "continuity and familiarity" and preventing pilots from "doctor shopping."^[12][42] Transferring requires formal FAA approval and, in some cases, approval from the Federal Air Surgeon.^[68][42]

Beyond these provider restrictions, the program's administrative structure involves federal contracting. ALPA administers HIMS under an FAA contract. Other Transaction Agreement 693KA9-20-H-00004, executed September 22, 2020, provides $530,632.07 to ALPA for program services.^[1] When the National Academies committee reviewed this contract in December 2022, it noted that "the FAA owned the data, not ALPA," yet the FAA still declined to provide full data access to the congressionally mandated study.^[1] The program is classified underNAICS code 813319, "Other Social Advocacy Organizations—Substance abuse prevention advocacy organizations."^[50] Contract requirements include conducting annual basic and advanced educational seminars, maintaining the HIMS tracking database and website, and providing program management support.^[50] The contract mandates formation of an Advisory Board composed of "representatives from the Airline Industry, the Air Line Pilots Association and a HIMS AME" to monitor progress and provide program guidance.^[50]

Pilots can be referred to HIMS through spouse referral, "layover/peer concerns," or company referral without formal due process protections.^[11] HIMS program documentation identifies multiple entry points:^[11]

• Spouse referral
• Layover/peer concerns
• Self-report/HIMS AME involvement
• DUI/Legal issues
• Company referral
• Drug/alcohol test failure
• Work/training issue

Critics have raised concerns that several of these entry points can be weaponized without due process protections. A spouse, ex-spouse, or domestic partner could make referrals during custody disputes or divorce proceedings. Coworkers could make anonymous reports based on personal grudges, competition for captain upgrades, or union politics. Company management could use referrals as retaliation for grievances, whistleblowing, or union activity.^[9][60]

Reform advocates have noted that program documentation does not specify investigation standards, burden of proof requirements, or appeal processes before HIMS entry is initiated.^[11][47][48] Pilots for HIMS Reform has called for "clear entry and exit criteria, free from secrecy or subjectivity" and "real appeal options, whistleblower protections, and accountability."^[47]

Program documentation makes no meaningful distinction between a pilot caught flying while intoxicated (who may face criminal charges) and a pilot who voluntarily seeks help through an employee assistance program before any incident occurs. Both face essentially identical HIMS requirements: minimum seven years of monitoring, lifetime special issuance medical certification, daily testing requirements, mandatory AA attendance, Last Chance Agreements waiving grievance rights, and permanent disclosure obligations.^[11][12][8] Critics argue this lack of differentiation actively discourages voluntary disclosure, as pilots who proactively seek treatment face the same career-long consequences as those caught in violations—eliminating any incentive to self-report before an incident occurs.^[31]

Program documents do not explain the surveillance mechanism by which "layover/peer concerns" are identified or reported. HIMS Chairman Chris Storbeck wrote in ALPA guidance documents that he "was informed of a relapsed pilot who was 'holed up' in a layover hotel, had called in sick, and had been drinking for 4 days,"^[7] but the document never explains how this information was obtained or what reporting channels exist for monitoring pilot behavior during off-duty layover periods.

The FAA describes HIMS as "an effective program that allows safety-sensitive employees to return to work in a safe and structured manner."^[26] ALPA has cited the program's return-to-duty success rates in congressional testimony and public statements, presenting HIMS as a cornerstone of aviation safety policy.^[71][72] Federal Air Surgeon Dr. Susan Northrup has characterized the program as having an "incredible success rate," citing approximately 12,000 pilots returned to flying since inception.^[2]

Industry stakeholders have defended the program's structure as necessary for aviation safety.Airlines for America, the trade association representing major U.S. airlines, has endorsed the Mental Health in Aviation Act as part of comprehensive aviation safety programs.^[73] TheNational Business Aviation Association has endorsed structured return-to-duty programs, and the program has received support in congressional testimony from both labor and management representatives.^[73] Proponents argue that the monitoring requirements, while demanding, provide accountability that benefits both pilots in recovery and public safety.^[71]

The FAA's 2024 Mental Health Aviation Rulemaking Committee, while recommending reforms to address barriers to treatment-seeking, affirmed the value of structured return-to-duty programs for aviation professionals with substance use disorders. The committee's recommendations focused on reducing stigma and improving access rather than eliminating monitoring requirements.^[31]

A 2022 study in theAmerican Journal on Addictions examining physician health programs—which share structural similarities with HIMS—found that 85 percent of physicians viewed their monitoring experience favorably five years after completing it, suggesting that participants may ultimately value the structure even when finding it burdensome during participation.^[64]

Standard program requirements typically include:

• Initial evaluation and treatment, often including inpatient rehabilitation
• Regular attendance at peer support meetings (traditionallyAlcoholics Anonymous)
• Ongoing psychiatric and psychological evaluations
• Random drug and alcohol testing (typically 14 tests per 12-month period)
• Quarterly meetings with a HIMS AME
• Monthly meetings with peer and company sponsors^[70]

A federal Administrative Law Judge ruled in 2022 that Delta Air Lines had "weaponized" psychiatric evaluations against a pilot whistleblower, finding it "improper for [Delta] to weaponize this process for the purposes of obtaining blind compliance by its pilots" and ordering the airline to pay $500,000 in damages.^[9] The National Academies noted that HIMS implementation is "highly decentralized," with individual airlines and unions having "considerable autonomy in how they carry out the expectations of the program."^[42] The risks of this decentralized structure were illustrated inMcKeon v. Fries (2025), where a single HIMS AME monitoring multiple pilots simultaneously misattributed one pilot's positive PEth blood test to another, resulting in years of wrongful grounding and a $513,000 jury verdict (seeMcKeon v. Fries).^[22]

The Delta whistleblower case that prompted the ALJ's "weaponized" finding involved Karlene Petitt, a Delta pilot with a doctorate in aviation safety fromEmbry–Riddle Aeronautical University, who raised safety concerns about pilot fatigue, training records, and FAA compliance issues.^[9][74] The case resulted in Delta being ordered to publish the court's findings to all 13,500 of its pilots.^[75] Dr. Petitt's attorney, who has represented over 50 aviation industry whistleblowers, described Delta's conduct as "Soviet-style psychiatric examination" used to silence safety concerns.^[9]

The Delta executive who approved the psychiatric referral, Stephen Dickson, was subsequently nominated by PresidentDonald Trump to serve asFAA Administrator. SenatorMaria Cantwell (D-WA) opposed his confirmation, citing the Petitt case as evidence of problems with airline safety culture.^[76] Dickson was confirmed 52-40 but resigned as FAA Administrator in March 2022, several months before the Department of Labor's Administrative Review Board affirmed the ruling against Delta in August 2022.^[9] Despite the ruling, Delta did not discipline the employees identified by Judge Morris as responsible for the unlawful retaliation. Jim Graham, then vice president of flight operations whom the judge described as exhibiting testimony "of dubious credibility," was promoted in October 2020 to CEO ofEndeavor Air (Delta's regional carrier subsidiary) and senior vice president of Delta Connection.^[9] According to Dr. Petitt's attorneys, Kelley Nabors, the human resources representative whose report facilitated the retaliatory psychiatric referral, was promoted to Delta's Salt Lake City HR manager.^[75]

