TSA revised the Annual Medical Certification Program directive on May 1, 2026. It took effect May 4, replacing a version that had governed the program since February 1, 2020.
Against Giants published a series of articles on the AMC program in May covering the questionnaire process, the revised directives, FMLA recertification, and what happens after a determination. Those articles remain accurate.
This article does something none of those articles did. It reads both versions of the directive side by side and identifies what specifically changed. AMC questionnaire windows are tied to individual entry-on-duty dates, so officers are still ahead of their questionnaire cycle or navigating the process now. The analysis here applies whenever your window opens.
The Change TSA Calls Clarifying
TSA publishes a summary of changes at the front of revised directives. For this provision, the summary reads in full: "Section 6.C., added clarifying language."
The 2020 directive described the evaluation process this way. The process "may include annual online medical questionnaires, periodic vision testing and/or comprehensive medical examinations."
The 2026 directive says the process "will include an annual online medical questionnaire as a minimum requirement. It may also include periodic vision testing, and/or comprehensive medical examinations."
The New Fifteen-Day Clock
Section 7.A.(4) is entirely new. It provides that a covered employee may pause in answering the medical questionnaire to gather additional information or to discuss the questionnaire with a healthcare provider, as long as the questionnaire is completed within fifteen calendar days from the initial start date of the medical questionnaire.
This cuts both ways and officers should understand both.
It establishes, for the first time in the directive, an explicit right to stop and consult your own doctor before answering. That is worth knowing, because the questionnaire is completed on duty time at a workstation and the practical pressure is to finish it in one sitting.
It also creates a deadline that did not exist before. Fifteen calendar days from when you start. Not fifteen business days. The clock begins on initial access to the questionnaire portal at amc.tsa.dhs.gov, not on HR notification. Officers who open the questionnaire to review the questions and then close it to consult their physician have started the fifteen-day clock.
When the Clock Starts
The 2020 directive keyed the questionnaire to the anniversary of appointment to the covered position, generally within thirty calendar days of that date.
The 2026 directive keys it to the anniversary of the employee's entry on duty appointment to the covered position, and widens the window. Notification is to occur generally within thirty calendar days before the anniversary, or no later than thirty calendar days after.
The revision also adds a definition of entry on duty. Section 4.B defines it as the date an individual began employment in his or her position of record with TSA, as reflected on the SF-50.
Read carefully, the definition and the procedure describe two arguably different dates. Section 7.A.(1) refers to the date of placement in the position the employee currently occupies. Section 4.B refers to the date employment began in the position of record with TSA.
For an officer who has held one position throughout, this makes no difference. For an officer who promoted, changed series, or moved between covered positions, it could. If you are unsure which anniversary applies to you, your SF-50 is the document that governs, and it is worth asking your HR point of contact to identify the date they are using.
Who Gets Told What
This is the provision most often misunderstood, and the directive is specific.
Under Section 6.D, all medical information, including diagnosis and supporting documentation, must be handled in compliance with 29 CFR 1630.14(c) and the Privacy Act. Information carrying your name or other unique identifiers is Sensitive Personally Identifiable Information and may be shared on a need-to-know basis only.
The 2026 directive strengthened one element of the privacy prohibition. The 2020 version prohibited airports and offices from retaining medical information on covered employees. The 2026 version explicitly adds documentation to that prohibition. Airports and offices are not authorized to retain any medical information or documentation on covered employees. All of it goes to OCMO only.
What management receives is the determination, not the file. Section 5.B.(4) provides that the medical office furnishes medical determinations to management officials as necessary to make employment related decisions.
The 2026 directive also changed who delivers that notification. Under the 2020 directive, OCMO notified the airport HR POC only. Under Section 7.E of the 2026 directive, the HR POC now directly notifies both the covered employee and the management official of the result. Officers are entitled to direct written notification of their determination from their HR POC. That is new.
