[Peetwo]

CASA AvMAD evidence of total incompetence and negligence on ADHD/ASD medical policy?? -   

Interesting developments on the UP 'ADHD/ASD and CASA medicals' thread.

Courtesy AOPA Oz Director Clinton McKenzie...
  

Clinton McKenzie

I have now received documents in response to my second FOI request about CASA Form 420. I will try to provide a link to the documents. I am doing a forensic review of the content, but note the following preliminary matters that have already become obvious.

The footer of the currently published version of Form 420 says this:

ADHD Instructors Questionnaire │V 1│CASA-04-1896│03/2022

The “V 1” represents that it is the first and only version of the Form. That is a misrepresentation. As we know, at least the sick joke was airbrushed out of it, with no trace as to who decided to do that and who did it. I can see other versions in the disclosed documents, which versions were evidently used because ‘outsiders’ have commented on or complained about them. There is nothing in the Form to indicate the differences between different versions. (It evidently remains beyond CASA’s current corporate competence to understand the difference between “impatient” and “inpatient”.)

More fundamentally, given the circumstances in which CASA Avmed has required the Form to be completed and the implications if the requirement is not complied with, ASD has now been deleted from the heading. As we will see, someone in CASA Avmed finally decided that the questions in the Form were aimed at behaviours typical of ADHD rather than ASD and – guess what - ASD and ADHD are apparently two quite distinct conditions.

CASA’s quality control is so poor that when the deletion of ASD from the heading of the Form was going through the approval process, nobody bothered to review the rest of the Form. The Form continues to say, under the heading “Purpose of this form”:

This behavioural questionnaire is for Flight Instructors of individuals with ASD and/or ADHD.

But rewind to 2018, when an applicant for a medical certificate made a complaint to the CASA ICC about the requirement, imposed by CASA Avmed, for the applicant to provide a completed Form 420 (plus Medicare consultation and prescription records for the past five years; academic and employment history; copies of any special reports (such as QEEG or neuropsychological testing); previous specialists reports). The applicant had low level ASD and complained that the Form related to ADHD, with which the applicant had never been diagnosed.

The ICC’s letter to the applicant, dated 17 July 2018, contains a chronology, 27 dot points long, spanning the period 4 October 2017 (when the applicant’s application was submitted to the MRS) through to 27 June 2018, at which point the applicant had still not been issued a medical certificate, because CASA was “currently waiting for you to return the Authority to Release Medical’in-confidence Information’ form before it can complete your certificate application”.

The events in between were the usual mixture of Avmed overreach and pedantry. The penultimate paragraph in the ICC’s chronology says in part:

Avmed also advised the instructor’s name wasn’t on the Form 420 you’d submitted and you clarified it was. AvMed agreed it was, stating ’the instructor name is…where it would have expected to see (your) name.’

It’s hard to imagine the extent of the stress caused to Avmed by the instructor’s name having been put on the Form where Avmed expected to see the applicant’s name, much less the extent of the consequential risks to the safety of air navigation.

The ICC’s findings included;

I agree Form 420 is confusing. It’s clearly states it relates to ADHD and is an extract from that condition’s assessment protocol. …

Form 420 contains no instructions for the level of detail it seeks from the flying instructor who is completing it. It asks a closed question (‘normal?’) and then seeks comments. …

As we know, that entirely inappropriate question has also been disappeared from the Form.

The ICC also found that CASA Avmed created an expectation in the applicant’s mind and then acted contrary to the expectation created:

In my view, AvMed created an expectation the information you’d provided would reviewed at the point it was received, rather than cumulatively. In reaching that conclusion, I note when you asked if you were to ’start sending through information … to help the transition go faster.’ AvMed replied on 10 January [2018] that ’it would be very helpful if you could send through anything you have available.’

Contrary to your expectation, it’s apparent the information wasn’t reviewed by a Doctor until all the information it’d sought had been received. …

Fast forward to 12 October 2021 – more than 3 years after the ICC’s findings. Some bloke named Tony Hochberg sent a string of emails to Nathan Sullivan, Kelsey Kadam and Angela Pearman, all of whom appear to be CASA folk. Mr Hochberg’s string of emails say, among other things:

I have a problem with the combined intent of the ASD/ADHD questionnaire as the behavioural aspects of ADHD and Autism are like opposite ends of the spectrum. …

ADHD questions predominate, however autistic individuals are often socially withdrawn and apprehensive when being looked at and like to be left alone in a corner away from everyone, not near doors or passageways etc. in class.

…

Decision made – please call this questionnaire ADHD instructors questionnaire form and problem solved.

…

The problem is the title includes autism spectrum disorder and if we remove that then the questionnaire is specific to ADHD. Not sure why it was combined into one questionnaire as they are two quite distinct conditions.

…

I note the usual insouciant indifference to the stress, delay, cost and confusion caused by CASA Avmed’s pedantry and flawed forms, none of which contributed anything positive to safety of air navigation. Who cares if people with low level ASD were put through the ADHD process.

At this point I will reiterate advice I have given before: Beware of putting yourself in circumstances in which you can be diagnosed with something. Be extraordinarily careful in answering what appear to be innocuous questions. Ditto anyone of your loved ones who may aspire to any aviation-related activities in circumstances in which CASA’s anachronistic medical certificate requirement applies.

Once diagnosed with something and CASA Avmed becomes aware of it, you are their guinea pig. CASA Avmed will spin almost [i]anything[/i] into an ‘aero-medically relevant condition’, will exaggerate the risks arising from the ‘condition’ and will then impose the most intrusive, expensive and potentially dangerous-to-you requirements in order to ‘satisfy’ them, assuming they don’t just refuse to issue a certificate to you. It does not matter if the weight of qualified expert opinion is contrary to Avmed’s.

They have a noble cause and they believe that, but for their crusade in the interests of that cause, it would be raining aluminium. They only back down if there’s a risk they’ll be embarrassed, and that will cost you a lot of time and money to make happen.

Choc frog that man...

MTF...P2