HIMS peer monitor reports are "not expected to meet clinical standards, but rather [are] a layman's report on the behavior of the HIMS pilot," according to official program guidance, yet these reports are included in FAA certification packages that determine pilots' careers.^[13][42] According to the official HIMS program website, the program acknowledges "much subjectivity in the monitoring of pilots in recovery" and identifies peer pilots as "the most critical component of the subjective monitoring process."^[13][42] Official ALPA training materials explicitly state peer reports are "Not a Medical Diagnosis / Assessment."^[16] At a 2003 HIMS seminar, Captain Chris Storbeck, then-chairman of the Delta Pilots Assistance Committee, instructed peer pilot committee members to "trust their intuition when involved in identifying cases of substance abuse."^[15]

Official HIMS monitor guidelines, authored by Storbeck for ALPA, describe the program's explicit goal as moving a pilot from "coerced sobriety" to "choosing abstinence."^[6] The guidelines instruct monitors to "protect the program, not the pilot" and require monitors to report any behavior they consider "at risk," with such reports flowing directly to airline management, the HIMS AME, and ultimately to the FAA.^[6] Monitors are directed to assess whether pilots are genuinely engaged in recovery or merely complying to preserve employment—distinguishing between those "playing the game" versus "walking the walk"—and are explicitly told that union "fraternal bonds" should not protect pilots from program consequences.^[6] The HIMS chairman guidelines similarly emphasize that the program's role is to "achieve and maintain leverage over the individual" and characterize "addictive disease behavior" as including "hiding facts, providing miss-information [sic], and manipulation of data"—framing participants as inherently unreliable based on their diagnosis.^[7]

The chairman guidelines also instruct HIMS chairmen that when receiving information about pilot behavior from concerned parties, "It is not necessary to validate sources" before taking action—meaning reports from anonymous sources, coworkers with grudges, or parties with conflicts of interest may trigger program interventions without verification.^[7]

The program guidance explicitly states that "the peer pilot cannot provide privacy, privilege, or anonymity to the HIMS pilot" and that peers have "a responsibility to communicate with other people involved in the pilot's recovery including the pilot's supervisor and the HIMS AME."^[13] The National Academies confirmed that these peer reports are "included in the pilot's submission package for Special Issuance" to the FAA.^[42]

Critics have raised concerns that this structure—in which subjective, non-clinical peer assessments based on "intuition" flow directly into FAA certification decisions without apparent mechanism for pilot review or challenge—creates potential for abuse, particularly given the National Academies' finding that airlines "often maintain the managerial functions" of HIMS monitoring for their own pilots.^[42]

These monitoring guidelines operate in conjunction with "Last Chance Agreements" that require pilots to waive union grievance rights and stipulate that "any violation of this Agreement will result in your discharge, and your discharge must stand."^[8]

The FAA's official HIMS training curriculum includes instruction on "Contracts and Last Chance Agreements" as part of the advanced seminar for aviation medical examiners, psychiatrists, psychologists, pilots, and airline management.^[50]

The Last Chance Agreement template specifies seven explicit termination triggers:^[8]

1. Failure to maintain complete abstinence from alcohol, drugs, or any other intoxicating substance
2. Any failure to perform any of the agreed-upon terms
3. Any positive test for alcohol, drugs, or any other intoxicating substance
4. Any failure to inform the new Chief Pilot of recovering pilot status upon transfer
5. Unauthorized or unsubstantiated absences (during first two years)
6. Any violation of any restrictions associated with the Medical Certificate
7. Any failure to submit to testing, or any positive test

The agreement further requires pilots to disclose their status permanently: "You will inform your new Chief Pilot that you are a recovering pilot and your status as of that date."^[8]

Similarly, "Recovery Contracts" require pilots to present for random EtG, PEth, and drug testing within a four-hour window of notification, attend daily Alcoholics Anonymous meetings for the first three months followed by twelve meetings per month thereafter, and acknowledge that "noncompliance with any term of this contract may result in termination."^[19] The FAA's Step Down Plan memorandum further specifies that pilots must maintain "permanent abstinence from alcohol for the duration of [their] flying career" and that any relapse resets the monitoring clock to zero, with "requests for early Step Down" explicitly prohibited.^[12]

Aviation safety experts have noted that a punitive or fear-based environment undermines safety reporting. TheFlight Safety Foundation has stated that "accidents will be prevented and further improvements in aviation safety will be gained if people, particularly pilots, are protected from punitive action."^[77] Aviation attorney Lee Seham, who has represented approximately 50 to 60 aviation industry whistleblowers, characterized psychiatric evaluation processes used against pilots as "Soviet-style" and warned: "You can't have a safe airline if pilots are afraid."^[9]

The Recovery Contract template authored by Chris Storbeck and dated April 12, 2021 includes the requirement: "If my Aftercare Team decides I should acquire and carry abeeper to notify me of required testing I will do so."^[19] Other program documentation requires participants to use Soberlink devices with "facial recognition and cellular transmission technology."^[13]

Key HIMS policy documents governing pilot monitoring, treatment requirements, and career consequences were authored by individuals with no documented medical, clinical, or addiction medicine credentials indicated in the documents (seeKey program personnel). The documents contain no indication of clinical peer review or formal validation procedures.

Reform advocates have raised concerns about this structure. Pilots for HIMS Reform, an advocacy organization, states that "medical decisions should be explainable, reviewable, and rooted in evidence" and calls for "oversight of AMEs and providers by neutral parties—not insiders."^[47] The FAA HIMS Program Information Center, an independent resource, notes that "FAA medical consultants operate behind closed doors" and that advocates seek "updated policies that reflect modern addiction science, relapse risk assessments, and peer-reviewed data."^[48]

The National Academies noted that without access to outcome data, it could not evaluate whether program practices are evidence-based or effective.^[3]

Peer monitors and employers are notcovered entities under theHealth Insurance Portability and Accountability Act (HIPAA), meaning health information shared with them lacks federal privacy protection.^[78] Employment records are explicitly excluded from HIPAA's protections.^[79]

Collective bargaining agreements govern aspects of HIMS program structure at unionized carriers, but these vary by airline. The National Academies noted that individual airlines and unions have "considerable autonomy in how they carry out the expectations of the program," resulting in differing monitoring requirements, appeal procedures, and protections across carriers.^[42] Pilots must comply with airline-determined monitoring requirements—including who conducts evaluations, when and where testing occurs, and how long monitoring continues—with limited ability to refuse or negotiate terms while remaining employed.^[70][42]

The FAA and ALPA refused to provide HIMS outcome data to congressionally-mandated researchers despite Section 554 of the FAA Reauthorization Act of 2018 requiring independent evaluation.^[1] The National Academies found that "(1) the lack of information made available to the committee... would limit the ability of the committee to execute the charge; (2) what information was available to the committee created uncertainty regarding the claims about the success of the programs."^[81]

Appendix C of the National Academies report reproduces the complete chronology of communications between the committee and FAA, HIMS, ALPA, and congressional staff documenting the refusals:^[1]

• On April 27, 2022, the HIMS Program Manager initially offered to share queries and results from the HIMS database and set up a confidentiality data-sharing agreement, but no response was provided to the committee.
• On November 3, 2022, the committee requested data from the FAA-funded HIMS database. The HIMS Advisory Board denied access, "asserting the contract with the FAA and concerns over confidentiality and data disclosure might erode program integrity."
• On November 9, 2022, the committee again requested access to the HIMS database. ALPA "asserted the contract with HIMS restricted access to the database."
• On December 2, 2022, the committee requested custom language so ALPA could run queries by their staff to assuage confidentiality concerns. ALPA "asserted sophisticated searches may not result in accurate or reliable results." No data was received.
• On December 6, 2022, Senator Shaheen's staff contacted ALPA representatives to allow the committee access to HIMS data. ALPA "asserted that lack of standardized data might lead to inaccurate results and negatively affect analysis."
• On December 14, 2022, the committee and Senator Shaheen's office received a copy of the FAA-ALPA contract for HIMS.
• On December 15, 2022, after review of the contract, the committee noted that "the FAA owned the data, not ALPA," and indicated that access to the data would assist the National Academies to fulfill the congressional mandate.
• On December 21, 2022, the FAA "noted that full access would not be provided" and offered to make available aggregate data related to HIMS.
• On January 30, 2023, the committee asserted its request for HIMS data. Data was not received.
• On February 3, 2023, Senator Shaheen's staff noted the lack of cooperation and access to the data and would inform future possible actions with regard to the HIMS database.

