Q: For currently-enrolled students that have already completed a portion of the A&P curriculum, do we need to go back and train them on ACS elements that are newly-incorporated before we issue the requisite authenticated documentation in order for them to test?

A: Gap training is not required. The school must ensure it's curriculum aligns with the new airman certification standards by Sept. 21, 2022, and must ensure its students are prepared for the FAA mechanic test (which will not align to the new standard until next summer). The FAA has issued the following guidance to its inspectors:

Please be aware that there is no specific requirement for gap training in the regulation. Therefore the FAA cannot request or demand that an AMTS do gap training. As previously stated, the AMTS is responsible to determine how to transition students relative to curriculum requirements. The FAA recognizes the difficulties associated with the "light-switch" effectivity of the curriculum changes imposed by the new regulations. If an AMTS is found to be in non-compliance with 147.21, or any regulation, the FAA is committed to working with the AMTS to appropriately address the non-compliance. If safety issues and/or regulatory noncompliance are identified, follow the process contained in Volume 14, Chapter 1, Section 2 to determine the appropriate FAA compliance or enforcement action.

Q: Do we need operation specification (op spec) paragraph A025 (Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals/Documents)? The school is getting some pushback from the FAA when we say we do not use electronic signatures or electronic recordkeeping.
 
A: There are three tables included op spec A025:

• Table 1: Electronic signatures
• Table 2: Electronic recordkeeping
• Table 3: Electronic manuals/documents

 
For tables 2 and 3, if your program is accredited, they should read “The certificate holder meets the requirements of 147.23 [which requires that the school have a quality system, or be accredited] by being accredited.” Even if your accredited program does not keep electronic versions of records, manuals, and/or documents, it’s still good for this language to be present in your operations specification. Alternatively the paragraph would state that your program does not use electronic records, which is fine, but will require a change to your operations specifications if/when you decide to transition.
 
If your program is not accredited, these tables will include statements that you do not use electronic recordkeeping, or a reference to (or description of) your recordkeeping system.
 
Table 1 (electronic signatures) is only speaking to signatures affixed to A&P student certificate of completions and authenticated documentation—since that’s the only “recordkeeping” required by part 147. All programs, no matter if they are accredited or not, need to provide a description of (or reference to) their electronic signature procedures. For example, what type of electronic signature does the program use, how does it ensure those signatures are kept secure, how will final documents be secured to ensure the signature isn’t removed or copied, etc.?
 
Alternatively, this table can remain blank if electronic signatures will not be used on authenticated documentation or certificates of completion.

​Q: If a student completes the general portion of the program and proceeds to take the general written test (using an “authenticated document” issued by the school to demonstrate the student’s preparedness to take the mechanic general written test early, as provided in 147.31), and fails that test, but then proceeds to pass the general test once the student finishes the curriculum (using the certificate of completion as the authority to test), for purposes of calculating our passage rate, will those written tests be counted as a pass, a fail, or both?
 
A:
The first failed general written test would not be used in the passage rate calculation (since it was not taken 60 days after graduation). The second passed general written test would be included in the passage rate calculation.
 
The program’s “minimum passage rate” (as provided for in 147.25) is calculated based on the test scores of students that test within 60 days after “graduation.” For purposes of the FAA regulation, the student’s “graduation date” is the date entered on the FAA Form 8610-2 and the student’s certification of completion (both of which are issued upon graduation of the airframe and/or powerplant curriculum). So, for the first general knowledge test, taken before “graduation,” would not be included in the calculation, but the second test, taken after graduation, would count.
 
Couple other considerations if we change up the scenario a bit:
 
What if the student takes an oral and practical early, as provided by § 65.80? The score would not count toward the passage rate because the student hasn’t “graduated” yet. Again, that “graduation date” is driven by the date on the 8610-2, and that form will state the proposed (i.e., future) graduation date, which would be the same date subsequently entered on the certificate of completion and any future 8610-2.
 
Side note: The student will not need a certificate of completion or an 8610-2 in order to take the written knowledge test. All the student will need is an “authenticated document” that demonstrates the student’s preparedness to take the test, which could be a certificate of completion but doesn’t have to be.
 
For more information on passage rate calculations, listen in on the recorded version of the June 30, 2022 webinar: https://register.gotowebinar.com/recording/2285866406537654799.