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.
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