U.S. CDC COVID Testing Requirements for Private Aviation FAQs

PT 5 M minute read

On Jan. 12, 2021, the U.S. CDC issued a new order requiring proof of a negative viral COVID-19 test (NAAT/PCR or antigen), or medical proof of recovery, for anyone arriving from a foreign country to the U.S. The order goes into effect Jan. 26, 2021 for ALL flights, including private flight and GA aircraft.

Key points:

  • Only ACTIVE crew members are EXEMPT. We are working to gain clarification on how exactly the CDC defines ACTIVE CREW.
  • Passengers must show aircraft operator proof of negative result, taken with 3 days of boarding, or of recovery prior to boarding.
  • Operators of private flights and general aviation must maintain passenger Attestations (i.e., declaration forms) for 2 years. Note: While the operator needs to see the test result, only the Attestations (which can be captured digitally) must be kept on file.
  • The CDC’s website has more information on the order, including the official announcement and FAQs.

We will continue to update this article as new information and best practice recommendations are known.

Here are some of the questions, we’ve received so far. The CDC FAQs also have additional information.

CDC Testing Requirement FAQs

Here are some of the questions, we’ve received so far. The CDC FAQs also have additional information.

Testing, Exemptions, & Overseas options

  • What kind of test is required? I don’t see PCR listed in the CDC FAQs.
  • Does having a COVID vaccine exempt one from the testing requirement?
      • No. The CDC’s FAQs state that everyone entering the U.S., including those who have been vaccinated, must provide either a negative test result or medical proof of recovery.
  • Are home test results acceptable?
    • Still researching.
  • Does Universal or any other handler/third party vendor currently offer testing for crew and passengers at overseas locations?
      • Several of our FBOs and locations have relationships with testing providers inside the airport or at a medical facility. Contact us for a specific location.
  • Are there any CDC exemptions if I’m returning from a country that does not have available testing?
    • Airlines or other aircraft operators may be granted specific waivers from the application of this Order based on CDC’s determination that a foreign country lacks available SARS-CoV-2 testing capacity. Such waivers may be granted based on a specific request made by an airline or aircraft operator to the CDC and will be limited to 14 days unless renewed by CDC.
  • What if you get tested in the U.S. and are gone for less than 72 hours. Will that test be acceptable or do you need one from the country you visit? What if you plan to return the same day (quick trip to the Caribbean/Mexico, etc.?)
    • Still researching.
  • What if I recently recovered from COVID-19?
    • CDC does not recommend getting tested again in the three months after a positive viral test, as long as you do not have symptoms of COVID-19. If you have had a positive viral test in the past 3 months, and you have met the criteria to end isolation, you may travel instead with documentation of your positive viral test results and a letter from your healthcare provider or a public health official that states you have been cleared for travel. The positive test result and letter together are referred to as “documentation of recovery.
  • If a passenger tests positive, is there a process to get them back into the U.S.?
    • Still researching.
  • Tests are unreliable where I’m located. Can I be tested on arrival?
    • The testing requirements are pre-departure. Obtaining a test on arrival is not an option.

Enforcement & record keeping

  • What is the difference between attestation and testing?
    • For the Operator record retention requirement, it’s important to know the difference between the Attestation (i.e. A Declaration Form) and proof of a negative viral test results.
    • From CDC Fact Page: Do airlines and operators of private flights or general aviation aircraft need to keep copies of passenger test results? No, passengers must show a copy of their test results to airline employees or the aircraft operator before boarding, but the airline or aircraft operator does not need to retain copies of test results.
    • What should airlines and operators of private flights or general aviation aircraft do with passenger attestations? Operators of private flights and general aviation aircraft must maintain passenger attestations for two years, per the Order.
  • Who is enforcing this and checking test results on arrival?
    • We’re still working to get more details on enforcement, but we have confirmed it will not be U.S. Customs and Border Protection. CBP informed us it plays no role in the implementation, monitoring, or enforcement of these latest CDC restrictions. Not adhering to the order, however, could result in government fines, so it’s important to maintain all documentation for two years, as stated in the order.
  • Will the PIC be held accountable for a passenger not having a valid PCR test if audited?
    • Still researching.
  • With regard to operational control and different operating regulations, 91, 91(k) and 135, where does the responsibility fall with asking passengers for test results and record holding?
    • Still researching.


  • Are crew members exempt?
    • According to the CDC’s FAQs: “Crew members on official duty, whether working or in an assigned deadhead status (transportation of a flight crew member as a passenger or non-operating flight crew member), are exempt from the testing requirement as long as they follow industry standard protocols for the prevention of COVID-19 as set forth in relevant Safety Alerts for Operators (SAFOs) issued by the Federal Aviation Administration (FAA).”
  • What is the CDC’s definition of “active crew?”
    • Still researching.
  • If you are crew and out of the country for several days waiting on passengers, are you still considered on-duty and exempt?
    • If you are part of the active crew on a trip, most countries view you as on-duty thereby exempting you from testing and quarantine requirements. There are some exceptions to this rule so it’s best to always check in advance for your particular destination. For the U.S., please refer to the crew exemptions referenced above.
  • Is a crew airlining out of country to pick up aircraft considered “active”. Do they have to get tested before leaving?
    • Still researching.


Air ambulance and medical flights

  • How does the CDC testing order impact medical and air ambulance flights? Can COVID patients still be transported?
    • Still researching.


  • Will Universal be providing these COVID ops requirements as part of the trips your managing for us?
    • For each potential mission with Universal, you will receive the latest information as it pertains to COVID requirements to assist you in preparing for your trip.
  • Any information on IATA developing a universally accepted “virtual COVID passport” that would be accepted by member nations as an official means of tracking testing compliance and/or vaccination proof?
    • Still researching.










    • Will Universal be providing these COVID ops requirements as part of the trips your managing for us?
    • Will Universal be taking steps or become a “records keeper” that might be used as a mediator between CDC and the Operator?
    • If an operator can’t find a testing location in time for the return flight back to the states, will they be required to stay 14-days before coming back to the U.S.?

Got a question for Adam about this article?