On May 4, 2026, TSA's Executive Assistant Administrators for Mission Support and Security Operations sent a joint broadcast to all TSA employees announcing two initiatives under Management Directive 1100.33. The broadcast described them as reflecting TSA's "ongoing commitment to resilience and excellence." What it did not describe was how either program works, who is covered, or when implementation begins. TSA acknowledged in the same message that processes are still being developed and that additional details would follow in the coming weeks.
Neither initiative is new authority. Both exist in policy that predates the current administration. What is new is that TSA is activating them with operational intent, and the consequences for officers who are unprepared are serious.
The Two Initiatives
The broadcast announced an Annual Medical Certification program and a Daily Fitness for Duty requirement.
The daily fitness for duty piece has been policy since 2014. MD 1100.33-1 requires supervisors to conduct a start-of-shift observation within 30 minutes of every shift. The broadcast added language not present in the underlying directive: that officers "will now be required to actively certify they are fit to perform their duties effectively each day." The existing directive places the observation obligation on supervisors, not officers. What that self-certification process looks like in practice has not yet been disclosed.
The Annual Medical Certification is the more consequential announcement.
What the Annual Medical Certification Program Is
MD 1100.33-4, revised and effective May 4, 2026, requires covered employees to complete an annual medical questionnaire on or around the anniversary of their appointment to their current position. The questionnaire header limits the program to TSO, LTSO, STSO, STI, and BDO positions. TSA's official FAQ lists a broader covered population including Criminal Investigators, Supply Technicians, and explosive specialists. Officers in those categories should confirm their specific obligations with their HR POC. TSA's Office of Chief Medical Officer reviews the completed questionnaire and makes one of three determinations: Medically Qualified, Temporarily Not Medically Qualified, or Not Medically Qualified for Full and Unrestricted Duty.
A finding of Temporarily Not Medically Qualified means a medical condition has been identified that temporarily restricts your ability to perform essential functions, with an expectation of resolution. A finding of Not Medically Qualified for Full and Unrestricted Duty means you may be subject to removal from your position and from federal service for failure to maintain a condition of employment.
If the OCMO needs additional information after reviewing your questionnaire, you will be contacted and asked to provide medical documentation.
The Deadline That Matters Most
30-Day Documentation Deadline
If TSA requests medical documentation from you, you have 30 calendar days to provide it. That deadline is not flexible by default. If you miss it without having submitted a written extension request before it expires, TSA policy allows a finding of Not Medically Qualified for Full and Unrestricted Duty regardless of your actual physical condition.The compliance deadline is as consequential as the medical finding itself. An officer in good health who fails to respond in time faces the same outcome as an officer with a disqualifying condition.
If you need more time, you must submit a written extension request to the OCMO before the 30-day window closes. Extensions are granted case by case and are not guaranteed, but submitting one before the deadline preserves your position. Waiting until after the deadline does not.
Officers who receive notification from HR to complete the questionnaire have 15 calendar days from that notification to submit it. Implementation communications confirm that airports are setting completion deadlines significantly beyond 15 days. The airport-imposed deadline in your notification is the operative constraint. Extension requests are available for the 30-day documentation deadline that follows an OCMO request for additional information. The directive does not establish a formal extension mechanism for the questionnaire completion deadline itself. Officers who cannot meet their airport-imposed deadline should contact their HR POC before that date passes.
What the Medical Guidelines Cover
TSA's Medical and Psychological Guidelines for Transportation Security Officers are the benchmark applied under this program. They cover vision, hearing, cardiovascular health, neurological disorders, diabetes, sleep disorders, psychiatric conditions, and medications. Several categories warrant particular attention.
The cardiovascular standards include a 10-year atherosclerotic cardiovascular disease risk threshold. Officers whose calculated risk reaches 10 percent or above face restrictions unless they can demonstrate performance on a stress test at a minimum exertion level. That threshold is reached by a significant portion of officers over 50 with common risk factors including hypertension and diabetes.
Sleep apnea is covered. Officers with obstructive sleep apnea on CPAP treatment must be able to document compliance, defined as at least four hours of use per sleep session across 70 percent of sleep sessions, on an annual basis.
The medication section is broad. TSA's guidelines provide for restrictions for any medication causing sedation, drowsiness, equilibrium disturbance, or behavioral changes, and categorical restrictions for benzodiazepines and opioids. Officers taking any of these medications should understand that a questionnaire or management-initiated evaluation that surfaces the medication will require individual assessment.
The Psychiatric Standards
TSA's guidelines establish two tiers for psychiatric conditions. The first tier is categorical disqualifiers with no pathway to unrestricted duty: bipolar I disorder, brief psychotic disorder, delusional disorder, schizophreniform disorder, schizophrenia, schizoaffective disorder, and antisocial, borderline, and narcissistic personality disorders. A diagnosis in any of these categories ends the inquiry regardless of treatment compliance, years of stability, or demonstrated functional capacity on the job.
The second tier covers conditions where clearing criteria exist but the language creates significant exposure. Anxiety disorders, depressive disorders, PTSD, and ADHD all require, among other conditions, no functional impairment in the past two months. That phrase is not defined in the guidelines. What constitutes functional impairment, who makes that determination, and what documentation is required to establish its absence are questions the guidelines leave entirely to TSA's medical office.
PTSD specifically requires no irritability, no reckless or self-destructive behavior, and no difficulty concentrating, in addition to the functional impairment standard. These are symptom descriptors, not clinical findings with established documentation thresholds.
What to Do Now
TSA has said additional details and guidance are coming in the coming weeks. That window exists now.
Steps to Take Before You Receive a Request
Review your current medications against the categories above. If you are managing a condition covered by the medical standards, confirm that your treating provider can document your status, including compliance with treatment, any applicable remission criteria, and relevant test results.The AMC questionnaire asks whether you have an open accepted claim with the Department of Labor Office of Workers Compensation Programs. That question appears before Part I begins, following the Driver's License Information section. If you have an open workers' compensation claim accepted by the Department of Labor for a specific condition, TSA cannot initiate a management-initiated fitness-for-duty evaluation on that same condition while the claim remains open and before you return to full unrestricted duty. That protection applies to management-initiated evaluations specifically under MD 1100.33-2 and may not extend to the annual medical questionnaire process under MD 1100.33-4.
If you receive a documentation request from TSA, contact Against Giants before you respond.
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