The study noted: "Those aggregate data were never delivered."^[30][1]

FAA contract documents confirm the agency's control over program data. The 2025 contract solicitation for HIMS program services specifies that "The FAA will retain access and ownership of all data belonging to the HIMS Tracking Database upon the expiration or termination of this contract."^[50] The solicitation describes the database purpose as quantifying "the overall effectiveness of the HIMS program, monitor relapses, identify possible risk factors for treatment failures and provide guidance to HIMS-trained professionals on how to improve their program structure to address weaknesses."^[50]

The study further noted that "the committee never received indications that HIMS and its administering organization, Air Line Pilots Association–International (ALPA), ever distributed the link or sought pilot participation" in the study's data collection efforts. The committee's "Call for Perspectives" tool received just nine responses from pilots, compared with over 1,000 from flight attendants.^[3]

The committee also commissioned a qualitative interview study, conducted by clinical psychologist Jennifer Wisdom, PhD, Director of Research at CODA, Inc., a Portland, Oregon substance use treatment program.^[82] Of 36 individuals interviewed, 35 were flight attendants and one was a pilot.^[30] The sole pilot interviewed was in his twenties with less than five years of industry experience, employed at a regional carrier, rated his familiarity with HIMS as two on a scale of one to five, and reported no personal experience with a substance use disorder—meaning the qualitative dataset contained no firsthand accounts from actual HIMS pilot participants.^[82] The commissioned paper noted that data "from a very few pilots are not reported separately here to preserve anonymity."^[82]

The National Academies highlighted that this participation gap has policy implications, noting that HIMS's own internal estimates suggested 8 to 12 percent of pilots may have substance use disorders—figures the committee observed were still "lower than the 13 to 15 percent derived from the research literature." The committee concluded: "The troubling implication of this is that the FAA and Congress have limited visibility of the degree to which pilots with substance misuse problems are being treated."^[81]

The study also found that existing screening procedures yielded low identification rates: "existing screenings are yielding rates of 0.5 percent from aviation medical examiners (AME's) annual examinations, when general screening rates are typically greater than 14 percent."^[81]

Despite apparently collecting HIMS case data through electronic systems available to HIMS AMEs since at least April 2011, the FAA does not publish aggregated HIMS program outcome statistics in any publicly accessible format.^[24][83] The 2023 National Academies study documented that neither the FAA nor ALPA provided comprehensive outcome data for evaluation despite the congressional mandate to conduct an independent review.^[3]

Some commercial HIMS AME practices have published statistics claiming to derive from FAA data sources. Kansas Aviation Medicine, a private HIMS AME practice, states on its website that FAA data from April 2011 through October 2019 shows 1,162 individual first-class certificate holders involved in HIMS, with an 85 percent sustained abstinence rate, 12.7 percent experiencing a single relapse, and 3 percent experiencing two or more relapses.^[24] However, no citation to any publicly accessible FAA publication or database is provided, and these statistics cannot be independently verified through any public FAA resource.^[83]

Multiple other commercial HIMS AME practices publish similar statistics without independent verification:

• Center for Family Medicine (South Dakota): "85% of participants achieving and maintaining sobriety"^[84]
• Martin Diagnostic Clinic (Texas): "85% of participants achieving and maintaining sobriety"; states "This is a cash program only; health insurance will not be accepted"^[85]
• High Altitude Health and Wellness: "almost 90% success rate"^[86]
• Aviation Medical Exams of Miami: "nearly 90%"^[87]

None of these commercial practices cite verifiable sources for their statistics.

Reform advocates have noted that commercial HIMS AME practices—which have financial interests in presenting the program favorably to prospective clients—appear to access HIMS outcome data that was not provided to the congressionally mandated National Academies study committee. Kansas Aviation Medicine claims access to "FAA 2011-2019 data using a new online tool," yet the National Academies was denied access to this same data despite repeated requests. The FAA and ALPA have not publicly addressed this discrepancy.^[24][3][1]

The FAA's publicly available Aerospace Medical Certification Statistical Handbook provides counts of pilots with various medical conditions but does not include HIMS-specific outcome measures such as relapse rates, return-to-duty success rates, or long-term sobriety statistics.^[83]

The FAA requires pilots who enter HIMS to undergo monitoring for the remainder of their flying careers, with no provision for completing the program. In April 2020, the FAA formalized a "Step Down Plan" establishing five phases over a minimum of seven years, after which pilots remain in indefinite "Phase 5" monitoring until retirement or career termination.^[12]

These represent FAA minimum requirements; individual airlines may impose additional monitoring requirements as part of their company-specific HIMS programs, which vary between carriers.^[42]

However, the FAA guidance explicitly states that progression through phases is "NOT guaranteed" and represents only "nominal" and "uncomplicated" recovery, with the FAA—not the pilot's HIMS AME—retaining final authority on tier advancement.^[12] The Step Down Plan memorandum implementing this structure was addressed only to Aviation Medical Examiners and Regional Flight Surgeons rather than to pilots themselves.^[12] Aviation attorneys have characterized the step-down provisions as largely theoretical rather than practical. Critics argue lifetime monitoring disincentivizes pilots from voluntarily seeking treatment, as disclosure results in permanent FAA oversight regardless of recovery duration or severity of initial diagnosis.^[60]

A single compliance failure at any point—even after years of successful monitoring—resets the monitoring timeline to zero. FAA guidance authored by Judith Frazier states: "If the pilot relapses or there is a withdrawal of authorization at ANY TIME, the Time-in-Phase start date is re-set to the date any NEW Special Issuance authorization is granted."^[10] For example, under this policy a pilot in year six of monitoring who experiences a single compliance issue would restart the minimum seven-year process from the beginning.^[10]

HIMS requires pilots to "attend meetings of Alcoholics Anonymous (AA)/Narcotics Anonymous (NA) on a daily basis for at least three months and a minimum of 12 times per month thereafter," with official ALPA guidelines describing peer monitoring as "AA '12th Step' work."^[19][6] This mandatory religious-based treatment model was central to the EEOC's 2022 lawsuit against United Airlines on behalf of a Buddhist pilot who sought religious accommodation.^[32]

Aviation attorneys and advocacy groups have alleged that somePart 121 carriers use HIMS referrals as what theAOPA Pilot Protection Services newsletter described as "an HR backboard and litigation shield" to manage problem employees or avoid wrongful termination claims.^[60] InTallon v. United Airlines (2025), the plaintiff alleges United saved millions in long-term disability payments by mischaracterizing his head injury as alcoholism and terminating him through the HIMS program rather than providing a medical separation.^[34] ThePetitt v. Delta Air Lines case resulted in a ruling that Delta had improperly used psychiatric evaluation processes against a pilot whistleblower.^[9]

The HIMS program website states that company supervisors maintain familiarity with participants' "on-duty performance and layover behavior," with concerns arising from non-work situations "to be taken very seriously."^[13]

Aviation attorneys and reform advocates have questioned how such monitoring is conducted and whether it conflicts with FAA rest regulations requiring pilot rest periods to be "free from all restraint by the certificate holder."^[14] Neither ALPA nor the FAA has publicly documented the specific methods used for monitoring HIMS participants during off-duty periods.

