What the Revised Directives Mean for Officers: A Follow-Up to Our May 8 Analysis

On May 8, Against Giants published an analysis of TSA's May 4 broadcast announcing the Annual Medical Certification program and the Daily Fitness for Duty requirement. That article remains substantially accurate, however it did not address the ways the revised versions of both directives shift compliance burdens onto officers that the prior versions did not. The revised directives signed May 1, 2026, TSA's official FAQ document for the AMC program, and implementation communications already issued to officers at specific airports are now in the record. Those differences are what this update addresses.

Both Directives Were Revised on May 1

TSA Management Directive 1100.33-4, Annual Medical Certification Program, and TSA Management Directive 1100.33-1, TSO Daily Fitness for Duty, were both revised and signed by Assistant Administrator for Human Capital Thomas J. Regan on May 1, 2026, effective May 4. Both supersede prior versions. The programs themselves are not new. The policy provisions governing them are, and where they differ from prior versions, they are more demanding of officers than what they replaced.

Implementation Is Already Underway

The May 8 article noted that TSA said additional details would follow in the coming weeks. Officers at one airport received implementation instructions on May 8 with a questionnaire completion deadline of June 13, 2026. The live questionnaire is accessible at amc.tsa.dhs.gov. Officers should expect similar communications from their airports shortly if they have not received them already.

The Swipe-In Is Now a Certification Against a Specific Written Standard

The revised MD 1100.33-1 makes the self-certification requirement explicit in a way the prior version did not. By swiping in at the start of a shift, a TSO is certifying that to the best of their knowledge they are physically and psychologically able to perform the essential functions of their position consistent with the Medical and Psychological Guidelines for TSOs.

The prior version of MD 1100.33-1 contained no mechanism by which the swipe-in served as a documented certification against the Medical and Psychological Guidelines. The 2026 revision added that. Officers swiping in while taking a medication in the guidelines' restriction categories, or managing a condition with clearing criteria they cannot currently meet, are certifying fitness against a standard that may not be satisfied.

The 15-Day Questionnaire Window

The May 8 article focused on the 30-calendar-day documentation deadline that follows an OCMO request for additional information. There is an earlier deadline the article did not address.

The OWCP Question

The official AMC questionnaire at amc.tsa.dhs.gov asks officers whether they have an open accepted claim with the Department of Labor Office of Workers Compensation Programs. That question appears on the questionnaire before Part I begins, following the Driver's License Information section. Officers with open OWCP claims should understand the intersection between that disclosure and their protections under MD 1100.33-2 before completing the questionnaire.

MD 1100.33-2 prohibits TSA from initiating a management-initiated fitness-for-duty evaluation on a condition covered by an accepted OWCP claim while that claim remains open and before the officer returns to full unrestricted duty. OCMO administers both the AMC program and the management-initiated evaluation process. Against Giants can help you navigate that intersection.

Who Is Covered

The May 8 article listed TSOs, LTSOs, STSOs, and Security Training Instructors as covered employees. TSA's official FAQ confirms the covered population also includes Criminal Investigators, Supply Technicians, Transportation Security Managers-Explosives, Transportation Security Specialists-Explosives, and Transportation Security Specialist-Explosive Detection Canine Handlers. The questionnaire header itself limits the program to TSO, LTSO, STSO, STI, and BDO positions. Officers in other covered categories should confirm their specific obligations with their HR POC.

Protections in the Record

The revised MD 1100.33-4 Section 7.C.(2) allows extensions for documentation deadlines on a case by case basis, considering good faith effort, reasons for delay, and circumstances beyond the employee's control. Appointment unavailability with a TSA-designated provider could fall within that language. The directive leaves that determination to OCMO discretion.

Bargaining unit employees have a more explicit protection under CBA Article 32 Section C.5, which prohibits adverse action solely as a result of appointment unavailability for an independent medical examination in the context of management-initiated evaluations. Bargaining unit employees directed to undergo a management-initiated evaluation have an additional protection under CBA Article 32 Section C.4, which requires TSA to notify the individual officer of the consequences of noncompliance specifically when the evaluation is ordered.

Bargaining unit employees charged with AWOL in connection with a fitness for duty matter will receive written notice of that charge prior to payroll completion for the affected pay period, providing a window to respond with documentation or an explanation.

What Has Not Changed

The core guidance in the May 8 article remains accurate. The psychiatric standards remain as described, including the categorical disqualifiers and the undefined functional impairment threshold. Extension requests for the documentation deadline must be submitted in writing before that window closes. Officers managing conditions covered by the medical guidelines should confirm their treating providers can document their status before the questionnaire arrives.