So your supervisor learns whether you are medically qualified. Your supervisor does not receive your medical records. And under the revised directive, you should receive written notification directly rather than learning the result through management.
On the Question of Your Own Doctor
Section 7.C.(4) provides that the medical office may request to consult with your health care provider, and that an employee's failure to provide any release necessary for that consult will be considered a failure to comply with the request.
That provision is unchanged from 2020, and it is worth stating plainly what it does and does not mean.
It does not authorize anyone to contact your physician without your authorization. It requires a release. What it does is attach a consequence to declining one, because a failure to comply may support a determination of Not Medically Qualified for Full and Unrestricted Duty under Section 6.B.(2).
We mention this because the concern that comes up most often about this program is framed as a health privacy question, and specifically as a HIPAA question. That framing does not fit, and an officer who builds a position on it will not get where they are trying to go.
HIPAA restricts what covered entities, essentially health plans and health care providers, may disclose. It does not prohibit an employer from requiring a medical evaluation as a condition of holding a position that carries medical requirements, and it does not prohibit an employer from asking an employee to authorize a release.
The law that actually governs here is the one the directive cites in its own text. Section 6.D.(1) points to 29 CFR 1630.14(c), which is the Rehabilitation Act regulation permitting medical inquiries and examinations of current employees where they are job related and consistent with business necessity, and requiring that the resulting information be kept confidential. The Privacy Act governs how the records are maintained.
Those are the standards that matter. If there is a question to be raised about the scope of this program, it will be raised under those authorities and not under HIPAA.
The Deadlines, in One Place
These deadlines existed in the 2020 directive and remain unchanged in the 2026 version. They are worth having in one place for officers who are encountering the program for the first time.
Fifteen calendar days to complete the questionnaire once you begin it, measured from initial access to the questionnaire portal.
Seven business days, generally, to respond when the medical office requests additional medical information.
Thirty calendar days to provide requested medical documentation.
An extension request must be submitted in writing before the thirty days expire. Approval is not guaranteed, and the directive states that failing to request an extension before the deadline may itself result in a determination of Not Medically Qualified for Full and Unrestricted Duty.
You pay for your own medical documentation and must obtain it on your own time, off duty or on personal leave. TSA pays for an independent medical examination, and that examination occurs on duty time with your tour adjusted if necessary.
The Provision Nobody Talks About
Section 7.F.(3)(b) carries a note that officers should read once, carefully.
Transportation Security Officers who are unable to meet the statutory requirements of the position are not eligible for reasonable accommodation under TSA MD 1100.73-4. The note specifies that this covers all positions in the 1802 series, and it lists them: TSO, Lead TSO, Supervisory TSO, Master TSO, and Expert TSO.
The 2026 directive also changed the order in which post-determination options are presented. The 2020 directive listed reasonable accommodation before the Job Search Program. The 2026 directive lists reassignment first and drops the separate reference to TSO Job Search Process Guidance that appeared in the 2020 version.
What remains after a Not Medically Qualified determination is reassignment under HCM Policy 339-2, the Job Search Program for Medically Disqualified Transportation Security Officers Eligible for Reassignment, and the reasonable accommodation framework for those positions where it applies. That is the practical landscape, and it is narrower than most officers assume.
For the full process that follows a determination, see What a Not Medically Qualified Determination Actually Means.
What to Do With This
Read the directive rather than a summary of it, including ours. It is nine pages.
Know your entry on duty date and confirm which anniversary your HR point of contact is working from.
If you need to consult your own physician before answering the questionnaire, the directive now says you may, and you have fifteen days from the moment you first open the questionnaire.
Track every deadline in writing, and if you need an extension on the thirty-day documentation window, request it in writing before that window closes rather than after.
And if a determination has issued, or a request has arrived that you do not know how to answer, the analysis is specific to your position, your medical situation, and your service. That is a conversation worth having, and the first one costs you nothing. againstgiantsllc.com/get-help.html or info@againstgiantsllc.com