The HIMS tracking database collects data on program participants including treatment outcomes and relapses. According to FAA contract documents, the database must include "procedures to transfer current cases data from FAA consultants and FAA HIMS AMEs" with the HIMS Program Manager performing "quality review of the data entered into the HIMS Database for the purpose of evaluating trends and extracting information relevant to the HIMS Program."^[50] For privacy protection, the contract specifies that "individuals will not be identified by name in this database" and requires compliance with thePrivacy Act,HIPAA, and federal information security standards.^[50]

The HIMS program operates without an independent oversight body, and the 2023 National Academies review represented the first external examination in the program's 49-year history.^[3][1]

The FAA contracts with ALPA for program administration, ALPA maintains the participant database, and the FAA's Medical Specialties Division provides policy guidance—but no external entity reviews program operations, outcomes, or participant complaints.^[3] When researchers requested outcome data to evaluate program effectiveness as mandated by Congress, both the FAA and ALPA declined to provide it.^[1] Dr. Richard G. Frank, chair of the study committee, observed that the program "did not really want to have a lot of scrutiny."^[5]

The FAA's 2025 contract solicitation for HIMS program services confirms ongoing data collection, stating the database purpose is to quantify "the overall effectiveness of the HIMS program, monitor relapses, identify possible risk factors for treatment failures and provide guidance to HIMS-trained professionals."^[50] However, this data has never been published or made available for independent review.

No formal complaint or appeals process exists for HIMS participants who dispute monitoring decisions, testing results, or determinations by HIMS AMEs, airline management, peer monitors, or other program stakeholders.^[11][3] The entry pathway diagram published by the program shows multiple mechanisms for identifying and enrolling pilots but no corresponding pathway for participants to challenge decisions or report concerns.^[11]

Pilots can file general complaints with the FAA Safety Hotline orDOT Office of Inspector General, but no HIMS-specific ombudsman, review board, or participant advocate exists within the program structure. InCastillo v. United Airlines (2025), the plaintiff alleges retaliation for retaining legal counsel, citing a chief pilot's statement as "direct evidence."^[35][88] The National Academies noted this absence of formal accountability mechanisms but did not make specific recommendations to address it.^[3]

Several pilots have pursued litigation as their only recourse for challenging program-related decisions, includingPetitt v. Delta Air Lines (psychiatric evaluation misuse),Erwin v. FAA (certification denial),McKeon v. Fries (misattributed test results), andBarnard v. Kozarsky (HIMS AME conduct).^{[9][33][22][25]}

TheSubstance Abuse and Mental Health Services Administration (SAMHSA) has warned that EtG tests used in HIMS monitoring "should not be used as the sole basis for legal or disciplinary action" and that positive results from incidental exposure "could have devastating consequences for someone who signs an alcohol abstinence contract."^[17] Despite these warnings, the FAA requires HIMS participants to undergo a minimum of 14 urine EtG tests annually for the first four years.^[13][42]

The abstinence testing mandated by the FAA for HIMS participants is distinct fromDOT workplace testing programs and utilizes different methodologies. According to the official HIMS program, "abstinence testing mandated by the FAA is NOT DOT testing and does not count toward the employer's random testing program requirements."^[13] Testing frequency is reduced to quarterly bloodphosphatidylethanol (PEth) testing after sustained compliance.^[13]

Unlike DOT workplace testing, which requires positive results to be reviewed by a Medical Review Officer (MRO) who evaluates whether there is a legitimate medical explanation before reporting results to employers,^[89] HIMS abstinence testing results are reported directly to the HIMS AME without comparable independent medical review.^[13][42]

Pilots must present for random drug and alcohol testing within four hours of notification or face program consequences including potential phase reset or termination.^[19] The HIMS Recovery Contract requires: "I agree to be available for random blood alcohol level tests, ETG tests, PeTH tests, and/or drug screens at any time upon notice" and "I have 4 hours to complete the requested testing procedure following notification."^[19] Testing locations are designated by the program; pilots who are traveling, unreachable, or otherwise unable to present within the window may face compliance violations regardless of the reason for unavailability.^[13]

TheSubstance Abuse and Mental Health Services Administration (SAMHSA) has issued multiple advisories warning against using EtG testing as a definitive measure of alcohol consumption. A 2006 SAMHSA advisory stated that using EtG as sole evidence of drinking is "scientifically unsupportable" and "should not be used as the sole basis for legal or disciplinary action."^[90] A 2012 revision reiterated that EtG/EtS are "highly sensitive" and can produce positive results after low-level incidental exposures, recommending that positive immunoassay results be confirmed by GC/MS or LC/MS/MS before being used in any consequential decision.^[17]

According to SAMHSA, the EtG test is "fine for use in clinical settings" but "should not be used as a stand-alone test in a forensic situation where someone's job is at stake."^[17] SAMHSA specifically warned that calling such a test "positive" for consumption or relapse, especially at low concentrations, "could have devastating consequences for someone who signs an alcohol abstinence contract or is required to be abstinent by law."^[17]

The EtG urine test used in HIMS monitoring has been shown in peer-reviewed research to produce false positive results from incidental alcohol exposure. A 2014 study published inForensic Science International found that healthcare workers using alcohol-based hand sanitizer produced EtG levels exceeding clinical cutoffs even when completely abstinent from alcohol consumption, with the study concluding that "accidental ethanol inhalation can occur quite frequently in the working place" and "should always be considered when EtG is used as a marker of recent ethanol consumption."^[20] A separate 2012 study found that propanol-based hand sanitizers produced false-positive EtG immunoassay results through inhalation alone, leading the researchers to conclude that "positive EtG immunoassay results have to be controlled by mass-spectrometry."^[91]

InErwin v. FAA (2021), theD.C. Circuit considered a pilot's challenge to a positive EtG test that resulted from unknowingly consuming food prepared in beer. The pilot submitted the SAMHSA advisory as evidence supporting his claim that the positive result was from incidental exposure rather than intentional consumption; the court remanded the case to the FAA for adequate explanation of its decision.^[33]

The PEth and EtG tests used in HIMS monitoring are not FDA-verified for safety, effectiveness, or quality—classified asLaboratory Developed Tests (LDTs) exempt from premarket review.^[17][18] These tests are intended as screening tools requiring confirmatory testing, yet in HIMS they may be used as the basis for career-ending decisions without MRO review or mass spectrometry confirmation.^[17][21]

Peer-reviewed research has documented that PEth tests can produce false positive results from hand sanitizer exposure, blood transfusions, and collection methodology variations.^[21][92]

Collection methodology has been identified as a variable affecting PEth test reliability. A 2022 study inSeparations by Bashilov et al. demonstrated that dried blood spot samples exposed to alcohol vapors from disinfectants during the drying process produced positive results in abstinent individuals, with the researchers concluding that "each PEth-negative sample from a healthy male patient incubated in the presence of ethanol vapor becomes PEth-positive."^[21] DBS PEth testing is not FDA-approved.^[17][18] United States Drug Testing Laboratories (USDTL) has stated that it is the only commercial laboratory conducting dried blood spot PEth testing, noting on its website: "There are no other labs that do commercial dried blood spot PEth testing, so there are no labs for comparison."^[18] In July 2025, Dr. Karlene Petitt—the Delta Air Lines captain who prevailed in thePetitt v. Delta Air Lines whistleblower case—published a study reporting that 10 of 20 dried blood spot samples from a single abstinent subject produced positive PEth results depending on collection methodology; the study was published in theJournal of Biomedical Science and Engineering, a journal whose publisher (Scientific Research Publishing) has been identified as a predatory publisher byBeall's List andCabells' Predatory Reports (seeFurther reading).^[93]

The question of whether PEth false positives could occur in completely abstinent individuals was central to theDanford arbitration (2021), in which the arbitrator acknowledged "we can never be certain whether or not Danford was abstinent and simply had some false positives" (seeDanford arbitration (2021) below).^[94] At the time of the arbitration, no peer-reviewed literature documented PEth false positives in abstinent subjects. Subsequent peer-reviewed research confirmed multiple mechanisms for false positive results, including alcohol vapor exposure during sample drying^[21] and red blood cell transfusions.^[92] Dr. Petitt acknowledged Danford in her 2025 study "for shining light on false positive results," noting that his termination had been based in part on the arbitrator's finding that no such literature existed at that time.^[93]

A 2023 study inClinical Biochemistry by researchers atMayo Clinic documented that packed red blood cell transfusions can artificially elevate PEth to concentrations associated with moderate alcohol consumption in patients who tested negative prior to transfusion. The case study demonstrated PEth rising from undetectable levels (<10 ng/mL) to 57 ng/mL after transfusion of four packed red blood cell units, with researchers concluding that "pRBC transfusion can artificially elevate PEth into clinically and forensically relevant ranges."^[92]

According to HIMS program documentation, participants must submit to breath testing "several times a day on a daily basis" using facial recognition devices that transmit results via cellular network.^[13][42] Research protocols specify testing four times daily: upon arising, after lunch, after dinner, and before bedtime.^[95]

Testing is required during both on-duty and off-duty time. The devices require cellular connectivity to transmit results, creating geographic limitations for pilots in remote areas without reliable cellular coverage; however, the devices can store tests when connectivity is unavailable and upload them when a connection is restored.^[96][95]

Under the FAA's lifetime monitoring policy implemented in 2020, pilots may be required to maintain daily breath testing for the duration of their flying careers, regardless of years of demonstrated abstinence or the severity of their initial diagnosis.^[13][12]

HIMS participation costs pilots $8,000 to $15,000 in the first year alone, with some HIMS AME practices requiring cash payment only and refusing health insurance.^[23][24] Pilots who work for airlines without active HIMS programs, or who are self-employed, must fund the entire process themselves.^[97] The AOPA Pilot Protection Services newsletter characterized the HIMS process as "time consuming and expensive," noting that monitoring can last five to seven years.^[70]

Pilot advocacy groups have raised concerns about overcharging in a market with limited provider options. Some HIMS AMEs have been reported to charge $500 to $600 per hour for consultations.^[23] A 2023Department of Transportation Office of Inspector General report noted that pilots may experience "financial hardship if FAA's approval process extends beyond the pilot's prescribed disability benefit period."^[98] A 2025Reuters investigation found that when pilots are grounded, "the financial fallout can be significant" as they are "often placed on disability, which can significantly reduce their income."^[38]

"Fear of temporary or permanent certificate/clearance loss is the most prevalent and serious barrier" preventing aviation professionals from seeking mental health treatment, according to the FAA's own Mental Health Aviation Rulemaking Committee in April 2024.^[31] This fear has been linked to pilot suicides, including 19-year-old John Hauser, a University of North Dakota aviation student who intentionally crashed his training aircraft after writing in his suicide note: "If you can do anything for me, try to change the FAA rules so that other young pilots don't have to go through what I went through."^[37] Hauser's parents, both physicians with psychiatric training, said they had no indication their son was depressed. His death became a catalyst for the Mental Health in Aviation Act, with his parents testifying before Congress.^[99]

A December 2025 Reuters investigation found that commercial airline pilots "often conceal mental health conditions for fear that disclosing therapy or medication, or even just seeking help, could mean having their license pulled." The investigation cited Delta pilot Brian Wittke, a 41-year-old father of three who died by suicide in June 2022 after refusing treatment because he was "terrified that getting treatment for depression would cost him his license and livelihood." Delta called Wittke's death "tragic and heartbreaking" and acknowledged stigma within the pilot community against seeking mental health services.^[38]

The Reuters investigation also documented the case of pilot Troy Merritt, a 33-year-old commercial airline pilot who voluntarily grounded himself in December 2022 for depression and anxiety. Merritt told Reuters the recertification process cost him approximately $11,000 out-of-pocket for psychological and cognitive tests not covered by health insurance, and he was grounded for 18 months while living on disability insurance.^[38] A 2023 study of more than 5,000 U.S. and Canadian pilots found that over half said they avoided healthcare due to concerns about losing flying status, a phenomenon encapsulated in the industry maxim: "If you aren't lying, you aren't flying."^[38]

The House of Representatives unanimously passed the Mental Health in Aviation Act (H.R. 2591) in September 2025, requiring the FAA to implement recommendations from its own Mental Health Aviation Rulemaking Committee within two years.^[36][73] The bill received endorsements from ALPA,Airlines for America, theNational Air Traffic Controllers Association, and theNational Business Aviation Association.^[73]

In November 2025, SenatorsJohn Hoeven (R-ND) andTammy Duckworth (D-IL) introduced S.3257, the Senate companion to the Mental Health in Aviation Act. The Senate bill includes identical provisions requiring FAA implementation of rulemaking committee recommendations, annual review of mental health special issuance processes, and allocation of $15 million annually from fiscal years 2026 through 2029 for additional aviation medical examiners. The legislation has received bipartisan cosponsorship from twelve senators including Katie Britt (R-AL), Dick Durbin (D-IL), Deb Fischer (R-NE), John Hickenlooper (D-CO), Lisa Murkowski (R-AK), Amy Klobuchar (D-MN), John Curtis (R-UT), Jack Reed (D-RI), Jerry Moran (R-KS), and Andy Kim (D-NJ).^[100]

While the Mental Health in Aviation Act received broad industry support, Pilots for HIMS Reform (P4HR) has argued that the legislation does not address structural issues within the HIMS program itself. In February 2026, P4HR published a side-by-side comparison characterizing the Mental Health in Aviation Act as "The Easy Bill" and their proposed alternative—the "Pilots for HIMS Reform Act of 2026"—as "The Real Fix."^[39]

According to P4HR, while the Mental Health in Aviation Act focuses on reducing stigma and improving access to mental health care, it does not reform the HIMS monitoring system's due process deficits, testing protocols, or oversight structure—issues documented by the 2023 National Academies study.^[39][3]

Given the program's acknowledged reliance on "coercive leverage" over participants' careers^[29] and the National Academies' finding that pilots avoid disclosure due to fear of career consequences,^[3] litigation may underrepresent the scope of concerns within the program. The following cases represent legal challenges to HIMS-related practices at major airlines and against individual HIMS AMEs that have received coverage in federal and state court decisions, EEOC press releases, and major news outlets.

Delta paid psychiatrist Dr. David Altman approximately $74,000 to evaluate pilot whistleblower Karlene Petitt, who had submitted a 43-page safety report to Delta executives detailing concerns about pilot fatigue, training records, and safety management systems. Altman diagnosed her withbipolar disorder, which grounded her. However, a panel of nine physicians from theMayo Clinic's Aerospace Medicine Department unanimously concluded she did not have bipolar disorder or any psychiatric disorder. Dr. Lawrence Steinkraus of Mayo Clinic testified that Altman's diagnosis was "a puzzle for our group" and that "the evidence does not support presence of a psychiatric diagnosis but does support an organizational/corporate effort to remove this pilot from the rolls."^[9]

Altman later testified that his diagnosis was driven in part by Dr. Petitt's accomplishments, which he characterized as "well beyond what any woman I've ever met could do"—therefore suggestive she was manic.^[9]

In December 2020, Administrative Law Judge Scott Morris ruled Delta had "weaponized" the psychiatric evaluation process and awarded Dr. Petitt $500,000 in compensation—five times the highest previously recorded award under the whistleblower statute. Morris ordered Delta to prominently post copies of his decision at every pilot base.^[9] Altman forfeited his medical license in 2020 rather than face charges from theIllinois Department of Financial and Professional Regulation over his conduct in psychiatric exams of two Delta pilots.^[101] The case settled in October 2022.^[102]

The EEOC filed suit against United Airlines on behalf of a Buddhist pilot forced to attend Alcoholics Anonymous meetings—held in churches with opening prayers and acknowledgment of a "Higher Power"—to regain FAA medical certification.^[32] United denied pilot David Disbrow's request to attendRefuge Recovery, a Buddhism-based peer support group, as religious accommodation.^[103]

United refused the accommodation, and Disbrow was unable to obtain a new FAA medical certificate. In November 2022, United agreed to a consent decree paying $305,000 in back pay and damages, reinstating Disbrow into HIMS while allowing participation in a non-12-step program, and implementing policies to accept religious accommodation requests in HIMS going forward.^[32]

EEOC New York Regional Attorney Jeffrey Burstein stated: "Employers have the affirmative obligation to modify their policies to accommodate employees' religious beliefs. If they require their employees to attend AA as part of a rehabilitation program, they must make sure that they allow for alternatives for their employees who have religious objections to AA."^[32]

A commercial airline pilot tested positive on a random EtG test after eating pulled pork at a restaurant that did not disclose the dish was prepared in beer; the D.C. Circuit remanded the case after the pilot submitted SAMHSA advisory evidence that EtG should not be used as the sole basis for such decisions.^[33][17]

Erwin provided the FAA with evidence including the restaurant's confirmation, his negative follow-up tests, and a 2012 SAMHSA advisory cautioning against using EtG results as sole evidence of alcohol consumption. A toxicology expert concluded "within a reasonable degree of scientific certainty" that the positive result was from incidental exposure rather than intentional consumption. The FAA denied reconsideration without adequate explanation.^[33]

In December 2021, the U.S. Court of Appeals for the D.C. Circuit remanded the case, ruling that the FAA must provide the "why and wherefore" of its decision rather than simply asserting agency expertise. The court recognized that Erwin suffered a cognizable injury from his "poorer position in the HIMS Step Down Plan" and accompanying extended monitoring requirements resulting from the disputed test.^[33]

A United Airlines check airman with nearly 30 years of experience alleges in federal court that his head injury was mischaracterized as alcoholism, with United and ALPA pressuring him to admit to alcoholism and enter HIMS rather than providing medical treatment for his concussion.^[104]

The complaint states that despite completing a month-long inpatient program and receiving multiple evaluations finding no alcohol dependency, Tallon remained in HIMS until his termination in February 2025 for refusing further compliance. The lawsuit alleges United saved millions in long-term disability payments by terminating Tallon through the HIMS program rather than providing a medical separation for his head injury. Tallon's attorney Mike Lueder described the system as "Kafkaesque."^[34] The case is ongoing.

First Officer Michael Danford, a Delta pilot and U.S. Naval Academy graduate with 18 years at Delta, was terminated in 2018 after disputing a positive PEth alcohol test. Danford maintained he had not consumed alcohol and presented three subsequent negative tests, but Delta required him to either undergo three to six months of inpatient treatment or face termination. The arbitration decision noted that his HIMS AME, chief pilot, and union representative all urged him to accept treatment regardless of whether he had actually relapsed. In February 2021, the arbitrator ruled for Delta, finding that just cause existed under the negotiated program protocols, while acknowledging "we can never be certain whether or not Danford was abstinent and simply had some false positives."^[94]

The FAA subsequently reissued Danford's first-class medical certificate without requiring inpatient treatment, determining that full consideration of clinical and testing data "cast doubt on the reliability" of the disputed test result.^[94]

Subsequent peer-reviewed research confirmed that PEth false positives can result from alcohol vapor exposure during sample collection^[21] and from red blood cell transfusions.^[92] In 2025, Dr. Petitt published additional research reporting false positive PEth results in an abstinent subject and acknowledged Danford "for shining light on false positive results"; the study was published in a journal whose publisher has been identified as predatory (seePEth testing reliability).^[93]

InMcKeon v. Fries (2025), a Florida jury found a HIMS AME 100% negligent for erroneously attributing another pilot's positive PEth result to the plaintiff, resulting in a $513,000 verdict—the first known jury verdict against a HIMS AME for testing-related negligence (seeMcKeon v. Fries).^[22]

In November 2023, Republic Airways pilot Brian McKeon filed a medical malpractice lawsuit against his HIMS Aviation Medical Examiner, Dr. Ian Blair Fries, and A1A Aviation Medicine, Inc. in Indian River County, Florida. McKeon alleged that in June 2021, Fries erroneously attributed a positive PEth blood test result of 246 ng/ml—belonging to a different, unrelated pilot—to McKeon and reported it to the FAA, stating: "we now have a clearly positive PEth. That ends the uncertainty." The FAA revoked McKeon's special issuance medical certificate the following day, grounding him indefinitely.^[55]

According to the complaint, McKeon had been fully compliant with HIMS requirements throughout his monitoring. Four earlier low-positive EtG results had each been accompanied by negative EtS confirmatory tests and negative PEth blood tests, and were appropriately attributed to incidental exposure by the FAA.^[55]

On June 25, 2025, a jury found Fries 100% negligent and awarded McKeon $513,000 in damages, including $508,500 in lost income—McKeon was paid only for actual flight hours and received no income from Republic Airways while grounded without medical clearance—and $4,500 in medical expenses. The jury found McKeon bore zero contributory negligence.^[22] Dr. Fries, a Senior FAA HIMS Aviation Medical Examiner who serves as Chairman of the AOPA Board of Aviation Medical Advisors, on the FAA/ALPA HIMS Advisory Board, and as aviation medical consultant for the Teamsters Airline Division,^[53][54] remained listed as an active HIMS AME on the FAA's directory as of February 2026.^[57]

The case represented the first known jury verdict finding a HIMS Aviation Medical Examiner liable for negligence in monitoring. The complaint alleged seven specific breaches of the standard of care, including failure to track the source and identity of blood PEth test results to the correct pilot, failure to accurately interpret four split positive-EtG/negative-EtS results, and referring McKeon to unnecessary psychiatric and rehabilitation treatment following the erroneously reported PEth test.^[55]

Captain Andrea Ratfield, a Delta pilot since 2007, filed suit in federal court alleging that Delta used HIMS referral and retreatment requirements as retaliation after she reported sexual harassment by male pilots. According to court filings, Ratfield sought help from a company supervisor to cope with trauma from sexual assault at an aviation event. She was directed to the HIMS program—a substance abuse program—rather than receiving trauma-focused support. The lawsuit alleged that Delta management subsequently used additional HIMS treatment requirements as retaliation for her harassment complaints. Ratfield's complaint also alleged that a PEth test administered during her monitoring was "non-controlled" and "notorious for its false positives."^[105]

In August 2023, Judge Katherine Menendez of the U.S. District Court for the District of Minnesota denied Delta's motion to dismiss, ruling that Ratfield "plausibly alleged that she had been subjected to 'a sexually hostile work environment emblematic of the good ol' boys club.'" The court rejected Delta's argument that retreatment requirements were "beneficial opportunities," finding that binding case law "indicates otherwise."^[105] The case was dismissed with prejudice in August 2024, indicating a settlement.^[106]

In June 2024, theNational Transportation Safety Board Administrative Law Judge reversed the FAA's denial of Donald Park's first-class medical certificate, finding the agency had "prematurely, and without sufficient information, labeled Petitioner as having substance dependence."^[107]

Park, a decorated U.S. Army helicopter pilot who earned twoair medals for combat missions in Afghanistan and subsequently worked as an airline pilot forEnvoy Air, was denied certification based solely on a blood alcohol content of .207 from a 2019 dirt bike accident on a private farm field—not a criminal DUI.^[107] FAA medical consultants Dr. Matthew Dumstorf and Dr. Flynn opined that the BAC alone demonstrated "increased tolerance" sufficient to establish substance dependence under14 CFR § 67.107(a)(4), relying on a 2018 FAA technical report rather than conducting a personal interview or contacting collateral sources.^[107]

Park's expert witness, Dr. Leonard Weiss, a board-certified forensic and addiction psychiatrist, testified that "it's not medically appropriate to create a determination of substance dependence without examining the entirety of a person's relevant medical history" and that a "BAC alone does not tell you anything" beyond "a huge inference."^[107] ALJ Alisa M. Tapia found the FAA's paper review methodology "deficient," noting that "once the government obtained the BAC lab results, it stopped all investigations, halted any need for additional information, and discarded any notion of discovering anything other than Petitioner Park has a substance dependence problem."^[107]

Park testified that he chose to appeal rather than enter the HIMS program because he "morally...could not find himself going to a HIMS program and 'play the part of an alcoholic'" when he did not have a substance dependency problem.^[107] The court distinguished the case from prior NTSB precedent, citingPetition of Lazzari (2021), which held that "we do not find that every DUI or other alcohol-related event is, without more, per se disqualifying."^[107]

In August 2024, Captain Martin Barnard, a Delta pilot, filed a negligence lawsuit against Dr. Alan Kozarsky, an ophthalmologist serving as his HIMS AME. According to the complaint, Barnard had entered HIMS following a 2020 DUI, and in September 2021 the FAA granted him a special issuance first-class medical certificate. In October 2022, Barnard reported possibly consuming low-alcohol beer accidentally; a subsequent PEth test returned negative. Despite the negative result, Barnard alleges Kozarsky reported to the FAA that Barnard was experiencing "imperfect recovery" and presented an "increased risk for full relapse."^[108]

Delta subsequently demanded Barnard accept the diagnosis and undergo 98 days of inpatient treatment. Kozarsky moved to dismiss, arguing he had no doctor-patient relationship with Barnard and was exempt from liability as an FAA representative. The court denied the motion, ruling that "Mr. Barnard's complaint, accepted as true, plausibly alleges that it was foreseeable that Dr. Kozarsky's report would cause the FAA to revoke Barnard's medical license." The case is proceeding to discovery and represents the second known negligence lawsuit filed against a HIMS AME in two years, followingMcKeon v. Fries in Florida, which resulted in a $513,000 jury verdict against a different HIMS AME for misattributing a PEth test result (seeMcKeon v. Fries).^[22][25]

In October 2025, John Paul Castillo III, a formerU.S. Air Force combat pilot who joined United Airlines in January 2023, filed a federal lawsuit alleging racial discrimination, disability discrimination, retaliation, and defamation. Castillo was arrested in July 2023 for suspected DUI based on a field sobriety test; no blood alcohol test was conducted, and the charges were later dismissed through pretrial diversion.^[35]

According to the complaint, United pressured Castillo to enroll in the HIMS program despite an independent psychiatric evaluation finding no alcohol-use disorder and describing the incident as "a one-off, aberrant event." The lawsuit alleges United retaliated against Castillo for retaining legal counsel, citing a chief pilot's statement as "direct evidence" of retaliation.^[35][88] When Castillo refused HIMS enrollment, United terminated him in November 2023, citing a temporary lapse of his FAA medical certificate. Castillo alleges that United's "perception of Mr. Castillo as an alcoholic was not a neutral medical judgment but reflected racialized stereotypes about Hispanic men and alcohol use," and that a white probationary pilot facing similar DUI charges remained employed because he joined the HIMS program.^[109] The lawsuit also alleges that United defamed Castillo by falsely reporting to the FAA that his termination was due to "pilot-performance issues."^[35] The case is pending.

The FAA investigated approximately 4,800 pilots—including 600 licensed to fly passenger airliners—after cross-referencing pilot health information against a Veterans Affairs database, ordering 60 pilots to "cease flying" for potentially disqualifying conditions including PTSD, depression, and sleep apnea.^[110][111]

FAA medical staff determined that 60 of the flagged pilots "may have disqualifying conditions" and ordered them to "cease flying unless and until they obtain a new medical certificate or an Authorization for Special Issuance." The conditions included post-traumatic stress disorder, depression, andsleep apnea. The remaining pilots were offered a reconciliation process to correct their medical records, though the FAA declined to offer broad amnesty as the aviation industry had requested.^[111]

The VA data sharing raised privacy concerns among pilots, though the legal basis for such sharing was established in federal statute. Under38 U.S.C. § 5701, VA records must be disclosed "[w]hen required by any department or other agency of the United States Government."^[112] TheHealth Insurance Portability and Accountability Act (HIPAA) does not restrict inter-agency sharing among federal entities, as federal agencies are notcovered entities under HIPAA for information they hold in governmental capacity.^[113]

The 2023 investigation followed a similar 2004 effort called "Operation Safe Pilot," in which the FAA cross-referenced pilot medical certificates withSocial Security Administration disability records. That investigation resulted in prosecutions and a legal challenge culminating in the 2012U.S. Supreme Court caseFAA v. Cooper, which addressed whether thePrivacy Act of 1974 permits damages for emotional harm caused by improper disclosure of government records. The Court held that the Privacy Act's waiver ofsovereign immunity does not extend to mental and emotional distress claims absent physical injury.^[114]

International programs adopting the HIMS model have cited approximately 85-90 percent success rates based on U.S. statistics that the 2023 National Academies study found have "no solid evidence" to support them.^[4][3] The U.S. HIMS program's official links page lists international aviation substance abuse programs including HIMS Australia, NZ HIMS, Lufthansa Antiskid (Germany), KLM Antiskid (Netherlands), and PAN HK (Cathay Pacific, Hong Kong).^[40]

Cathay Pacific in Hong Kong introduced a formal HIMS-modeled program in 2012, making it one of the earliest international adoptions of the U.S. framework.^[115]

HIMS New Zealand was established circa 2017 and is supported byAir New Zealand,Airways Corporation of New Zealand, theRoyal New Zealand Air Force, and the New Zealand Air Line Pilots' Association, with endorsement from theCivil Aviation Authority of New Zealand.^[116] The program is described as "modelled on well-established overseas programmes" and claims to have "assisted thousands of pilots in getting back to work," a figure that matches U.S. program historical totals rather than any published New Zealand-specific data.^[116] According to HIMS Australia, "New Zealand is finding similar successes as the US," though no independent verification of New Zealand-specific outcomes has been published.^[115]

The HIMS Australia Advisory Group (HAAG) was formed circa 2015 as a collaborative body comprising representatives from professional pilot associations, Designated Aviation Medical Examiners (DAMEs), addiction medicine specialists, and psychologists.^[117] The catalyst for HIMS Australia's formation was a fatal 2002 accident atHamilton Island, Queensland. On September 26, 2002, aCherokee Six crashed shortly after takeoff, killing the pilot and five passengers.^[118] TheAustralian Transport Safety Bureau (ATSB) investigation found post-mortem toxicological examination revealed a blood alcohol concentration of 0.081%, an inactive metabolite ofcannabis indicating prior use, and codeine/morphine/paracetamol consistent with the over-the-counter medicationPanadeine.^[118] The ATSB concluded: "There was insufficient evidence to definitively link the pilot's prior intake of alcohol and/or cannabis with the occurrence. However, the adverse effects on pilot performance of post-alcohol impairment, recent cannabis use and fatigue could not be discounted as contributory factors."^[118] The accident investigation led to recommendations for the introduction of alcohol and other drug testing programs for safety-sensitive personnel, ultimately resulting in CASR Part 99 regulations approved in 2008.^[117]

The program is supported by theAustralian Federation of Air Pilots and involves coordination with theCivil Aviation Safety Authority (CASA). HIMS Australia's FAQ states that "the success rates for this very complicated relapsing medical condition have been over 88% in the long term," explicitly citing U.S. program data rather than Australian outcomes, while acknowledging the program structure is being "tailored to suit the Australian environment."^[115]

Unlike the U.S. HIMS program, which operates as a "return to work" program integrated with airline management, HIMS Australia describes itself as a "peer support programme where trained peer supporters mentor pilots who have had AOD [alcohol or other drug] issues."^[62] The same document emphasizes a key structural difference: "Pilots are not forced into a HIMS programme in Australia. Participation is voluntary."^[62]

Several European airlines have established similar programs, includingLufthansa's Antiskid program (Germany),KLM's Antiskid program (Netherlands), and programs at airlines in France and Finland.^[115][40] TheUK Civil Aviation Authority has participated in U.S. HIMS training seminars, with CAA medical officers attending to learn about certification approaches for pilots with substance use histories.^[119]

In August 2024,FX airedThe New York Times Presents: Lie to Fly, a documentary examining pilot mental health issues, including the 2023 incident involvingAlaska Airlines pilot Joseph Emerson.^[120]

Following the National Academies' 2023 report documenting the FAA and ALPA's refusal to provide program data, a broader ecosystem of pilot-led advocacy has emerged. Pilots for HIMS Reform (P4HR), co-founded in 2024 by Mike Danford and Captain Maurice MacEwen, an active airline captain, advocates for program transparency and accountability, and has proposed an alternative evidence-based model called AEROPath.^[121] Danford, a former Delta Air Lines pilot and U.S. Naval Academy graduate, was terminated in 2018 after disputing a positive PEth test (seeDanford arbitration above). The organization's HIMS Voices Project collects confidential survey data from pilots about their program experiences—an effort to gather participant outcome information that the FAA and ALPA have declined to release publicly.^[122][3]

P4HR has developed two major policy initiatives: AEROPath (Aviation Evaluation & Recovery Oversight Pathway), a proposed science-based alternative monitoring framework emphasizing independent medical oversight and evidence-based testing protocols; and the "Pilots for HIMS Reform Act of 2026," comprehensive draft legislation that the organization contrasts with the Mental Health in Aviation Act. According to P4HR, the Mental Health in Aviation Act maintains FAA discretion without establishing independent oversight, due process protections, or enforceable rights, while their proposed legislation would create binding accountability mechanisms (seeReform advocacy critique).^[39]

The National Academies documented that pilots had been reluctant to participate in official research due to fear of career consequences—receiving only 15 pilot responses to their "Call for Perspectives" survey—up from the nine initially reported in the study summary, after the committee reopened the tool—compared to 1,173 from flight attendants. The committee noted that ALPA and HIMS "never distributed the link or sought pilot participation."^[3] The emergence of P4HR and similar advocacy efforts has been led primarily by pilots who, having already lost their careers, no longer face such constraints. Co-founder Maurice MacEwen has stated: "I believe aviation medicine should be a pathway to safety and wellness, not a barrier to a pilot's livelihood. Our mission is to create a system where fairness and science take priority over fear and stigma."^[121]

Other initiatives include alternative AME directories such as AeroMedical Compass, online forums and discussion boards, personal blogs by affected pilots, and self-published accounts of program participation. Paul Valone, a retired airline captain writing under the pseudonym Randle Patrick McMurphy, publishedThe HIMS Nightmare (2023), stating the book "is intended to empower pilots to avoid the program if they can, or to survive it if they must."^[123] Joe Miller, author ofUS of AA: How the Twelve Steps Hijacked the Science of Alcoholism, described HIMS as "yet another example of the harms caused by a one-size-fits-all treatment policy based entirely on AA."^[124] Monica Richardson, host of the podcastSafe Recovery and producer ofThe 13th Step documentary, wrote that the book "needs to be read by every pilot flying commercially in the skies today" and characterized HIMS as a system where "the 'man behind the curtain' is not a health care or mental health professional or a substance abuse PhD, but rather an antiquated, religious self-help group founded in the 1930s."^[124] An anonymous reviewer ofThe HIMS Nightmare wrote: "There is so much fear of reprisal that I would be crazy to use my real name in the review byline."^[124] Another self-published critique,The HIMS Experiment Exposed (2024), has also circulated among program participants. As self-published accounts and advocacy materials, these sources represent participant perspectives rather than peer-reviewed assessments of program outcomes.

• Air traffic controller
• Aviation medicine
• Aviation safety
• Random drug testing
• Alcoholics Anonymous
• Substance use disorder
• Occupational health psychology
• Aviation medical examiner
• Whistleblower protection in the United States

• Valone, Paul (as Randle Patrick McMurphy).The HIMS Nightmare (2023). Self-published account of program participation. Pseudonym referencesRandle McMurphy, the protagonist ofOne Flew Over the Cuckoo's Nest who fights against institutional psychiatric control.
• "John Nicodemus" (pseudonym).The HIMS Experiment Exposed (2024). Self-published critique of program practices. Pseudonym references thebiblical figure who came toJesus secretly at night for fear of reprisal (John 3:1–21).
• Petitt, Karlene. "False Positives with Non-FDA Approved Blood Testing."Journal of Biomedical Science and Engineering 18, no. 7 (2025): 277–287.doi:10.4236/jbise.2025.187020. Published byScientific Research Publishing (SCIRP), listed inBeall's List and Cabells' Predatory Reports; methodology and data available viaMendeley Data. Included for transparency as author is a principal inPetitt v. Delta Air Lines and the study is relevant to theDanford arbitration.
• Petitt, Karlene."Petitt v. Delta Air Lines II (2025)". Documentation of ongoing follow-up litigation (Docket: 2025-AIR-00035).

Official

• Official website – Official HIMS Program website (United States)
• HIMS New Zealand – New Zealand HIMS program
• HIMS Australia – HIMS Australia Advisory Group (HAAG)

Advocacy and reform

• Pilots for HIMS Reform – Pilot advocacy organization
• FAA HIMS Program Information Center – Independent information resource with proposed AEROPath alternative model
• AeroMedical Compass – Aviation medical provider accountability, ranking, and transparency project

Personal accounts and discussion

• HIMS Nightmare – Website associated with self-published book
• Karlene Petitt – Website of pilot involved in Petitt v. Delta Air Lines
• Flight to Success – Blog by Karlene Petitt
• HIMS Victims Forum – Online discussion forum for program participants

• Aviation medicine
• Aviation safety
• Federal Aviation Administration
• Substance abuse
• Alcoholics Anonymous
• Aviation in the United States

• Pages using cite court with unknown parameters
• Articles with short description
• Short description matches Wikidata
• Use American English from January 2026
• All Wikipedia articles written in American English